Summary
The proposition is sound if it compares issuer scarcity in Hong Kong with service-provider depth in Singapore. It is misleading if it treats the licence counts as equivalent.
Hong Kong
The Stablecoins Ordinance directly regulates specified stablecoin issuance. The HKMA register lists two issuer licensees: Anchorpoint Financial Limited and The Hongkong and Shanghai Banking Corporation Limited. Both licences took effect on 10 April 2026. Stablecoins Ordinance (Cap. 656), ss. 15 and 21.
The HKMA received 36 first-batch applications and granted two licences. That record supports describing the route as “selective.” It does not establish the individual disposition of every other application.
Cap. 656 reaches a specified stablecoin only. Section 3 excludes central-bank and government issuance and limited purpose digital tokens under Cap. 615. It also excludes securities and futures contracts under Cap. 571, deposits under Cap. 155, and a float or an SVF deposit under Cap. 584. A token answering one of those descriptions falls outside Cap. 656 and must be assessed under the law applicable to that classification. Stablecoins Ordinance (Cap. 656), ss. 3–4; HKMA, Explanatory Note on Licensing of Stablecoin Issuers, para. 2.1.
Subject to an exemption under section 13, section 9 confines offering to a permitted offeror. Section 9(5) defines five categories: a licensee, an authorized institution, an SFC Type 1 licensed corporation, a licensed virtual asset trading platform, and a stored value facility licensee. An over-the-counter dealer that holds none of those permissions and has no section 13 exemption cannot offer or hold itself out as offering a specified stablecoin to the Hong Kong public. Stablecoins Ordinance (Cap. 656), ss. 9(5) and 13.
Singapore
The MAS Financial Institutions Directory shows 38 results under the combined filters “Major Payment Institution” and “Digital Payment Token Service.” The Payment Services Act regulates DPT dealing, exchange, transmission, custody and related services. Payment Services Act 2019, ss. 5–6 and First Sch.
The 38 results are not stablecoin issuer licences. An MPI licence authorizes the listed payment services of the licensee. It does not approve each token handled by that licensee.
An MPI licence carries fixed entry conditions. MAS requires Singapore incorporation or a Singapore branch, a permanent place of business, base capital of at least S$250,000, and a security deposit lodged before the licensee commences business. MAS, Guidelines on Licensing for Payment Service Providers (PS-G01).
Section 21A of the Payment Services Act and Division 2A of the Payment Services Regulations 2019 require a digital payment token service provider to segregate customer assets and hold them on trust. MAS expects at least 90 per cent of customers’ tokens in cold wallets. MAS, Guidelines on Consumer Protection Measures by DPT Service Providers (PS-G03).
Comparison
The legally matched comparison needs two layers. The first compares issuer authorization. The second compares exchange, custody, transfer, brokerage, payment and distribution permissions.
Hong Kong provides a direct statutory issuer route for an own-brand stablecoin that falls within Cap. 656. Singapore has an established population of licensed DPT intermediaries, represented by 38 current MPI entries.
A Singapore-incorporated business serving only overseas customers does not obtain an easy alternative route. Part 9 of the Financial Services and Markets Act 2022 applies to relevant offshore-only digital-token services. MAS states that it generally will not license that model.
Both regimes reach outside their own territory through different connecting factors. Cap. 656 follows the reference currency and the marketing target. Part 9 of the Financial Services and Markets Act 2022 follows the place of incorporation and the place of business.
Retail access diverges at a different point in each regime. Subject to section 13 exemptions, Hong Kong permits an offer to the Hong Kong public only where a licensee issued the specified stablecoin. Singapore allows a payment-service licensee authorised for DPT service to serve retail customers, subject to MAS limits on lending, staking and incentives.
The two figures measure different permissions.
Hong Kong’s figure measures licensed issuers under the Stablecoins Ordinance. Singapore’s figure measures institutions licensed to provide DPT services under the Payment Services Act. One concerns creation and maintenance of a regulated stablecoin. The other concerns services performed in relation to a broad class of digital tokens.
