What does a Singapore DPT licence cover?

The PSA covers seven payment-service categories. This guide concentrates on DPT services, which include dealing, exchange platforms, transmission, custody and certain forms of facilitating transactions. If the same business also provides fiat payment services, those activities need to be assessed separately. MAS’s types of payment services

An MPI licence allows a firm to operate beyond the relevant Standard Payment Institution (SPI) thresholds. In summary, these include:

  • S$3 million in average monthly transactions for one relevant payment service.
  • S$6 million in average monthly transactions for two or more relevant payment services.
  • S$5 million under the Act’s prescribed daily e-money calculation.

The monthly averages are calculated over a calendar year, and the transaction tests exclude e-money account issuance and money-changing. The e-money test is separate from the value of DPTs held in customer wallets. An SPI licence may be suitable below the relevant thresholds; an MPI is not automatically required for every cryptocurrency business. Payment Services Act, section 6

Stablecoin projects need a separate look at token classification and issuance. Providing exchange, transfer or custody services and issuing a stablecoin are different questions. As at 6 October 2026, MAS is consulting on legislative amendments to implement its stablecoin framework. A DPT MPI licence is not blanket permission to issue a “MAS-regulated stablecoin”. MAS’s stablecoin consultation

Singapore DPT licence application checklist

For a new MPI application that includes DPT services, these are the main items to prepare. The checklist draws on the current licensing guidelines, MAS’s licence overview and the relevant application forms.

Area What to prepare
Entity and office A Singapore-incorporated company or Singapore branch of a foreign corporation, with a permanent place of business or registered office where records can be securely held and customer queries addressed.
Directors At least one executive director who is a Singapore citizen or permanent resident; or an Employment Pass-holder executive director plus another director who is a Singapore citizen or permanent resident. The CEO can also be the executive director.
Compliance function An independent, in-house local compliance officer at management level, with relevant expertise and authority. Identify the officer at application and employ and appoint them before commencing business. External or group support can supplement this arrangement.
Base capital For a Singapore-incorporated MPI, at least S$250,000, with an adequate buffer for operating costs and losses. A foreign-company branch has the corresponding net head office funds requirement.
Security A separate cash deposit or bank guarantee of S$100,000 or S$200,000, depending on transaction volumes. This must be in place before business begins.
Business plan Proposed products and services, target clients, jurisdictions, detailed transaction and funds-flow diagrams, third parties and implementation plans, supported by the management team’s experience.
Token and service risks A risk assessment of the tokens and services to be supported, their regulatory classification and the token-listing governance process.
Legal opinion An opinion from a law firm experienced in Singapore’s PSA, mapping the proposed products and services to the regulated activities.
Safeguarding and consumer protection Arrangements for customer assets, segregation, access controls, complaints, consumer access and conflicts of interest. Document the applicable safeguarding arrangements and have them in place before operations begin.
Ownership and organisation A complete shareholding and organisation chart, controller information, reporting lines and the outside-interest disclosures required by the relevant forms.
Independent assessments An AML/CFT and consumer-protection assessment report with the application, signed within the preceding three months. A technology and cybersecurity assessment follows in-principle approval.
Technology testing and ongoing audit For online financial services, penetration testing, remediation of high-risk findings and independent validation before licence grant. Plan for continuing technology controls, independent audit and the annual statutory audit.

The CEO and executive directors are expected to work full-time for the applicant and be based in Singapore. A non-executive director provides board oversight and does not need to hold a full-time executive role. MAS Form 3

This list is not exhaustive. The particular products, customers and operating arrangements determine what else the firm needs.

The obstacles most likely to hold up your application

Going through the checklist, it can certainly be a handful. Let’s break down the parts that deserve attention before you spend heavily on the application.

In our experience, some applications have taken around 8-12 months. That is not a reliable planning assumption for a fresh application today: MAS currently warns of a waiting period exceeding a year before an officer is available to review an application. The review and any remediation then take additional time. MAS Form 1 application page

External professional firms may also need additional time to review drafts and changes to the business plan or policies. So we really want to get this right before submission.

