Where your customers are decides it. Serve customers in Singapore and a digital payment token business sits in the Payment Services Act regime, and that licence also lets you serve customers abroad. Serve only customers outside Singapore and you are in Part 9 of the Financial Services and Markets Act 2022, where MAS says it will generally not issue a licence.
What a Part 9 licence costs, in the regulations' own figures
Two public documents settle this: MAS's clarification statement of 6 June 2025 and section 137 of the Financial Services and Markets Act 2022. The shape of the choice is in choosing a licence.
Key takeaways
- The test is not where the company is registered. It is where the customers are.
- A Singapore corporation is caught "whether from Singapore or elsewhere" — moving the team offshore does not move the entity out of scope.
- Operating without the licence is a criminal offence: up to S$250,000 for a company, plus up to S$25,000 for each day it continues.
- Serve customers in Singapore under a Payment Services Act licence and MAS says you may also serve customers outside Singapore; that is the route that works.
Which Singapore crypto licence applies: the Payment Services Act or Part 9?
There is no single Singapore crypto licence. Section 137 of the Financial Services and Markets Act 2022 draws the line by who you are and where the business is carried on: a Singapore corporation is caught wherever it operates, an individual or partnership only through a place of business in Singapore, and a standard or major payment institution licence for a digital payment token service takes you outside the section 137 prohibition.
Who section 137 catches, and the one way out of it
| Your situation | The test | Provision |
|---|---|---|
| A Singapore corporation | Must not carry on a business, whether from Singapore or elsewhere, of providing any type of digital token service outside Singapore without a licence | s137(3) |
| An individual or a partnership | Must not carry on that business from a place of business in Singapore without a licence | s137(1) |
| Your main business is something else | Presumed to carry on a secondary business of providing the service; proving it is only incidental does not rebut that | s137(2) individuals and partnerships; s137(4) Singapore corporations |
| Licensed or exempt under the Payment Services Act for a digital payment token service | Subsections (1) and (3) do not apply to you | s137(5)(a)(iii) |
Which services count as a digital token service?
A digital token service is defined by activity, not by business label. Part 1 of the First Schedule lists ten services and Part 2 three carve-outs; dealing, facilitating an exchange, inducement and custody each count on their own. The table shows the rows firms get wrong most often.
Which activities count as a digital token service
| What you actually do | In scope? | Provision |
|---|---|---|
| Deal in digital tokens (buy or sell them for money or other tokens) | Yes | First Schedule Pt 1, 1(a) |
| Facilitate the exchange of digital tokens | Yes | Pt 1, 1(b) |
| Induce or attempt to induce someone to enter an agreement to buy or sell tokens | Yes, even holding nothing | Pt 1, 1(e) |
| Safeguard a digital token where you have control over it | Yes, custody on its own | Pt 1, 1(f) |
| Provide technical support and never at any time enter into possession of money or tokens | No | Pt 2, 1(a) |
| Provide a service for a limited purpose digital payment token | No | Pt 2, 1(c) |
| Serve tokens used only as utility or governance tokens | No, outside the new regime | MAS clarification, para 4 |
How the same activities are treated elsewhere is in which licence a crypto exchange needs.
What has MAS actually said about granting these licences?
MAS answered this in paragraph 2 of its clarification of 6 June 2025: it has set the bar high for licensing and will generally not issue a Part 9 licence, because the money laundering risks are higher and it cannot effectively supervise a firm whose regulated activity sits outside Singapore.
MAS has set the bar high for licensing and will generally not issue a licence.
The money laundering risks are higher in such business models and if their substantive regulated activity is outside of Singapore, MAS is unable to effectively supervise such persons.
Otonomos, a corporate-services firm, reported in September 2026 that MAS's Financial Institutions Directory listed 3,653 regulated entities across 48 licence types, and no Digital Token Service Provider among them. A third party's search on a stated date, not an MAS figure.
What does the licence cost to get, and to hold?