The comparison therefore supports a route-selection statement. It does not support a claim that Singapore has licensed 38 stablecoin issuers. It also does not prove that Singapore applies a lower approval threshold.
The figures contain a further timing difference. Singapore’s Payment Services Act commenced in January 2020. Hong Kong’s Stablecoins Ordinance commenced on 1 August 2025. The HKMA granted its first licences on 10 April 2026. Singapore’s 38 results represent an accumulated service-provider population. Hong Kong’s two licences represent the first issuer cohort.
Which digital assets fall inside each perimeter
Neither regime applies to every token. The classification question comes first in each, and it disposes of many business models before any licensing question arises.
Cap. 656 applies to a specified stablecoin. Section 3 defines a stablecoin as a digital representation of value that satisfies the provision’s functional and technological elements and purports to maintain stable value by reference to a single asset or a pool or basket of assets. Section 4 makes it a specified stablecoin where the reference runs wholly to one or more official currencies, or to another unit of account or store of economic value specified by the HKMA in the Gazette. Section 3 also excludes central-bank and government issuance, limited purpose digital tokens under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615), securities and futures contracts under the Securities and Futures Ordinance (Cap. 571), deposits under the Banking Ordinance (Cap. 155), and a float or an SVF deposit under the Payment Systems and Stored Value Facilities Ordinance (Cap. 584). Stablecoins Ordinance (Cap. 656), ss. 3–4; HKMA, Explanatory Note on Licensing of Stablecoin Issuers, para. 2.1.
The Payment Services Act starts from the opposite end and does not define a stablecoin. It defines a digital payment token, then regulates services performed in relation to that class. A stablecoin meeting the statutory description of a digital payment token attracts the same service licensing as any other token in the class. Payment Services Act 2019, First Sch.
The sequencing differs as a result. A Hong Kong analysis begins with the token, because a token that is not a specified stablecoin falls outside Cap. 656. A Singapore analysis must identify both a DPT and a listed payment service. Section 5 attaches the licence to the service provided, while the First Schedule determines whether the instrument is a DPT and whether the activity is a DPT service.
Hong Kong measures access to regulated issuance
Section 8 of the Stablecoins Ordinance prohibits unlicensed regulated stablecoin activity. Section 5 captures specified stablecoins issued in Hong Kong in the course of business. It also captures an overseas issuance referencing the Hong Kong dollar. Active marketing to the Hong Kong public can amount to holding out as carrying on regulated activity. Stablecoins Ordinance (Cap. 656), ss. 5 and 8.
This perimeter gives the Hong Kong route substantial extraterritorial relevance. An offshore issuer cannot avoid the Ordinance merely by locating minting operations outside Hong Kong. An HKD reference or Hong Kong-directed active marketing may engage the licensing prohibition.
A licence requires satisfaction of the minimum criteria in Schedule 2. A non-bank applicant ordinarily needs a Hong Kong-incorporated company. For such an applicant, the financial-resource test includes at least HK$25 million in paid-up share capital or approved equivalent resources. The issuer must maintain segregated reserve assets, preserve full backing, grant redemption rights and maintain suitable management, risk, technology and anti-money-laundering controls. Stablecoins Ordinance (Cap. 656), Sch. 2.
Those duties attach to the issuer and its stabilization mechanism. They justify treating the licence as an institutional issuance authorization, not a general crypto-business licence.
The selectivity proposition has direct regulatory support. The HKMA publicly stated that approval thresholds would be high and only a handful of licences would initially be granted. It received 36 first-batch applications. It granted licences to Anchorpoint and HSBC. The current issuer register contains those two licensees. HKMA, “Granting of Stablecoin Issuer Licences” (10 Apr. 2026); HKMA, Register of Licensees under the Stablecoins Ordinance (accessed 13 Aug. 2026).
The numbers do not reveal the legal status of each unsuccessful applicant. Public materials may not distinguish refusals, withdrawals, incomplete applications and applications resolved through another process. The defensible statement is that two of the 36 first-batch applicants obtained licences.
