Regulatory and Licensing Advisory for a Singapore MAS DPT Licence

Singapore offers one of the clearest licensing regimes in Asia for businesses that provide digital payment token services. The MAS licence under the Payment Services Act is the entry point, and the review is rigorous.

We advise founders on the licence class, prepare the application and compliance framework with specialist counsel, and coordinate the formation of the Singapore Pte. Ltd. through licensed local corporate service providers. The licence is issued to the client, and the client operates the business. Our role is advisory.

What is a DPT licence?

Under Singapore’s Payment Services Act 2019, a business that provides digital payment token services needs a licence from the Monetary Authority of Singapore. This includes dealing in digital payment tokens, operating an exchange or facilitating token exchanges.

MAS supervises DPT service providers for AML/CFT, technology risk and consumer protection.

Company requirements

A licensed company needs a Singapore-resident director, a company secretary, a registered address and the base capital required for its licence class, typically S$250,000 for a Major Payment Institution.

MAS expects a permanent place of business in Singapore and a management team that runs the business locally. We advise on the local team structure and on how to present it in the application.

AML/CFT framework

MAS expects a full compliance framework before it reviews the application: AML/CFT policy, technology risk management framework, cybersecurity policy and business continuity plan. The compliance officer must be fit and proper.

Source-of-funds checks, transaction monitoring and Travel Rule compliance are standard. We prepare these policies with specialist counsel before the application is filed.

Travel Rule and stablecoins

MAS applies the Travel Rule to DPT service providers: originator and beneficiary information must be collected and shared for transfers above a threshold. The client’s systems must support this before launch.

If a project issues or facilitates a stablecoin, the licence class depends on the design. We review the token design before the application so that the licence class matches the product.

The management team

MAS looks closely at the people behind the application. At least one senior manager must be resident in Singapore and actively involved. The CEO, compliance officer and technology risk officer must be fit and proper, with relevant experience.

Banking

We prepare the compliance file that banks and EMIs review: evidence of the MAS application, business plan, shareholder structure, source of funds and a clear revenue model. The account decision is the bank’s. DBS, OCBC and UOB review licensed and applicant companies case by case.

We sequence the work so that the MAS file is complete before any bank approach, since banks review the same documents.

Timeline and cost

Company formation: 1–3 days. Application preparation: 2–4 months. MAS review: 6–9 months for straightforward cases, longer for complex models. Total first-year cost: S$50,000–120,000 including legal, compliance, local directors and capital.

FAQ

Who needs a DPT licence? A business that deals in, or facilitates the exchange of, digital payment tokens in or from Singapore.

What is the difference between DPT and other payment services? DPT covers digital payment tokens. Other payment services cover fiat money transfer, e-money and merchant acquisition.

Do I need a local director? Yes. At least one director must be ordinarily resident in Singapore.

How long does the review take? Typically 6–9 months after a complete application.

Does INNOVA handle client funds or tokens? No. We advise and prepare documentation. The licensed company operates its own services.