2025 saw the steam towards stablecoins. Singapore has introduced a robust regulatory framework for stablecoins, positioning itself at the forefront of financial innovation while prioritizing safety and consumer protection. This article explains the key features of Singapore’s stablecoin regulation, highlighting differences with Hong Kong and the US.

Singapore’s Regulatory Framework

In 2025, the Monetary Authority of Singapore (MAS) finalized its stablecoin framework under the Payment Services Act, applicable specifically to single-currency stablecoins (SCS) pegged to the Singapore Dollar (SGD) or G10 currencies and issued in Singapore. Multi-currency or non-G10 currency stablecoins fall outside the regime.

– Issuers must back SCS with high-quality, liquid reserve assets worth at least 100% of coins in circulation, ensuring direct redeemability at par value within five business days.

– Monthly independent checks and annual audits of reserves are required, and assets must be segregated with approved custodians.

– A minimum base capital (S$1 million or 50% of annual operating costs) is mandated to ensure operational resilience.

– Clear disclosures—including risks, whitepapers detailing stabilization mechanisms, and audit results—are required for transparency.

– Only issuers regulated under MAS can use the “MAS-Regulated Stablecoin” label, ensuring consumers can distinguish compliant coins.

In our view, MAS’s approach to stablecoins emphasizes financial integrity, consumer protection, and aims to discourage speculative cryptocurrency trading while supporting genuine innovation.

Hong Kong Comparison

On August 1, 2025, Hong Kong’s Stablecoins Ordinance came into effect, similarly requiring issuers to be licensed by the Hong Kong Monetary Authority (HKMA) and to fully back fiat-referenced stablecoins with reserve assets. The rules focus on single and multi-currency stablecoins pegged to the Hong Kong Dollar or other fiats.

– The regime mandates high compliance, strong risk management, regular reserve audits, and custodianship standards.

– Unique is its zero-threshold Travel Rule: sender/receiver identity information must be collected on all transactions, regardless of value—among the strictest for AML/CFT.

– A “Stablecoin Sandbox” allows innovation trials and cross-border pilots.

– Emphasis is placed on payment applications and cross-border trade, with retail investment de-emphasized in the initial phase.

– Only a limited number of entities will receive licenses, aiming for quality over quantity.

US Comparison

The US GENIUS Act, signed into law in July 2025, creates a multi-tiered regulatory schema:

– All stablecoin issuers must fully back coins with US dollars or short-term Treasuries and enable prompt redemption.

– Oversight is split: over $10 billion issuance triggers federal supervision, while smaller issuers can opt for state regulation.

– Reserve quality is emphasized, but unlike Hong Kong, the US focuses more on monetary integrity, interoperability, and financial inclusion than on identity rules for every transaction.

– Prohibitions exist on interest-bearing and lending-linked stablecoins, with rigorous AML/KYC compliance and severe penalties for violations.

Feature	Singapore	Hong Kong	US (GENIUS Act)
Scope	SGD/G10 SCS only	Fiat-backed, incl. HKD	USD-backed, broad
Licensing	MAS approval	HKMA license	Federal/State
Reserve Requirements	100% high-quality	100% high-quality	100% USD/Treasuries
Audits	Monthly/Annual	Regular, detailed	Mandated
Redemption	Par, 5 days	Par, prompt	Prompt redemption
AML/KYC	Standard	Stringent (all txns)	Strong, but not zero-threshold.
Disclosure	Whitepaper, audits	Required	Required
Use Restriction	Issue-only	Payment focus	No lending/yield
Labeling	“MAS-regulated SC”	Regulated stablecoin	Registered

Singapore’s approach is notable for its clear demarcation between regulated and unregulated stablecoins, with consumer protection and solvency at its core—a stance echoed by, but not identical to, Hong Kong and the US.