Issuance permission also does not settle distribution. Section 9 separately restricts offering a specified stablecoin. Subject to section 13 exemptions, the offeror must be a permitted offeror, and retail distribution depends on the issuer’s status. A business model may therefore require an issuer licence, permitted-offeror status and other intermediary permissions. Stablecoins Ordinance (Cap. 656), ss. 9 and 13.
What a Hong Kong licensee must maintain after grant
The minimum criteria in Schedule 2 are continuing conditions. The HKMA treats failure to meet any of them as a ground for revocation or disciplinary action. HKMA, Explanatory Note on Licensing of Stablecoin Issuers.
Reserve management carries the heaviest continuing burden. The licensee must maintain a separate pool of reserve assets for each type of specified stablecoin it issues. The market value of that pool must at all times equal at least the par value of the outstanding stablecoins of that type in circulation. The licensee must segregate the pool, place it under custody arrangements acceptable to the HKMA, and obtain independent attestation at a frequency the HKMA accepts. Stablecoins Ordinance (Cap. 656), Sch. 2.
The Ordinance gives the holder a redemption right against the issuer. A holder who satisfies the applicable conditions may request the par value in the reference asset. The licensee must meet a valid request without imposing an onerous condition or an unreasonable fee.
Schedule 2 also fixes the licensee’s corporate form. A non-bank licensee must be a company incorporated in Hong Kong under the Companies Ordinance (Cap. 622). An authorized institution incorporated outside Hong Kong may hold the licence instead. Each chief executive, director, stablecoin manager and controller must be a fit and proper person approved by the HKMA.
Section 16 of Schedule 2 requires recovery planning and orderly wind-down. The licensee must implement systems of control that support timely recovery and continuity of critical functions after a significant operational disruption. It must also hold a business exit plan covering the scenarios that would make an orderly exit necessary, with monitoring for those scenarios. HKMA, Explanatory Note on Licensing of Stablecoin Issuers, para. 3.14.
Who may offer a specified stablecoin in Hong Kong
Section 9 controls distribution and operates independently of the issuer licence. Subject to an exemption under section 13, only a permitted offeror may offer a specified stablecoin in Hong Kong or hold out as offering one to the Hong Kong public. Section 9(5) lists five categories: a licensee under the Ordinance, an authorized institution under the Banking Ordinance (Cap. 155), a corporation licensed by the SFC for Type 1 regulated activity under the Securities and Futures Ordinance (Cap. 571), a licensed virtual asset trading platform, and a stored value facility licensee under the Payment Systems and Stored Value Facilities Ordinance (Cap. 584). Stablecoins Ordinance (Cap. 656), ss. 9(5) and 13; HKMA, Explanatory Note on Licensing of Stablecoin Issuers, para. 2.10.1.
The audience a permitted offeror may address turns on how the token was issued. A specified stablecoin whose issue is authorized by an HKMA licence may be offered to the Hong Kong public, including retail investors. If its issue is not prohibited by section 8 but is not authorized by a licence, section 9(2)(b)(iii) limits the offer to the class specified by the Financial Secretary, currently professional investors as defined in section 1 of Part 1 of Schedule 1 to the Securities and Futures Ordinance. These rules remain subject to exemptions under section 13. Stablecoins Ordinance (Cap. 656), ss. 9(2) and 13; Stablecoins Ordinance (Specification of Persons for Purposes of Section 9(2)(b)(iii)) Notice (Cap. 656A).
Two consequences follow for a distribution chain. An over-the-counter dealer that holds none of the five permissions and has no section 13 exemption cannot offer or hold itself out as offering a specified stablecoin to the Hong Kong public, including a United States dollar stablecoin issued offshore. Under section 9(2), a licensee may only engage a permitted offeror to offer a specified stablecoin the issue of which is authorized by a licence. A third-party distributor must itself be a permitted offeror or exempt, because the issuer’s own licence does not confer permission on the distributor. Stablecoins Ordinance (Cap. 656), ss. 9(2), 9(5) and 13.
