The Monetary Authority of Singapore’s (MAS) September 1, 2026 draft amendments to the Payment Services Act 2019 would let it designate any stablecoin circulating in Singapore as systemic, wherever it is issued, and then order licensed exchanges to delist it if the issuer does not meet MAS reserve and redemption standards. The power sits alongside an interest ban and a new stablecoin issuance licence, and comments close on October 16, 2026.

Singapore is turning a voluntary label into a supervisory perimeter. Consultation Paper P015-2026, published by the Monetary Authority of Singapore on September 1, 2026, adds a new Part 2A to the Payment Services Act 2019 (PS Act) under which MAS may designate a stablecoin as a “designated systemic stablecoin” by Gazette order (draft section 40B), regardless of whether the coin or its issuer is regulated in Singapore. Paragraph 4.9 of the paper says MAS could then direct digital payment token (DPT) service providers to delist the coin and its trading pairs. This analysis sets out what the draft text says, how it compares with the EU, US and UK, and what licensed exchanges should prepare for.

Sources and method behind this analysis

This analysis relies on five primary documents. They are MAS Consultation Paper P015-2026 (32 pages) and its Annex C, the 75-page consolidated draft of the amended PS Act, both linked from the MAS consultation page; the text of the Markets in Crypto-Assets Regulation (MiCA), Regulation (EU) 2023/1114; the enrolled GENIUS Act, Public Law 119-27; and the Bank of England’s November 10, 2025 consultation paper on sterling-denominated systemic stablecoins. The enforcement example comes from the Commodity Futures Trading Commission (CFTC) order against Tether, Docket No. 22-04. The time window runs from MAS’s first stablecoin consultation on October 26, 2022 to the current comment deadline. One caveat applies throughout: the Singapore text is a consultation draft. MAS says it will consult separately on the subsidiary legislation, which will contain most of the numbers, including redemption timelines and stress-test thresholds.

What the draft PS Act amendments actually say

The draft works in three layers. The first is a licence. Draft Part 2, Division 1 creates a new “stablecoin issuance” licence class, and draft section 5A reserves the terms “MAS-regulated stablecoin” and “MAS-regulated stablecoin issuer” for licensees. The framework covers single-currency stablecoins pegged to the Singapore dollar or a G10 currency. That scope dates from MAS’s August 15, 2023 finalised framework, which also requires issuers to return par value within five business days of a redemption request. Licensed issuers may not carry on other regulated business, such as banking, capital markets services or issuing non-MAS-regulated coins. They may, however, provide DPT services in their own coin where this is incidental to issuance.

The second layer adds requirements that were not in the 2023 framework. These are the interest ban in paragraph 3.2, quarterly stress testing, recovery and orderly wind-down plans, a requirement to safeguard customer money received before tokens are issued, and a technical capability to “trace, freeze and/or burn” coins used for illicit activity (paragraph 3.22). MAS is also consulting on a minimum share of reserves held as cash or bank deposits, and on caps on total issuance or individual holdings.

The third layer applies to coins that MAS does not license. It is the least discussed part of the paper, and it gives MAS the most reach.

A designated systemic stablecoin under Singapore’s draft Part 2A is a stablecoin that MAS has named by Gazette order because a loss of its value stability, or a disruption to its issuance, redemption, transfer or settlement, could cause systemic disruption to Singapore’s financial system or affect public confidence in it. Designation does not depend on where the issuer is incorporated. Paragraph 4.1 of Consultation Paper P015-2026 says the power applies “regardless of whether the stablecoin is issued in or outside of Singapore.” Once a coin is designated, draft section 40E requires its issuer to keep reserves at least equal to par, grant every holder a par redemption right and meet redemption requests within a period MAS sets. Breaches carry fines of up to S$250,000, plus S$25,000 a day. If the issuer fails these requirements, paragraph 4.9 says MAS may direct DPT service providers to stop offering the coin, delist it and prevent customers from buying more of it.

Draft section 40A comes before any designation. It lets MAS require any issuer or “participant” to supply issuance volumes, market value in circulation and partnership data. Paragraph 4.2 extends this to any token that “purport[s] to maintain a value” relative to a reference asset, including algorithmic designs. Failure to comply carries a fine of up to S$100,000 or two years’ imprisonment.

