1. PSA payment service license and FSMA overseas DTSP system boundary
Standard payment institution license (SPI)
SPI is regulated by PSA, Basic capital is S$100,000, And applicable to a single item of 3 million, Multiple scale thresholds of SGD 6 million and other conditions. Whether digital payment token services can use SPI depends on the specific service., trading volume, Confirmation of client assets and MAS current policies.
Major payment institution license (MPI)
MPI is regulated by PSA, Basic capital is S$250,000, And provide a guarantee of S$100,000 or S$200,000 according to the applicable threshold.. Whether MPI is required depends on payment service and size, All “large digital asset institutions” or FSMA overseas DTSPs cannot be automatically classified into MPI.
Digital Token Service Provider (DTSP)
Part 9 of FSMA applies to relevant entities in Singapore that only provide regulated digital token services from Singapore to overseas.. From June 30, 2025, Those without permission are not allowed to continue relevant business; MAS said it will generally only issue licenses in very limited circumstances, It cannot be described as a regular "offshore license" that can be applied for.
AML/CFT and tax boundaries
DPT or DTSP business is subject to applicable MAS AML/CFT, sanctions, Travel Rule and Recording Requirements. Corporate income tax and tax treatment of crypto asset gains depend on the nature and facts of the income or capital, Flat tax benefits not covered by MAS license.
2. PSA SPI/MPI capital and FSMA DTSP fee verification boundary
| License plate type | legal basic capital (Base Capital) | Government application fee (Non-refundable) | Government annual license fee |
|---|---|---|---|
| Monetary Authority of Singapore (MAS) Payment Services License Guidelines (Standard payment institution) | 100,000 Shingen | Confirm according to the MAS fee schedule when applying | Confirmation of MAS fee schedule according to billing time |
| MPI (Major payment institutions) | 250,000 Shingen *A security deposit of S$100,000-S$200,000 is required. |
1,500 From SGD | 10,000 Shingen |
| MAS Digital Token Service Provider Licensing Guidelines(Only serving overseas customers) | MPI’s S$250,000 capital cannot be directly applied | Confirmed according to FSMA and MAS final charging rules | Confirmed by license category and current fee schedule |
illustrate: PSA applicants must demonstrate sufficient financial resources, But operating budget and basic capital are different concepts. Capital of FSMA DTSP, Fees and resource conditions are subject to final rules and MAS case confirmation, The 6 to 12 month buffer cannot be applied uniformly.
3. [Statutory Requirements for Corporate Governance and Local Substantialization] stipulated by MAS
Business location and contact person: PSA applicants must meet the permanent place of business or registered office in Singapore, Recordkeeping and Contact Requirements. Specific 10 days/8 hours, Personnel and venue arrangements are confirmed according to MAS's current licensing guidelines and application path.; FSMA DTSP is also reviewed according to its guidelines.
Executive Directors and Governance: The PSA path usually requires a Singapore Citizen or Permanent Resident Executive Director, Or an executive director with an employment pass and a citizen/permanent resident director. The personnel conditions of FSMA DTSP must be confirmed according to its independent system and MAS licensing policy.
Compliance function: DPT or DTSP applicants must have configurations commensurate with the risk and have actual authority, Resources and independence for the Compliance and AML/CFT function. Does it have to be in-house full time?, Residing locally and whether it can be part-time or outsourced, Must be confirmed according to the specific route and MAS current requirements.
Fit and proper review: directors, CEO, Partner, Key personnel and major shareholders accept integrity according to the applicable scope, Competence, Financial soundness and performance review. Experience must be commensurate with responsibilities, MAS does not set a uniform threshold of more than 5 years for all positions.