Section 6 also reaches conduct outside Hong Kong. A person who actively markets to the Hong Kong public an activity that would constitute an offer if carried on in Hong Kong is treated as holding out as offering. Contravention of section 8(1) is an offence, and section 9 carries a separate offence for unauthorized offering. Both offences carry maximum penalties fixed by the Ordinance. This route comparison does not quantify enforcement exposure. Stablecoins Ordinance (Cap. 656), ss. 6, 8 and 9.
Singapore’s 38 results measure DPT intermediation
Section 5 of the Payment Services Act prohibits a person from carrying on a business of providing any type of payment service in Singapore without the required licence or exemption. A major payment institution licence may authorize one or more listed payment services. Payment Services Act 2019, ss. 5–6.
“Digital payment token service” is an activity category. Its current statutory scope includes dealing in DPTs, facilitating exchange, transmitting DPTs or arranging their transmission, inducing transactions, safeguarding DPTs or DPT instruments, and carrying out customer instructions where the provider controls the relevant DPTs or instrument. Payment Services Act 2019, First Sch.
A DPT is broader than a stablecoin. Bitcoin, payment-oriented cryptoassets and qualifying stablecoins can fall within the category. The licence therefore concerns the service, not one approved token design.
As of 13 August 2026, MAS’s directory returns 38 results when filtered for:
- Sector: Payments;
- Licence type: Major Payment Institution; and
- Activity: Digital Payment Token Service.
MAS, Financial Institutions Directory (accessed 13 Aug. 2026).
The result set includes businesses with materially different operating models. It includes exchanges, custodians, brokers, payment firms and financial institutions. Some institutions hold other financial-services licences. The directory itself warns that an institution may hold multiple licences.
The count therefore proves that Singapore has a sizeable licensed DPT-service population. It does not prove any of the following:
- 38 stablecoins have been approved;
- 38 firms hold stablecoin issuer licences;
- all 38 firms may perform every possible DPT activity;
- all 38 received licences during one application round; or
- MAS approved the reserve or redemption terms of each stablecoin they handle.
The count also cannot establish an approval rate. No comparable denominator of completed, rejected and withdrawn MPI applications appears in the cited directory.
What an MPI licence for digital payment token service requires
The directory count describes a licence population. The conditions behind the licence set the actual cost of entry.
Section 6(5) of the Payment Services Act draws the line between the two institution classes. A firm falls into the major payment institution class where monthly transactions average more than S$3 million for any one payment service, or more than S$6 million across two or more services, or where daily outstanding e-money averages more than S$5 million. Payment Services Act 2019, s. 6(5).
MAS applies fixed conditions to an MPI applicant. The applicant must be a Singapore-incorporated company or a Singapore branch of a foreign corporation. It must hold a permanent place of business or registered office where books and records are securely kept, with a person present to handle consumer queries. Base capital must be at least S$250,000, and MAS expects a buffer above that floor matched to the scale of operations. The applicant must also lodge a security deposit with MAS before it commences business. MAS, Guidelines on Licensing for Payment Service Providers (PS-G01), para. 3.1.
Custody duties attach to the digital payment token service specifically. Section 21A of the Payment Services Act empowers MAS to prescribe requirements for a licensee providing that service, and Division 2A of the Payment Services Regulations 2019 carries them. A provider must segregate customer assets from its own and hold them on trust, depositing assets received from a customer into a trust account by the next business day. MAS expects the provider to keep at least 90 per cent of customers’ tokens in cold wallets and to run a custody function operationally independent of other business units. MAS, Guidelines PS-G03.
Conduct limits bite on the retail side. MAS restricts a digital payment token service provider from facilitating lending or staking of a retail customer’s tokens. That restriction does not extend to institutional and accredited investors. MAS also restricts incentives offered to attract retail customers. MAS, “MAS Publishes Investor Protection Measures for Digital Payment Token Services” (3 July 2023); MAS, “MAS Strengthens Regulatory Measures for Digital Payment Token Services” (23 Nov. 2023). MAS Notice PSN02 carries the anti-money laundering duties that attach to the service.