Your CEO, executive directors and compliance officer

First, let’s talk about the people. These individuals are key to the application, particularly the CEO and executive directors driving the business and the compliance officer responsible for keeping it in check.

For an overseas group, the local DPT compliance role cannot simply be handed to the head office. MAS expects an in-house local compliance officer. Group teams and external advisers can provide support, but the Singapore entity still needs someone with the expertise and authority to own the function.

For the CEO and executive directors, MAS looks at relevant payments or financial-services experience, understanding of the regulatory framework and the ability to oversee the business. Although the MPI guidelines do not prescribe a fixed five- or ten-year minimum, drawing on our experience with capital markets licence applications, we would expect at least ten years of directly relevant payments or financial-services experience to strengthen the application and give MAS greater confidence in the proposed leadership.

Managerial experience matters too, particularly if the firm intends to manage a sizeable team. As a practical benchmark, we would look for a CEO with five to ten years of genuine managerial experience, including having led a team in a regulated industry. This can considerably strengthen the application. Spending ten years working independently or in a junior role is a different track record from leading people and being responsible for their work. The CEO should be able to show whom they have managed, what responsibilities they held and how they exercised oversight.

The compliance appointment is at management level. In our view, the officer should be experienced enough to handle the firm’s policies, procedures and operational risks, and explain the controls when MAS asks questions. A fresh graduate can support the team, but leading this function requires experience, judgment and authority.

There is a practical reason to take this seriously: MAS’s licensing interview is for the applicant’s key management and compliance personnel. Consultants and external legal advisers cannot attend and answer on their behalf. Licensing guidelines, Appendix 5

Next, we have the business plan. MAS sets out a detailed list of what it expects, and the checklist above covers the main topics. The plan needs to show how the actual business works, including where money and tokens move, who handles them and which services the applicant provides.

A legal opinion maps that business model to the regulated payment services under the PSA. It does not guarantee that MAS will approve the application. MAS’s licensing-process requirements

From our experience in Singapore, the legal opinion for a DPT application can cost around S$30,000-S$50,000, depending on the business model and scope. This is separate from licensing-application support and other professional fees.

It makes sense to discuss the proposed scope and obtain a preliminary legal view before commissioning the full opinion. If the business plan keeps changing, the lawyer, compliance team and auditor may all have to revisit their work.

External assessments and cybersecurity work

Since we are on the subject of outside professionals, you will also need a suitably qualified independent external auditor for the licensing assessments.

The sequencing matters. The AML/CFT and consumer-protection report accompanies the application. The technology and cybersecurity assessment comes after in-principle approval. These assessments are separate from the annual statutory audit of accounts, transactions and regulatory compliance. Licensing guidelines, section 4.1, Payment Services Act, section 37

ISCA collates a list of external auditors available for the independent assessments. MAS does not endorse those firms, and choosing from the list is not mandatory. The applicant must assess whether its chosen auditor has the relevant experience and meets the criteria.

This brings us back to the compliance officer’s competence. A 10,000-word compliance manual - whether generated by AI or drafted by the best lawyers in Singapore - will not help if your compliance officer and operating team cannot understand or carry out the controls you have promised to MAS. The policies must be practical and risk-based, with controls commensurate with your firm’s business model, clientele and risk appetite.

Advisors Assemble can assist with reviewing the initial policies and controls and preparing for independent assessment. The external auditor must retain its independence.