Jurisdiction / regulator	Effective date	Scope	Key requirement	Penalty / sanction
Singapore (MAS)	Consultation closes October 16, 2026; no commencement date set	Licensed SGD/G10 single-currency issuers; any coin designated systemic under draft s.40B, onshore or offshore	Par reserves and redemption (draft s.40E); interest ban (CP para 3.2); delisting directions to DPT providers (CP para 4.9)	Up to S$250,000 plus S$25,000 per day (s.40E); S$125,000 or three years for individuals holding out (s.5A)
EU (EBA / national authorities under MiCA)	Title IV applied from June 30, 2024	E-money token issuers; significant EMTs classified by the European Banking Authority (Article 56)	At least 30% of funds in credit-institution deposits (Article 54); interest ban on issuers and CASPs (Article 50); Article 23 transaction caps for non-EU-currency EMTs (Article 58(3))	Maximum fines of at least €5 million or 12.5% of annual turnover (Article 111(3))
US (Treasury / OCC under the GENIUS Act)	Earlier of January 18, 2027 or 120 days after final rules	Permitted and foreign payment stablecoin issuers; digital asset service providers	Interest ban (s.4(a)(11)); Treasury comparability findings for foreign regimes (s.18); secondary-trading ban on non-compliant foreign coins (s.8)	$100,000 per violation per day for platforms; $1 million per violation per day for foreign issuers (s.8)
UK (Bank of England, systemic regime)	Consultation paper November 10, 2025; closed February 10, 2026	Sterling stablecoins recognised as systemic payment systems	At least 40% of backing assets as unremunerated Bank deposits; up to 60% in short-term gilts	Proposed holding limits of £20,000 per individual and £10 million per business

Sources: MAS P015-2026 and Annex C; Regulation (EU) 2023/1114; Public Law 119-27; Bank of England CP, November 2025. Last updated: September 22, 2026.

How four jurisdictions compare on systemic coins

All four regimes accept that a stablecoin can grow large enough to matter to the domestic financial system. They differ on which tool they use to control that risk.

The EU’s main tool is classification plus a cap. Once the European Banking Authority classifies an e-money token as significant under Article 56 of MiCA, Article 58 applies the stricter reserve rules and requires independent audits every six months. For EMTs referencing a non-EU currency, Article 58(3) also applies the Article 23 limit: once a token averages more than 1 million transactions and €200 million a day as a means of exchange within a single currency area, the issuer must stop issuing it. The UK tool is structural. The Bank of England proposed that systemic sterling issuers hold at least 40% of backing assets as unremunerated deposits at the Bank, together with temporary holding limits. Our earlier analysis of the Bank of England’s stablecoin cap sets out how that design splits reserve models across the Atlantic.

The US and Singapore both reach offshore issuers through the platforms that list their coins. The GENIUS Act’s foreign-issuer route is a stablecoin issued outside the US that can stay on US trading platforms only if Treasury has found the home regime comparable under section 18 and the issuer registers with the Office of the Comptroller of the Currency (OCC). If a foreign issuer ignores a lawful order, section 8 requires Treasury to publish a noncompliance determination and a notice barring digital asset service providers from facilitating secondary trading in that coin. The ban takes effect 30 days after the notice. Platforms that knowingly continue face civil penalties of up to $100,000 per violation per day, and the issuer faces up to $1 million per violation per day. Singapore’s draft reaches the same result through different steps. Section 8 of the GENIUS Act starts from a failure to comply with a lawful order, while MAS starts from designation and then applies requirements. The practical difference is that MAS does not need a prior order before it can issue directions to platforms. Our coverage of the GENIUS Act deadline for foreign issuers explains why offshore issuers are still waiting for comparability findings.

Hong Kong adds a fifth reference point. Its Stablecoins Ordinance has made the issuance of fiat-referenced stablecoins a licensed activity since August 1, 2025. As we noted when Hong Kong issued its first stablecoin licences, that regime is built around licensing issuers, which leaves Singapore’s systemic designation power as the broader tool among the Asian financial centres.

The main regulatory-arbitrage risk is the gap between these tools. A dollar coin issued outside the US, the EU and Singapore could be treated as significant in Europe, face secondary-trading limits in the US and be designated as systemic in Singapore, with three different timetables and three different tests.