4. [List of statutory registration documents and external reports submitted to MAS for review]
| File category | Submission details of statutory requirements and interpretation of regulatory core (2024New regulations in August) |
|---|---|
| Mandatory legal opinion (Legal Opinion) |
When required by the MAS licensing guidelines, Analyze business under PSA or FSMA pathways by qualified legal counsel, Token, Serve, Regional peace exemption. The scope of application and lawyer qualifications shall be subject to the guidelines at the time of submission.. |
| Independent external auditor assessment (EA Assessment) |
AML/CFT and client asset protection inspections by assessors meeting MAS qualification and independence requirements where applicable. Assessment scope, The reporting timeliness and whether it is applicable to FSMA DTSP shall be confirmed according to the current guidelines.. |
| Compliance and Technology Risk Dossier (TRM) |
Business plans and financial forecasts, well with wallet, private key, trade, custody, Evidence of technical controls and testing commensurate with outsourcing and continuity risks; Specific years and independent testing confirmed by path and MAS list. |
5. Application and MAS review of PSA DPT and FSMA DTSP
first stage: Institutional classification, Entity and Governance Preparation
Determine PSA DPT or FSMA DTSP path, Prepare entity, shareholder, personnel, place, Capital, AML/CFT, Customer Assets and Technical Data, and obtain independent legal advice or control assessments where applicable.
second stage: Submit application and multiple rounds of inquiries
Submit via MAS designated forms and systems. MAS may issue supplementary questions and set a deadline for replying; The number of inquiries and overdue handling are determined based on individual cases and current procedures., Cannot preset fixed multiple rounds or automatically withdraw.
The third stage: Management briefing and fit and proper review
MAS can require managers to independently explain their business, Risks and Responsibilities. The consultant cannot answer for you; Whether to interview, object, The form and third-party participation boundary shall be determined according to the MAS case notification..
Stage 4: shelving mechanism (Trigger conditions apply)
significant equity stake, Management or business changes may result in reassessment or suspension. the term, Whether it will be extended and the consequences will be subject to the current MAS guidelines and case notifications..
The fifth stage: MAS Decisions and Conditions
If MAS issues a conditional decision, Applicants must complete the designated capital, personnel, Customer Assets and System Matters. PSA DPT and FSMA DTSP periods depend on the case, Officials do not guarantee a uniform range of 6 to 14 months or more than 12 months.
6. client assets, AML/CFT and technical risk requirements
Customer asset protection: Customer assets must be segregated when DPT services under PSA are applicable, and manage the trust in accordance with MAS rules, storage, Cold wallet ratio, Records and reconciliation. 90%Indicators such as cold wallets must not be automatically applied to FSMA DTSP or all businesses, Please check the current applicable rules.
Retail customer limits: DPT service providers are subject to applicable credit, lever, credit card, Token Lending and Staking Limits. The exact scope of the prohibition depends on the customer category, Services and MAS Current Consumer Protection Rules, It is not appropriate to generalize that all forms are prohibited.
AML/CFT与Travel Rule: Cash and bearer instrument restrictions, Information collection and verification thresholds are subject to applicable MAS notifications and transaction types.. 2Values such as 10,000/1,500 Singapore dollars may be adjusted according to the rules., Current thresholds should be reviewed when submitting and operating.
Technical availability and incident reporting: recovery goals, Unplanned downtime, Initial reporting and root cause analysis deadlines depend on system criticality and applicable MAS technical rules. 4Hour, 1The hourly and 14-day caliber must be confirmed item by item according to the current notification, It cannot be used as a unified red line for all DTSPs.
7. DPT/DTSP application support provided by Hong Kong Huitong
Local entity establishment and executive placement
can assistCombing Singapore Entities, Governance and staffing needs, and coordinate third-party services. banks, Directors and compliance officers are determined independently by the relevant agency and applicant, No guarantee of matching or account opening.
Core external audit reports and compliance documents
May assist in preparing plans and financial forecasts by business, and coordinate with a qualified attorney or independent evaluator. Legal opinions and independent assessments must be independently issued by corresponding professional institutions, Hong Kong Huitong cannot replace.
MAS case file submission and interview guidance
May assist with submission of applicable forms and inquiry preparation upon written authorization, and help management check responsibilities. Applicants are responsible for materials and responses; PSA Form 1 should not automatically apply to FSMA DTSP, The specific forms are determined according to the current MAS procedures..
8. Singapore Cryptocurrency and Payment Services License Core Legal Questions and Answers (FAQ)
9. Relevant regulations, Regulatory information and further reading
| Data category | Related information |
|---|---|
| Professional interpretation | |
| Fact-checking sources for this page |