For online financial services, penetration testing, remediation of high-risk findings and independent validation must be completed before the licence is granted. This work does not have to be finished before the initial application, but it needs to be planned and budgeted for. MAS’s technology-risk licensing criteria

Testing also continues after licensing. MAS’s Technology Risk Management Guidelines call for recurring vulnerability assessments and penetration testing of internet-accessible systems at least annually and following major changes. Technology Risk Management Guidelines, sections 13.1-13.2

Audit work continues too. The statutory external audit is mandatory every year, and the firm must also maintain independent audit arrangements to regularly assess whether its AML/CFT controls are working. The frequency and extent of those independent audits should reflect the firm’s risks, size and complexity. MAS’s annual audit guidance, PSN02 audit requirements and guidance

For a DPT firm, we recommend planning for an annual internal audit as a practical starting point, with additional reviews where the risks warrant them. As a working budget, allow around S$10,000-S$12,000 a year for an outsourced internal audit, depending on the scope and complexity. Statutory external audit fees are separate.

Capital and the cost of staying ready

The minimum base capital for a Singapore-incorporated MPI is S$250,000. The separate security amount is S$100,000 where the average monthly transaction value over a calendar year does not exceed S$6 million for each payment service, and S$200,000 otherwise.

Base capital is an ongoing regulatory calculation, rather than a frozen S$250,000 bank balance. Salaries, office costs, professional fees and operating losses still need funding, and the firm must continue to meet its capital requirement. Payment Services Regulations, regulations 12-13

That is why the minimum should not be your entire budget. You need enough room to prepare, wait and deal with additional questions without running out of cash halfway through.

Outside interests and conflicts of interest

In our experience, a blind spot in an application is often the key individuals’ outside business interests.

Even if you have engaged the right lawyers and auditors, hired competent people and prepared the paperwork, MAS will still examine who owns and runs the applicant, what else they are involved in and whether those interests create conflicts.

The details matter. Form 3 asks CEOs, directors and partners about their current directorships and other business positions, and outside holdings of 5% or more of voting shares. The controller form asks for other business interests and positions more broadly. Its “20% controller” definition includes at least 20% of shares or votes, alone or with associates. There is no universal five-percent exemption for controller disclosures. MAS Form 3, MAS Form 3A

For example, if a director owns another financial-services business, could the applicant favour that company in commercial dealings? If the director has another significant executive role, how much time will they have for the Singapore business?

Depending on the conflict and the proposed safeguards, an individual may need to change responsibilities, relinquish an outside role or dispose of a shareholding. It is not an automatic rule that every outside interest must be given up, but these are conversations worth having early.

MAS’s checks may also raise questions about adverse news or the regulatory history of related entities. Complete and accurate disclosures matter. Something left out can become a much bigger issue when the regulator discovers it later.

The Bsquared case is a reminder of the consequences of misleading the regulator. MAS identified materially false or misleading information on multiple occasions, alongside serious control weaknesses. MAS’s Bsquared announcement

Explain what the business brings to Singapore

All in all, the MPI licence journey is very frontloaded. MAS expects the applicant to be prepared with the infrastructure, the right people, appropriate security around its systems, a workable compliance setup and a reasonable war chest to begin operations in Singapore.

On the bright side, by the time the licence is granted, your firm should already have solid, internally approved policies and procedures, the right legal and compliance support, competent people to run the business and the necessary security controls. You can then get on with the business proper.

The job then shifts to maintaining that foundation: committed monitoring, regular updates to senior management, keeping policies current and dealing with risks as they arise. The controls you promised to MAS should not start unravelling because people become complacent, cut corners or assume someone else is taking care of them.

MAS also considers whether granting the licence would serve the public interest. A profitable business plan is important, but the application should explain the practical contribution it brings here. If your idea is stablecoin payments, for example, spell out how the service could help merchants, users or payment infrastructure in Singapore. Projected volumes and shareholder returns alone do not tell that story. MAS’s assessment criteria

If you have read this far and feel your team can meet the requirements, but need professional help to piece the application together and work through the blind spots, contact Advisors Assemble.

Our founder has served as Senior Compliance Manager Lead and the responsible Money Laundering Reporting Officer within a Singapore MPI licensed to provide DPT services. That hands-on experience, alongside previous fund management licence applications, informs how we approach regulatory questions, external assessments and the practical work of maintaining compliance.