“MAS’ proposed legislative amendments will give effect to a stablecoin framework that promotes responsible financial innovation. The framework will provide clear regulatory guardrails for stablecoins that meet high standards of value stability and governance.”

— Ho Hern Shin, Deputy Managing Director (Financial Supervision), Monetary Authority of Singapore (MAS media release, September 1, 2026)

Enforcement context: what Tether’s reserve order shows

The clearest precedent for why regulators want audit, attestation and redemption powers over coins issued elsewhere is the CFTC’s settled order against Tether Holdings Limited and affiliates, CFTC Docket No. 22-04, dated October 15, 2021. The CFTC found that from September 2, 2016 to November 1, 2018, the fiat currency held in Tether’s designated bank accounts was less than the USDT tokens in circulation on 573 of 791 days. On that basis, the order says, the reserves were “fully-backed” by fiat currency in those accounts only 27.6% of the time. The order also found that reserves had at times been commingled with Bitfinex operational and customer funds, and that funds were held under at least 51 different third-party arrangements, only 22 of them documented by formal contracts. According to the CFTC press release, Tether agreed to pay a $41 million civil monetary penalty and to cease and desist. A separate order required Bitfinex to pay $1.5 million.

The order also records Tether’s own statement that it had never failed to meet a redemption request. That is the point MAS’s draft is designed to address. A coin can meet redemptions in normal markets while its reserves are weaker than its public statements claim, and a regulator overseas has little visibility until something breaks. Draft section 40G would let MAS require a designated issuer to appoint an auditor for a “reserve assets attestation” at a frequency MAS specifies and to publish each report. Refusal carries a fine of up to S$100,000 or two years’ imprisonment. Draft section 40A gives MAS the data before designation, so it would not depend on the issuer’s public disclosures to decide whether a coin matters to Singapore.

Singapore also enforces through the DPT licence. MAS revoked the major payment institution licence of Bsquared Technology Pte Ltd with effect from May 14, 2026, ending its authority to provide DPT services under the PS Act. The circulation-restriction power would apply that same licensing leverage to the coins that licensed platforms list.

What this means for exchanges, issuers and compliance teams

Licensed DPT exchanges and brokers. The obligations fall mainly on intermediaries. Question 16 of the paper asks about reporting requirements for all licensed DPT service providers, and draft section 40A treats them as “participants” required to answer MAS information notices. Exchanges should be able to report, for each coin that claims a stable value, the balances held for Singapore customers, trading volumes and any issuer partnership. Question 19 asks what notice period should apply before a delisting direction and what recourse customers should have. Platforms should work out how quickly they could close trading pairs and handle customer withdrawals under that kind of direction.

Retail-facing platforms. Paragraph 6.2 proposes that licensed DPT providers give retail customers disclosures on the reserves backing non-MAS-regulated stable-value tokens, add risk warnings that these tokens are not regulated by MAS for value stability, and stop marketing them as “stablecoins.” The existing DPT consumer protection rules, including the ban on offering financing, margin or leverage and on accepting locally issued credit cards, continue to apply to those tokens.

Issuers and banks. Licensed issuers must segregate the issuing entity from other business. Under paragraph 6.3, banks and merchant banks that want to issue an MAS-regulated coin must do so through a separate non-bank legal entity. Wholesale and merchant banks remain barred from issuing Singapore-dollar coins that retail users can trade freely. Issuers planning joint issuance from more than one jurisdiction will need an exemption under draft section 100A, reserves that meet the stricter of the MAS rules and the foreign rules, and reserve rebalancing arrangements approved by MAS, with daily records submitted to MAS each month.

Legal and compliance teams. The interest ban in paragraph 3.2 excludes “revenue-sharing, distribution, service or other commercial arrangements” between issuer and third party. This is narrower than MiCA’s Article 50, which also prohibits crypto-asset service providers from granting interest. Our coverage of the US stablecoin yield ban and Coinbase’s USDC rewards shows how quickly distributor rewards fill that kind of gap.

“Seizing a first-mover advantage is imperative given that the MAS is expected to issue only a small number of licences and grant recognition on a limited basis.”