Getting and holding a Part 9 licence costs a company at least S$250,000 of base capital, a S$1,500 application fee and S$10,000 a year, plus an audit report on Form 3 within six months of each financial year end. Every figure comes from the Digital Token Service Providers Regulations 2025.
What the Part 9 licence costs and requires
| Item | Amount | Provision |
|---|---|---|
| Base capital, company applicant | At least S$250,000 | reg 7 |
| Base capital while the licence is in force | At least S$250,000 | reg 9 |
| Application fee | S$1,500 | the Schedule |
| Annual licence fee | S$10,000, however many services you provide | the Schedule |
| Audit report | Filed on Form 3 within 6 months of financial year end | reg 11 |
An individual applicant lodges a S$250,000 cash deposit with MAS instead. Substance requirements across jurisdictions are compared in local substance requirements explained.
What happens if you keep operating without one?
First, you have to stop: MAS required existing providers serving only customers outside Singapore to cease that activity when the Part 9 regime came into effect on 30 June 2025. Second, section 137(6) makes operating without the digital token service provider licence a criminal offence: up to S$250,000 for a company, plus up to S$25,000 for each day it continues.
Section 137(6) puts an individual at up to S$125,000 or up to three years' imprisonment or both, plus up to S$12,500 a day. After a refusal or forced wind-down, see what happens if your licence application is rejected.
So what is the route that actually works?
Paragraph 3 of the MAS clarification of 6 June 2025 carries the answer most readers skip: providers serving customers in Singapore are already regulated, nothing changes about what licensed providers can do, and such providers "may also provide services to customers outside of Singapore".
Under the Payment Services Act a digital payment token service needs a standard payment institution (SPI) or major payment institution (MPI) licence (s6(4)), and the major licence becomes mandatory once monthly average transaction value exceeds S$3 million for one payment service or S$6 million across two or more.
List your activities in the statute's words
Write down each thing you do using the First Schedule's language: control over tokens, dealing, inducement, technical support only.
Decide whether the Singapore customer side is real
The Payment Services Act route assumes you genuinely serve customers in Singapore and hold the corresponding licence.
If neither fits, change jurisdiction rather than forcing it
The nearest alternatives have their own thresholds: Hong Kong MSO and Canadian or US MSB, and VARA versus ADGM in the UAE.
What is changing next?
On 1 September 2026 MAS published a consultation paper on amendments to the Payment Services Act to implement its stablecoin framework, with comments due by 16 October 2026. Stablecoins that are not MAS-regulated will be treated as digital payment tokens, with the same consumer-protection requirements. The two-layer picture is set out in which licence for stablecoin payments and card issuing.
Frequently asked questions
Is there a VASP licence in Singapore?
No licence carries that name. A digital payment token business serving customers in Singapore applies for a standard or major payment institution licence under section 6 of the Payment Services Act. One serving only customers outside Singapore falls under the Part 9 digital token service provider (DTSP) licence, which MAS says it will generally not issue.
Our company is Singapore-incorporated but the team and customers are overseas — does the DTSP regime apply?
Yes. Section 137(3) applies to a Singapore corporation carrying on the business "whether from Singapore or elsewhere". For a corporation, section 137(4) adds that providing the service alongside a main business is presumed to be a secondary business, and showing it is only incidental does not rebut that.
Does non-custodial or technology-only work fall outside the regime?
It can, but the line is narrower than it sounds. Safeguarding a token you control is in scope in its own right. The carve-out covers a technical service provider that does not at any time enter into possession of money or tokens: one pass-through of customer funds takes you outside it.
The bottom line
This sets out public provisions and regulator statements; it is not legal advice. CryptoLicense is the licensing advisory brand of CL GLOBAL SDN BHD (1421939-T); Singapore is one of twelve jurisdictions we cover, and we have served 100+ companies: see our entity proof, the glossary and jurisdictions. No application can be guaranteed; the discretion belongs to the regulator. Banking after a licence is in can a licensed crypto business actually open a bank account.
Part of a series: the full guide is choosing a licence.