Tokenization regulation · Singapore

Tokenization regulation in Singapore: MAS and the Securities and Futures Act

Tokenization is generally permitted in Singapore. The Monetary Authority of Singapore (MAS) takes a technology-neutral approach: a token that is a capital markets product under the Securities and Futures Act 2001 (SFA), such as a share, debenture or fund unit, is generally regulated like its non-tokenized equivalent, including prospectus and licensing rules.

Last updated:

Educational overview, not legal, tax or investment advice. Regulation changes, and the answer for any project depends on the asset, the structure, the investors and where they are. Consult qualified counsel in each jurisdiction before you issue, offer or market anything. Last reviewed 16 October 2026.

When is a digital token a capital markets product?

Under the SFA, capital markets products include securities (shares, debentures and units in a business trust), units in a collective investment scheme, derivatives contracts and spot foreign-exchange contracts for leveraged trading. If a token falls within one of these categories, the SFA rules for that product apply, regardless of the token format.

What rules apply to offering tokenized securities in Singapore?

Offers of tokenized securities, securities-based derivatives or fund units are subject to Part 13 of the SFA, as for non-tokenized ones. Generally, the offer must be made in or accompanied by a prospectus registered with MAS, and that prospectus should disclose tokenisation-specific features and risks (such as the DLT used, smart contracts and custody). Fund units also need authorisation or recognition. MAS lists exemptions, each subject to conditions including advertising restrictions:

  • Small personal offers of up to S$5 million in any 12 months.
  • Private placements to no more than 50 persons in any 12 months.
  • Offers to institutional investors only.
  • Offers to accredited investors.

Which licences do tokenization platforms need in Singapore?

  • Primary issuance platforms may be carrying on regulated activities and generally need a capital markets services (CMS) licence unless exempt.
  • Secondary trading platforms for tokenized securities may be operating an organised market and must be an approved exchange or recognised market operator unless exempt.
  • Custodians with possession or control of customers’ tokenized securities generally need a CMS licence for custodial services unless exempt.

What is Project Guardian?

Project Guardian is a MAS-led collaboration between policymakers and the financial industry to test asset tokenisation, described by MAS as a cross-border sandbox programme covering tokenised funds, bonds, stablecoins and bank liabilities. It has published the Guardian Fixed Income Framework and the Guardian Funds Framework.

How does Libertum fit in?

Libertum is a software platform (T-Suite). It is not licensed, registered or authorised in Singapore and is not a CMS licensee or a recognised market operator there. What the software does:

  • On-chain compliance rules. ERC-3643, CIP-113 and authorised XRPL tokens can enforce country allow/restrict lists, maximum balance, hold time and KYC claims, rejecting non-conforming transfers (Compliance).
  • KYC and KYB run through Sumsub.
  • Structuring module (Beta) with jurisdiction packs for El Salvador CNAD/LEAD, US SEC Reg D/Reg S, EU MiCA/MiFID II and Cayman Islands CIMA. Only the Cayman pack is counsel-reviewed and published; the others are drafts marked “Beta — pending counsel review”. Structuring is a software tool, not a Libertum legal or structuring service.

Libertum, S.A. de C.V. holds an El Salvador Digital Asset Service Provider (DASP) licence from the Comisión Nacional de Activos Digitales (CNAD), registry entry PSAD-0094, covering custody, exchange and transfer of USDT and USDC and receipt and transmission of client orders (LEAD Art. 19 (a), (d) and (f) numerals 1 and 2); RLUSD custody is approved by the CNAD under the same registration. It does not authorise any issuance, has effect in El Salvador only and confers no passporting or authorisation in Singapore. Issuers remain responsible, with their own counsel, for registration or exemption analysis in every jurisdiction. See Licences.

Related

Singapore tokenization FAQ

Is tokenization legal in Singapore?

Generally yes. If the token is a capital markets product under the SFA, the same prospectus, licensing and conduct rules apply as for the non-tokenized product, unless an exemption applies. Whether a token is one depends on its substance.

Does it matter whether a token is called a security token?

No. MAS deliberately avoids labels such as “security token” or “utility token” and looks at the token’s economic substance and rights under the SFA definitions.

Can a tokenized offer go to accredited investors only?

Yes, an offer to accredited investors is one of the exemptions MAS lists, subject to conditions including advertising restrictions.

Is Libertum licensed by MAS?

No. Libertum is a software platform and holds no MAS licence or recognition. Its El Salvador DASP licence (PSAD-0094) has effect in El Salvador only.

Primary sources

Last checked:

  1. MAS — Guide on the Tokenisation of Capital Markets Products (last updated 14 November 2025) — Replaces the 2017/2020 Guide on Digital Token Offerings; technology-neutral, 'same activity, same risk, same regulatory outcome'; definition of capital markets products (SFA s.2(1)); Part 13 SFA prospectus registered with MAS; exemptions (small personal offers up to S$5m, private placements to up to 50 persons, institutional and accredited investors); tokenisation-specific prospectus disclosure; CMS licence for primary platforms and custody; approved exchange or recognised market operator for trading platforms; Payment Services Act for other tokens.
  2. MAS — Project Guardian — Collaboration between policymakers and industry to test asset tokenisation; cross-border sandbox programme; Guardian Fixed Income Framework and Guardian Funds Framework; policymaker group members.

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