— Etelka Bogardi, partner, and Jeremy Koo, associate, Reed Smith, Singapore (Reed Smith client alert 2026-179)

What’s next: the forward view on MAS stablecoin rules

The consultation closes on October 16, 2026, and MAS has not published a commencement date. Several further steps are already signalled in the paper. MAS will consult on subsidiary legislation, which will set redemption timelines, stress-test thresholds and the conditions for recognising foreign coins under draft Part 2B. It will consult “at a later time” on resolution planning for designated systemic issuers (paragraph 4.7). It will issue a Notice setting out the trace, freeze and burn capabilities (paragraph 3.22), and separate guidance on tokenised deposits (paragraph 6.4). MAS is also still deciding whether to require minimum cash and deposit holdings and whether to cap issuance or individual holdings. Paragraph 3.7 notes that the UK and EU already require or will require deposit floors of 5% to 30% for non-systemic coins and 40% to 60% for systemic ones.

The designation criteria are the open question. Paragraph 4.10 lists size, links to payment systems, links to the wider financial system and substitutability. Footnote 12 says these metrics will not trigger designation automatically. That gives MAS discretion but gives issuers little certainty, and the only appeal route under draft section 40B is to the Minister, whose decision is final. Timing outside Singapore matters too. The GENIUS Act takes effect by January 18, 2027 at the latest, and a Treasury comparability finding for Singapore would affect whether MAS-regulated coins can be used on US platforms. As we reported on the MiCA and GENIUS Act stablecoin deadlines, issuers are already structuring around each of these regimes. A Singapore designation power would add a further regime to that planning.

Recognition of foreign coins is limited. MAS says in paragraph 1.3 that it expects to authorise or recognise “a limited number” of stablecoins, assessed on financial soundness, business viability and operational track record. Joint issuance from Singapore and another jurisdiction was not permitted under the 2023 framework, and the draft now allows it case by case. Issuers such as the one behind the SBI and Coinhako JPYSC project will be watching how narrowly MAS applies that exemption.

FAQ

What is a designated systemic stablecoin in Singapore?

It is a stablecoin that MAS names by Gazette order under draft section 40B of the amended Payment Services Act. MAS can do this if a loss of the coin’s value stability, or a disruption to its issuance, redemption or settlement, could cause systemic disruption or damage public confidence in Singapore’s financial system. Designation applies whether the coin is issued in Singapore or overseas. Its issuer must then keep reserves at least equal to par and honour redemptions at par within the period MAS sets.

Can MAS force exchanges to delist a stablecoin?

Under the proposal, yes. Paragraph 4.9 of Consultation Paper P015-2026 says amendments to sections 102 and 103 of the PS Act would let MAS direct licensed DPT service providers to stop offering a designated systemic stablecoin that fails MAS requirements. MAS could also require them to delist the coin and its trading pairs and to stop customers from buying more of it. MAS is asking what notice period should apply and what recourse customers should have.

Does the MAS proposal ban stablecoin interest?

Yes, for issuers of MAS-regulated stablecoins. Paragraph 3.2 prohibits issuers from paying holders “interest, return, or any other benefit” that is directly or indirectly linked to holding the coin. The ban does not cover revenue-sharing, distribution or service arrangements between the issuer and third parties. That is narrower than Article 50 of MiCA, which also bars crypto-asset service providers from granting interest on e-money tokens.

Which stablecoins can be labelled MAS-regulated?

Only single-currency stablecoins pegged to the Singapore dollar or a G10 currency, issued by a holder of the new stablecoin issuance licence. Draft section 5A makes it an offence for anyone else to use the label. Individuals face up to S$125,000 or three years’ imprisonment, and firms face up to S$250,000, with daily fines for continuing breaches. Coins without the licence remain digital payment tokens under the existing DPT regime.

When will the MAS stablecoin amendments take effect?

MAS has not set a date. The consultation closes on October 16, 2026. MAS will then consult separately on subsidiary legislation, resolution planning for systemic issuers and an anti-money laundering Notice on trace, freeze and burn capabilities. The amendments also need to pass Parliament, so the paper does not give a firm commencement date.

This article is informational analysis only and does not constitute legal, regulatory, tax, or investment advice. Regulatory frameworks change frequently and interpretation depends on facts and circumstances; primary documents and official regulator guidance always supersede summaries. Firms should consult qualified legal counsel and their relevant supervisory authority before taking any action based on the analysis above.