LedgerBeat / Crypto Exchange Licensing Requirements in Singapore - A Complete 2025 Guide

Crypto Exchange Licensing Requirements in Singapore - A Complete 2025 Guide

Crypto Exchange Licensing Requirements in Singapore - A Complete 2025 Guide

Singapore Crypto Exchange License Calculator

Recommended License Type

License Details

Minimum Capital Required:

Application Timeline:

Compliance Staff Required:

Annual Legal Fees:

Cost Breakdown
Expense Category Standard License Major License
Legal & Consulting Fees SGD 30-45k SGD 55-80k
Technology & Security Upgrades SGD 20-40k SGD 50-90k
Ongoing AML Compliance Staff 1-2 FTEs (~SGD 80k/yr) 2-4 FTEs (~SGD 180k/yr)
Note: This calculator provides estimates based on current Singapore regulations. Actual requirements may vary. Consult with a licensed compliance consultant for precise guidance.

Singapore just rolled out the toughest crypto‑exchange licensing rules in the region. If you’re planning to run a digital token platform from the Lion City, you need to know what the Monetary Authority of Singapore (MAS is the country’s central bank and financial regulator) expects in terms of capital, compliance and reporting. This guide walks you through every step - from the legal backdrop to the actual paperwork you’ll file - so you can decide whether Singapore is still a viable launchpad for your business.

TL;DR - Quick Takeaways

  • Effective 30June2025, all crypto platforms must qualify as a Digital Token Service Provider (DTSP) under the Financial Services and Markets Act.
  • Two main licenses: Standard Payment Institution (≤SGD3M/month, SGD100k capital) and Major Payment Institution (>SGD3M/month, SGD250k capital).
  • MAS NoticePSN02 forces the same AML/KYC standards as banks - continuous monitoring, SAR filing, and full audit trails.
  • Application takes 3‑6months for a standard license, 6‑12months for a major one; expect legal fees of SGD30‑80k.
  • Compared to EU MiCA or US state‑by‑state rules, Singapore is faster but less forgiving - no transition period.

Regulatory Landscape - What Changed in 2025?

Before June2025, many crypto firms operated in Singapore under the Payment Services Act (PSA) of 2019. The MAS‑issued final consultation on 30May2025 added the Financial Services and Markets Act (FSMA) provisions, creating the DTSP regime. The change closed a loophole that let firms serve offshore clients without a local license.

Key takeaways:

  1. All crypto‑related activities - exchange, custody, token issuance - are now classified as “regulated activity” under FSMA.
  2. There is no grace period - you either obtain a DTSP license on day one or shut down.
  3. MAS aligns AML/CTF obligations (NoticePSN02) with those imposed on traditional banks.

License Types, Capital Requirements & Operational Scope

The PSA still defines three categories, but for crypto exchanges the relevant ones are the Standard and Major Payment Institution licenses. Below is a side‑by‑side view.

Standard vs. Major Payment Institution License
Attribute Standard Payment Institution Major Payment Institution
Monthly transaction volume Up to SGD3million Above SGD3million
Minimum paid‑up capital SGD100,000 SGD250,000
Risk management depth Basic controls, quarterly reporting Enhanced controls, continuous monitoring, annual external audit
AML/CTF obligations NoticePSN02 compliance, annual SAR filing Full‑scale AML program, real‑time transaction screening
Application timeline 3‑6months 6‑12months

For most startups, the Standard license is the entry point. However, if you anticipate rapid growth or plan to list multiple high‑value tokens, the Major license may save you a costly upgrade later.

Step‑by‑Step Application Process

Getting the green light involves a marathon of documents. Below is the typical checklist:

  1. Business Plan: Clear mission, revenue model, projected cash flows (12‑month outlook), and market‑entry strategy.
  2. KYC/AML Policy: Tailored to NoticePSN02 - include customer onboarding flow, risk‑based profiling, and SAR escalation matrix.
  3. Internal Controls Manual: Transaction processing, fund segregation, cyber‑security safeguards, and incident‑response procedures.
  4. Risk Assessment Report: Identify market, operational, and compliance risks; outline mitigation (e.g., automated monitoring, third‑party audit).
  5. Capital Proof: Bank statements or a letter of credit showing the required SGD100k or SGD250k is readily available.
  6. Audit Reports: Internal audit summary for the past 12months; for Major licenses, attach a signed external audit.
  7. Fit‑and‑Proper Test: Background checks on directors, senior managers, and key compliance officers.

The MAS portal accepts a single PDF bundle. Expect one to three rounds of feedback - MAS is strict about formatting and completeness.