Commencement dates matter to any firm reading the directory. Relevant provisions of the Payment Services (Amendment) Act 2021 commenced on 4 April 2024 and widened the digital payment token service definition to cover transfer, facilitation of exchange without possession, custody of tokens and token instruments, inducement, and carrying out customer instructions in specified circumstances. The customer asset requirements commenced on 4 October 2024. Before those dates, the statutory definition was narrower and the customer-asset requirements had not commenced. Existing licensees became subject when the provisions commenced, subject to applicable transitional arrangements.
Singapore’s proposed stablecoin issuer status is separate
MAS finalized policy features in 2023 for single-currency stablecoins issued in Singapore and pegged to the Singapore dollar or a G10 currency. The proposed status would identify qualifying products as “MAS-regulated stablecoins.”
That policy contemplated issuer-level requirements concerning reserve assets, redemption, capital and disclosures. It therefore resembles Hong Kong’s issuer route more closely than a DPT-service MPI licence does.
The official materials located through 13 August 2026 did not show that the dedicated issuer legislation had taken effect. A 15 October 2025 parliamentary reply stated that MAS was preparing legislation. A 13 November 2025 MAS speech stated that draft legislation would be prepared.
MAS had earlier granted in-principle approval under the Payment Services Act to three entities whose proposed stablecoins would substantively comply with the announced regime. Those approvals did not commence the new issuance service or create the statutory “MAS-regulated stablecoin” designation. MAS, “Shaping the Financial Ecosystem of the Future” (15 Nov. 2023).
The 38 MPI results should not be presented as licences under that proposed issuer regime. An MPI holding DPT-service permission may handle stablecoins within its authorized activities. That status does not itself entitle the firm or token to the “MAS-regulated stablecoin” designation.
What changes for a Singapore intermediary if the issuer regime commences
MAS announced on 15 August 2023 that it would add a stablecoin issuance service as a payment service under the Payment Services Act. No legislation had brought that service into force as at 13 August 2026. The requirements below are announced policy features, not enacted rules.
The announced conditions sit above the MPI conditions already described. An issuer of an MAS-regulated stablecoin would hold reserve assets equal to at least 100 per cent of the par value in circulation, denominated in the pegged currency, segregated and held with an approved custodian. Independent attestation would run monthly and audit annually. Base capital would be the higher of S$1 million or 50 per cent of annual operating expenses. The issuer would return par value within five business days of a redemption request. MAS, Stablecoin Regulatory Framework (15 Aug. 2023).
Two scope limits shape who the announced regime would catch. A non-bank issuer whose in-scope single-currency stablecoins in circulation do not exceed, and are not anticipated to exceed, S$5 million would fall outside its mandatory application. Tokenised bank liabilities would sit outside the announced scope, with MAS reserving the ability to impose requirements later.
Current law does not list stablecoin issuance as a separate payment service. An issuer may still require DPT-service permission if its activities amount to dealing, transmission, safeguarding or another listed service involving its token. If the announced issuance service commences, an in-scope non-bank issuer would need the new permission to provide that service and use the “MAS-regulated stablecoin” label. Any re-permissioning risk therefore depends on the issuer’s circulation, activities and eligibility; it does not arise merely because the firm issues a Singapore dollar stablecoin today.
The proper comparison has two layers
At the issuer layer, the relevant Hong Kong route is the Stablecoins Ordinance licence. The matched Singapore reference is MAS’s dedicated stablecoin issuer policy and any legislation that brings it into force. The DPT MPI count is not the matched Singapore figure.
At the intermediary layer, Singapore’s DPT-service MPI population is commercially relevant. The matched Hong Kong analysis should examine permitted-offeror status, authorized-institution permissions, SFC-licensed virtual-asset trading platforms and other applicable intermediary licences.
This two-layer method avoids an apples-to-oranges conclusion while preserving the useful commercial distinction:
- Hong Kong currently provides a scarce, operative issuer route.
- Singapore currently provides an established licensed DPT-service channel represented by 38 MPI entries.
- Singapore’s separate stablecoin issuer status was not found in force as of 13 August 2026.
Territorial reach compared
Each regime reaches past its own borders through a different connecting factor, and a structure that escapes one factor can meet the other.
