Crypto Law Profile

Singapore Expanded Payment Services Act DPT Amendments

Singapore’s 2021 Payment Services Act amendments expanded MAS oversight of DPT services, including custody, transfer and exchange facilitation, with user-protection rules phased in during 2024.

Singapore Effective Act Apr 4, 2024

At a glance

Status In force in Singapore; DPT safeguards were phased in by Oct. 4, 2024.
Regulator MAS supervises payment service providers under the PS Act framework.
DPT scope Adds DPT custody, transfer facilitation, and exchange facilitation to regulated services.
Transition Newly scoped-in providers received temporary notification and licensing pathways.

Overview

Singapore’s expanded Payment Services Act amendments for digital payment token services refer to the Payment Services (Amendment) Act 2021 and the 2024 subsidiary legislation that brought a broader set of digital payment token (DPT) activities under the Monetary Authority of Singapore’s payment-services framework. The regime is in force as of 6 June 2026. The main commencement date for the amendment act was 4 April 2024, while customer-asset and related user-protection rules under the 2024 regulations were phased in on 4 October 2024.

Expanded DPT scope under the Payment Services Act

The amendments extend the regulated perimeter beyond earlier DPT dealing and exchange activity. They bring into scope DPT custody, arranging the transmission of DPTs between accounts, and inducing or arranging DPT exchange activity, including models where the service provider facilitates a transaction without taking possession of the customer’s money or tokens. This structure is designed to capture virtual-asset service provider activity that may present payment, money laundering, terrorism financing, customer-asset, or operational risks even where the provider is not the direct holder of transaction assets.

The package also affects cross-border money-transfer activity. MAS described the expansion as covering facilitation of cross-border money transfer between countries even where moneys are not accepted or received in Singapore. That element is relevant for businesses operating from Singapore that arrange payment flows outside Singapore, but the precise licensing analysis depends on the statutory definitions, exemptions, and MAS guidance applicable to the particular activity.

Digital payment token custody and user protection

The Payment Services (Amendment) Regulations 2024 add a dedicated set of requirements for licensees that provide DPT services. From 4 October 2024, the regulations require customer assets received by a DPT service licensee to be deposited in a trust account or returned to the customer no later than the next business day. Trust accounts must be designated and maintained separately from the licensee’s own assets, and assets in such accounts are not to be used for payment of the licensee’s debts.

The regulations also address operational controls around custody. DPT service licensees must keep customer-asset records, assess safeguarding persons where customer assets are held with a third party, provide written disclosures on commingling and insolvency consequences, and maintain systems and controls for asset-safeguarding risks. These provisions are part of the broader MAS move to impose user-protection, AML/CFT, and financial-stability-related requirements on DPT service providers under the payment-services regime.

Transitional arrangements and affected firms

Entities that were already conducting newly scoped-in activities were given transitional arrangements through the 2024 saving and transitional provisions. The transition framework was intended to avoid an abrupt cliff edge for businesses brought into the licensing perimeter, while requiring affected firms to notify MAS, seek licensing where relevant, and support applications with external auditor attestations.

For CryptoSlate reference purposes, this profile should be read alongside the broader Singapore Payment Services Act 2019 profile. The amendment package is not a standalone crypto code; it modifies Singapore’s existing payment-services licensing architecture and should be understood as a perimeter and conduct update for DPT activity. It also sits alongside other MAS materials for DPT service providers, including AML/CFT notices, conduct notices, disclosure rules, and consumer-protection guidelines.

Status and review posture

As of 6 June 2026, the amendment act is treated here as in force. The 2024 regulations show a two-step phase-in: certain regulations commenced on 4 April 2024, and the main additional DPT customer-asset requirements commenced on 4 October 2024. Editors should periodically review MAS and Singapore Statutes Online for later amendments to DPT licensing, custody, consumer access, and digital-token service provider rules. This profile is descriptive only and should not be read as legal, compliance, tax, investment, or trading advice.

Key provisions

Expanded DPT service perimeter

Brings DPT custody and facilitation of DPT transmission or exchange within PS Act regulation, including non-possession models.

Licensing Apr 4, 2024 Source

Cross-border transfer facilitation

Extends cross-border money-transfer coverage to arranging transfers between countries even where funds are not accepted in Singapore.

Payments Apr 4, 2024 Source

Customer asset safeguards

Requires DPT customer assets to be placed in trust accounts or returned, with separation from the licensee’s own assets.

Custody Oct 4, 2024 Source

MAS user-protection powers

Empowers MAS to impose AML/CFT, user-protection, and financial-stability-related requirements on DPT service providers.

Consumer protection Apr 4, 2024 Source

Transitional arrangements

Provides temporary pathways for newly scoped-in entities to notify MAS, seek licensing, and support applications with audit attestations.

Licensing Apr 4, 2024 Source

Timeline

  1. Amendment bill passed

    Parliament passed the Payment Services (Amendment) Bill to expand DPT and related payment-service coverage.

    Passed Source
  2. Presidential assent

    The Payment Services (Amendment) Act 2021 received assent as No. 1 of 2021.

    Enacted Source
  3. MAS announces expansion

    MAS announced expanded payment-service scope and DPT user-protection requirements.

    Enacted Source
  4. Amendment Act commenced

    The Payment Services (Amendment) Act 2021 came into operation.

    In force Source
  5. DPT safeguard rules phased in

    Additional customer-asset, custody, recordkeeping, and control requirements for DPT service providers commenced.

    In force Source

Who it affects

Actors

Digital payment token service providers, Monetary Authority of Singapore, Payment service providers

Asset classes

Digital payment tokens

Official sources

Editorial note

This profile covers the 2021 amendment act and 2024 instruments implementing expanded DPT service scope. It is descriptive and does not provide legal advice.