AML, KYC & Ongoing Compliance Obligations

AML, KYC & Ongoing Compliance Obligations

NoticePSN02 treats crypto platforms like traditional banks. In practice, you’ll need to:

  • Verify identity for every user (government ID, proof of address, facial verification).
  • Run real‑time transaction monitoring against watch‑lists (OFAC, UN sanctions).
  • Generate a Suspicious Activity Report (SAR) within 24hours of detection.
  • Maintain a five‑year audit trail of all token movements, wallet addresses, and counterparties.
  • Submit quarterly AML compliance reports to MAS, including volume metrics and risk‑score statistics.

Failing any of these triggers a licence suspension or revocation - MAS has already warned that enforcement actions will be swift.

Costs, Timeline & Resource Allocation

Beyond capital, the real expense is professional services. A typical cost breakdown looks like this:

Expense CategoryStandard LicenseMajor License
Legal & consulting feesSGD30‑45kSGD55‑80k
Technology & security upgradesSGD20‑40kSGD50‑90k
Ongoing AML compliance staff1‑2 FTEs (~SGD80k/yr)2‑4 FTEs (~SGD180k/yr)

Expect the entire onboarding journey to span 4‑8months, depending on how polished your documentation already is. Early engagement with a MAS‑approved compliance consultant can shave weeks off the timeline.

How Singapore Stacks Up Against Other Jurisdictions

When you compare the Singapore regime to the EU’s MiCA, the US fragmented state approach, or Switzerland’s high‑capital model, a few patterns emerge:

  • Speed: Singapore’s rules became effective overnight, whereas MiCA gave operators a three‑year transition.
  • Capital Barrier: SGD100k-250k is modest versus CHF1‑3million required in Switzerland.
  • Uniformity: Unlike the US, where each state may impose its own crypto licence, MAS offers a single, nationwide standard.
  • Enforcement: Singapore’s no‑transitional‑period stance signals tougher enforcement compared to Hong Kong’s more lenient pilot scheme.

If you value regulatory certainty and can meet the capital and compliance costs, Singapore remains the most practical Asian hub for a crypto exchange.

Practical Tips & Common Pitfalls

Here are lessons from operators who have already navigated the MAS maze:

  • Start the KYC engine early: MAS will audit your onboarding workflow; a half‑baked solution will delay approval.
  • Document everything: Even internal SOPs must be signed and version‑controlled. Missing signatures are a frequent rejection cause.
  • Use a local bank: Some offshore banks refuse to hold the required capital. Partner with a Singapore‑based bank that understands crypto.
  • Plan for post‑licence audits: MAS expects annual external audits for Major licences. Build that cost into your financial model now.
  • Don’t chase offshore clients only: The DTSP framework explicitly bars firms that serve “solely overseas” users without a Singapore‑centric business purpose.

Next Steps - Your Immediate Action Plan

Whether you’re still in the idea phase or already have a prototype, follow this short roadmap:

  1. Map your projected monthly transaction volume to decide between Standard and Major licence.
  2. Engage a Singapore‑based compliance consultant within the next two weeks.
  3. Compile the business plan, capital proof and AML policy - aim for a 30‑page dossier.
  4. Submit a pre‑application enquiry through the MAS portal to confirm required documents.
  5. Allocate at least SGD50k for legal and tech upgrades before the formal application.

Once you’ve cleared the MAS gate, you’ll gain access to a regulated market that’s among the most attractive in Asia - provided you stay on top of the ongoing compliance calendar.

Frequently Asked Questions

Frequently Asked Questions

Do I need a licence if I only serve foreign users from a Singapore entity?

Yes. The DTSP framework explicitly requires a licence for any crypto service operating out of Singapore, even if its customers are abroad. MAS will reject applications that lack a genuine Singapore‑centric business purpose.

Can I start with a Standard licence and upgrade later?

You can, but the upgrade process is as rigorous as a fresh Major licence application. Expect another 6‑12months of review and additional capital injection.

What are the penalties for AML non‑compliance?

MAS can impose fines up to 10% of annual turnover, suspend the licence, or order a complete shutdown. Re‑licensing after a sanction requires a clean audit and a new fit‑and‑proper test.

Is there a minimum number of employees required?

MAS does not set a strict headcount, but you must have at least one qualified compliance officer and a senior manager who passes the fit‑and‑proper test. Realistically, teams of 3‑5 for a Standard licence and 6‑10 for a Major licence are common.

How does the Singapore regime compare cost‑wise to Europe’s MiCA?

Capital requirements are lower (SGD100k vs. EU’s €350k‑€1M depending on asset class). However, Singapore’s compliance onboarding is faster, while MiCA offers a longer transition but higher legal fees due to the multi‑jurisdictional nature of the EU.