Cap. 656 follows the token and the audience. Section 5 captures issuance of a specified stablecoin in Hong Kong in the course of business. It also captures issuance outside Hong Kong where the stablecoin purports to maintain a stable value by reference to the Hong Kong dollar. Section 8 adds holding out, which active marketing to the Hong Kong public can satisfy. An issuer with no Hong Kong establishment can fall inside the licensing prohibition through its reference currency alone.
Part 9 of the Financial Services and Markets Act 2022 follows the provider. It applies to a Singapore corporation carrying on a business of providing a digital token service outside Singapore, and to an individual or partnership doing so from a place of business in Singapore. MAS stated on 6 June 2025 that a provider serving only overseas customers requires a licence from 30 June 2025, that it has set the bar high, and that it will generally not issue one. Financial Services and Markets Act 2022, Pt. 9; Financial Services and Markets (Digital Token Service Providers) Regulations 2025 (S 342/2025).
The planning problems are different. A Hong Kong dollar reference draws an offshore issuer into Cap. 656 whatever its place of incorporation, so moving issuance offshore does not avoid the Ordinance while that reference remains. A Singapore incorporation draws an offshore-facing service provider into Part 9 whatever the location of its customers. A group using both features can trigger both regimes.
Retail access compared
Subject to an exemption under section 13, Hong Kong closes retail offering at the level of the token. A specified stablecoin whose issue is authorized by an HKMA licence may be offered to the Hong Kong public through a permitted offeror. A specified stablecoin whose issue is not prohibited by section 8 but is not authorized by a licence may be offered only to the persons specified under Cap. 656A, currently professional investors.
Singapore regulates retail exposure through provider conduct. A payment-service licensee authorised for DPT service may serve retail customers; the licence may be standard or major depending on the section 6 thresholds. MAS then limits what that provider may do with them: no lending or staking of a retail customer’s tokens, and no incentives offered to attract retail business.
The difference affects where a consumer-facing product can launch. A Hong Kong-facing wallet may offer specified stablecoins to retail customers only if the issue is authorized by an HKMA licence, subject to section 13 exemptions; section 9 does not by itself prohibit mere custody of a token already held. The HKMA register listed two licensees as at 13 August 2026. A Singapore retail platform may make multiple qualifying DPTs available under one DPT-service permission, subject to its licence class and conditions, token classification and other law. A Singapore model centred on an offshore specified stablecoin not issued under an HKMA licence cannot be replicated as a Hong Kong retail offer without an issuer-side change or an applicable exemption.
Commercial route implications
An applicant intending to issue a specified stablecoin in Hong Kong, issue an HKD-referenced specified stablecoin, or place its own specified stablecoin into Hong Kong retail distribution should treat Hong Kong as the direct licensing route. The applicant must plan for local substance, capital, reserve custody, redemption operations, risk controls and close HKMA review. Distribution must be designed separately.
A business intending to operate an exchange, custodian, broker, transfer service, on-ramp or payment intermediary should treat Singapore’s DPT-service licensing route as the more relevant comparator. The applicable licence class is standard or major under section 6; the 38-result population describes the current MPI segment. It demonstrates an established licensing channel, but it does not make approval routine.
A group can split the functions. One entity may issue the stablecoin. Other regulated entities may provide custody, exchange, transfer or distribution. That structure does not remove licensing requirements. Each entity’s conduct, customer location, token rights and marketing determine the applicable permissions.
A Singapore incorporation does not create a low-substance offshore solution. Part 9 of the Financial Services and Markets Act 2022 covers relevant digital-token services provided from Singapore to customers outside Singapore. The implementing regulations commenced on 30 June 2025. MAS states that it sets a high licensing threshold and generally will not grant licences for this offshore-only model. Financial Services and Markets Act 2022, Pt. 9; Financial Services and Markets (Digital Token Service Providers) Regulations 2025.
The route decision must also test whether the token has securities, derivatives, deposit, stored-value or collective-investment features. Those features may engage laws beyond the stablecoin and DPT regimes.
