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Singapore applies a consistent substance-over-form classification test: fungible, non-pegged mediums of exchange are digital payment tokens; capital-markets-characteristic tokens are securities; utility/governance tokens sit outside both perimeters. NFTs are not currently regulated as a category absent embedded capital-markets characteristics. Stablecoins currently classify as DPTs, with a prospective, distinctly labelled 'MAS-regulated stablecoin' category pending legislative codification.
NFTs occupy a distinct position within this framework. As of MAS's 2022 parliamentary reply, NFTs are not regulated as a category, reflecting the nature of the assets most NFTs represent (predominantly digital art and collectibles) and MAS's technology-neutral, look-through stance toward the underlying rights an NFT confers rather than its technical form. Where an NFT does embed capital-markets-product characteristics -- for example, rights to a portfolio of listed shares -- the Securities and Futures Act's collective-investment-scheme provisions would apply, subjecting the arrangement to the same prospectus, licensing and conduct requirements as any other capital-markets product. This conditional look-through rule means the absence of NFT-specific regulation is a description of current market composition rather than a permanent regulatory gap.
Stablecoins present the most structurally unsettled classification question. Single-currency stablecoins pegged to the Singapore dollar or a G10 currency and issued in Singapore are, today, classified and regulated as digital payment tokens under the existing PS Act framework. MAS's finalised stablecoin policy design contemplates a further, distinctly labelled 'MAS-regulated stablecoin' category once that framework is codified into primary legislation -- meaning the same instrument currently sits under one classification with a second, more specific classification pending enactment.
Outlook
Classification methodology itself is stable and unlikely to shift; MAS's substance-over-form test has been applied consistently since 2019 and shows no signs of revision. The open item is temporal rather than doctrinal: the stablecoin classification will bifurcate further once the 'MAS-regulated stablecoin' label is codified, and NFT treatment could shift if NFT products embedding capital-markets or payment characteristics become more prevalent in the Singapore market, triggering the existing look-through rules rather than requiring new doctrine.
Token Classification
Singapore's token-classification boundary for stablecoins sits mid-reform. Pending the commencement of MAS Consultation Paper P015-2026, a Singapore stablecoin issuer that does not meet, or does not seek, the MAS-regulated stablecoin label is treated under the Payment Services Act 2019 as an ordinary digital payment token, requiring a Major Payment Institution digital-payment-token licence like any other digital payment token. This is the current, in-force classification position, but it is explicitly provisional: CP P015-2026 proposes to carve statutorily-defined stablecoins meeting the par-reserve and redemption test out of the general digital-payment-token category into their own distinct classification, with a correspondingly distinct regulatory regime of reserve, redemption, capital and interest-ban obligations that does not apply to the broader digital-payment-token category.
The practical consequence of this transition period is that an issuer's classification — and therefore its compliance obligations — depends on which side of the still-being-drawn statutory line its stablecoin eventually falls. An issuer currently licensed as a Major Payment Institution digital-payment-token provider for a stablecoin product may need to assess, once CP P015-2026 is finalised, whether its product qualifies for or is required to seek the new regulated-stablecoin classification, or whether it will continue to be treated as an ordinary digital payment token under the existing framework.
Outlook
The classification boundary will not be settled until CP P015-2026's subsidiary legislation is finalised following the 16 October 2026 consultation close. Issuers currently operating under the ordinary digital-payment-token classification should expect this boundary to shift, though the precise criteria separating a statutorily-defined stablecoin from an ordinary digital payment token remain to be fixed in the final legislative text.
Sources and findings (6)
- T2 · Bank for International SettlementsPayment Services Act 2019 — A unit of value that is fungible, not denominated in or pegged to any currency, and is/intended to be a medium of exchange, as a digital payment token (DPT)retrieved M4bindingin forcenew
- T1 · Monetary Authority of SingaporeSecurities and Futures Act 2001 — Digital tokens meeting the definition of a capital markets product (e.g., tokenised shares, debentures or business trust units) as securities subject to prospectus, licensing and business-conduct requirementsretrieved M4bindingin forcenew
- T1 · Monetary Authority of SingaporeMAS regulatory perimeter — Tokens used only as utility or governance tokens without capital-markets or payment characteristics from MAS's licensing and regulatory remitretrieved M3bindingin forcenew
- T1 · Monetary Authority of SingaporeMAS — NFTs, given the nature of their underlying assets (predominantly digital art and collectibles), applying a technology-neutral look-through stanceretrieved M2non-bindingnew
- T1 · Monetary Authority of SingaporeSecurities and Futures Act 2001 — An NFT possessing capital-markets-product characteristics (e.g., rights to a portfolio of listed shares) subject to prospectus, licensing and business-conduct requirements as a collective investment schemeretrieved M3bindingin forcenew
- T1 · Monetary Authority of SingaporeMAS Stablecoin Regulatory Framework — Single-currency stablecoins pegged to SGD or a G10 currency, issued in Singapore, as digital payment tokens today, prospectively recognisable as 'MAS-regulated stablecoins' once the framework is codified in primary legislationretrieved M5bindingnew