24 comment

Sidharth Praveen

Sidharth Praveen

Great rundown! If you're eyeing Singapore, the speed of the MAS process really plays to your advantage-just make sure you lock down that SGD 100k capital early and line up a compliance officer who can hit the ground running. A solid business plan with clear revenue streams will shave weeks off the review, and partnering with a local bank that understands crypto can smooth the capital proof step. The good news is the regulator’s focus on AML is transparent, so once you have your policies in place, the rest is mostly paperwork. Keep the momentum, and you’ll be trading in less than a year.

Sophie Sturdevant

Sophie Sturdevant

Listen, the MAS ecosystem expects full‑stack compliance architecture-think end‑to‑end KYC/AML pipelines, real‑time transaction screening, and a documented risk‑based client segmentation matrix. Your legal counsel should draft a DTSP‑compliant AML policy that references Notice PSN02 verbatim; otherwise you’ll be flagged for non‑conformity. Don’t underestimate the capital adequacy ratio; the minimum SGD 250k for a Major license isn’t a suggestion, it’s a hard floor tied to the liquidity coverage ratio. Secure a Singapore‑based custodian early, integrate their AML API, and you’ll avoid the typical “missing signature” rejections that stall the 6‑12 month review.

Nathan Blades

Nathan Blades

Stepping into Singapore’s crypto regulatory arena feels like navigating a tightrope over a bustling cityscape-one misstep can send you plummeting, but a well‑balanced approach can give you a panoramic view of the market’s future. First, recognize that the Payment Services Act is not just a legal requirement; it’s a framework that embodies the city‑state’s ethos of trust, security, and innovation working hand‑in‑hand. By aligning your internal controls with the MAS’s Notice PSN02, you signal to regulators that you respect the same safeguards that traditional banks uphold. This alignment starts with a robust KYC engine that captures not only documents but also behavioural analytics, flagging anomalous patterns before they become systemic risks. Second, the capital requirement, while modest compared to Swiss standards, serves as a liquidity buffer that protects both users and the platform during market turbulence. Treat that capital as a strategic reserve rather than a sunk cost; allocate a portion to a high‑yield, low‑risk instrument that can cover unexpected audit fees or SAR filings. Third, technology upgrades are the backbone of compliance-implementing blockchain analytics tools that trace token flows in real time will reduce manual workload and impress MAS auditors. Fourth, the human element cannot be overstated. Hiring a seasoned compliance officer with a track record in AML and a deep understanding of MAS expectations will accelerate the application timeline and reduce the likelihood of re‑submission. Empower that officer with a clear escalation matrix so that any red flag is addressed within the mandated 24‑hour window. Fifth, documentation is the lifeblood of the application; every SOP, risk assessment, and internal audit report must be version‑controlled, signed, and stored in a secure, encrypted repository. Sixth, engage with a MAS‑approved consultancy early on. Their institutional knowledge of the form‑filling nuances and formatting quirks often shaves weeks off the process. Seventh, plan for post‑licence obligations: schedule quarterly AML reports, conduct annual external audits, and maintain an ongoing training program for staff to keep them abreast of evolving threats. Eighth, be aware of the geopolitical context-Singapore’s neutrality makes it a hub for cross‑border transactions, but that also subjects you to heightened scrutiny from foreign regulators. Build a compliance bridge that can satisfy both MAS and, for example, EU MiCA requirements if you intend to serve European clients. Ninth, the market perception of a Singapore‑licensed exchange can be a competitive advantage; use it in your marketing narrative to attract institutional investors who demand regulatory certainty. Tenth, finally, treat the entire licensing journey not as a hurdle but as an opportunity to embed best‑in‑class governance into the DNA of your platform. By the time you receive that approval, you’ll have a resilient, compliant, and scalable operation ready to thrive in the global crypto economy.

Somesh Nikam

Somesh Nikam

Here’s a quick checklist to keep you on track:
1️⃣ Draft a detailed business plan with projected cash‑flows.
2️⃣ Develop a KYC/AML policy that mirrors Notice PSN02.
3️⃣ Prepare a risk‑assessment report outlining market and operational risks.
4️⃣ Secure proof of the required paid‑up capital (SGD 100k or 250k).
5️⃣ Arrange a senior compliance officer and obtain fit‑and‑proper certificates.
6️⃣ Compile all documents into a single PDF bundle for the MAS portal.
7️⃣ Schedule a pre‑application enquiry to confirm any missing items. Following these steps reduces the chance of a “document incomplete” rejection. Good luck! 😊

Debby Haime

Debby Haime

Don’t let the paperwork intimidate you-tackle it one chunk at a time. Start with the capital proof, then lock down the AML policy, and finally polish the business plan. Each milestone you clear shortens the overall timeline, and the confidence you gain shows up in the MAS review.

emmanuel omari

emmanuel omari

Anyone thinking they can bypass Singapore’s strict capital requirements is simply naïve; the MAS will not tolerate shortcuts, and foreign banks that refuse to hold the required SGD 250k capital are clearly not aligning with national financial sovereignty.

Andy Cox

Andy Cox

Singapore’s licensing is fast but not cheap.

Courtney Winq-Microblading

Courtney Winq-Microblading

Speed without a solid compliance foundation is like sprinting downhill without brakes-exhilarating at first, but you’ll quickly lose control when the slope steepens.

katie littlewood

katie littlewood

Reading through the guide feels like assembling a puzzle where each piece-capital, AML, tech upgrades, and staffing-fits together to reveal a clear picture of a thriving exchange. I love how the author emphasizes the importance of starting KYC development early; that’s a lesson we’ve learned the hard way in other jurisdictions. The side‑by‑side cost breakdown is especially useful for budgeting, and I appreciate the candor about legal fees ranging up to SGD 80k for a major license. It’s also refreshing to see the contrast with EU MiCA, reminding us that Singapore offers a more streamlined path while still demanding rigorous compliance. For anyone on the fence, the practical tips about using a local bank and planning for post‑license audits are gold nuggets that can save months of trial and error. Overall, this guide is a solid roadmap that turns a daunting regulatory maze into a series of manageable steps.

Jenae Lawler

Jenae Lawler

While the guide paints Singapore as the “most practical Asian hub,” one must consider that the zero‑tolerance stance on offshore client focus may marginalize startups whose primary market lies outside the region, thereby undermining the very scalability the article lauds.

Chad Fraser

Chad Fraser

That’s a fair point, but the regulatory certainty and single‑jurisdiction licence still outweigh the geographic limitation for many firms looking to establish a credible foothold.

Jayne McCann

Jayne McCann

Honestly, the “fast” licence sounds like a marketing gimmick; I’ve heard of firms waiting months for a simple form to be approved.

Richard Herman

Richard Herman

It can feel that way, yet the majority of applicants who submit a complete, well‑structured dossier typically see approval within the advertised 3‑6 months for a standard licence.

Parker Dixon

Parker Dixon

🚀 The key takeaway: start building your AML engine now, even if you’re only aiming for a standard licence. Early integration means you won’t have to do a massive overhaul later when you scale to a major licence. Plus, having that system in place shows MAS you’re serious about risk management, which can shave weeks off the review. Keep the documentation tidy, use version control, and don’t forget to schedule regular internal audits. 👍

Stefano Benny

Stefano Benny

From a compliance architecture perspective, the recommendation to “use a Singapore‑based custodian” may overlook the emerging trend of decentralized custody solutions that can meet MAS security standards without the overhead of traditional banking relationships.

Bobby Ferew

Bobby Ferew

I guess the guide is helpful, but the cost tables seem a bit optimistic; real world consulting fees can easily eclipse the high‑end estimates, especially when you factor in the need for ongoing legal counsel.

celester Johnson

celester Johnson

One could argue that the regulatory landscape is a mirror reflecting the underlying trust in the financial system; if the MAS enforces stringent AML measures, perhaps the market should adapt rather than complain about the “burden.”

Prince Chaudhary

Prince Chaudhary

It’s worthwhile to remember that the fit‑and‑proper test isn’t merely a formality; the MAS looks closely at directors’ past conduct, so ensure your governance records are spotless before you submit.

John Kinh

John Kinh

Honestly, reading this feels like a sales pitch; I’m not convinced the “quick 4‑8 month onboarding” applies to everyone. 🤷‍♂️

Mark Camden

Mark Camden

From a principled standpoint, any entity that disregards the meticulous documentation standards set by MAS not only jeopardizes its own licence but also erodes the broader credibility of the crypto ecosystem in Singapore.

Evie View

Evie View

People need to stop glorifying “speed” and start respecting the depth of compliance required; cutting corners will only lead to punitive fines and reputational damage.

Kate Roberge

Kate Roberge

But hey, if you’re comfortable with the heavy AML workload, the Singapore route might just be the “sweet spot” between EU red tape and US fragmentation.

Oreoluwa Towoju

Oreoluwa Towoju

Start with a local compliance consultant; they’ll guide you through the MAS forms and save you weeks of guesswork.

Jason Brittin

Jason Brittin

Sure, because nothing says “I’m serious about finance” like adding a smiley to a legal compliance discussion. 😒

Write a comment