top of page

Singapore Is Building Trust Into Stablecoins—But Trust Still Needs Due Diligence

Nixon Ng
Sep 13
6 min read

MAS has proposed legislative amendments to implement Singapore’s stablecoin framework. Reserve backing and redemption rules should strengthen confidence, but founders and businesses must still understand exactly which token, issuer and legal claim they are relying upon.



The most dangerous word in “stablecoin” may be “stable”.


It sounds like a promise.


One token equals one dollar. The value remains constant. Money moves quickly across borders and digital platforms without the volatility associated with cryptocurrencies such as Bitcoin.


For startups operating internationally, the appeal is obvious. Stablecoins may facilitate settlement outside conventional banking hours, reduce friction in digital markets and connect tokenised financial infrastructure.


But stability is not a characteristic created by a name.


It depends on assets, custody, liquidity, governance and a legally enforceable ability to redeem the token.


On 1 September 2026, the Monetary Authority of Singapore published proposed legislative amendments to implement its regulatory framework for stablecoins. The consultation concerns changes to the Payment Services Act and remains part of a legislative process—not a declaration that every stablecoin in circulation has become regulated or safe.


The distinction matters.


Singapore is creating a credible label for qualifying instruments.


Businesses must learn to read what the label does—and does not—say.


Not every stablecoin will be an MAS-regulated stablecoin


The proposed framework applies to single-currency stablecoins issued in Singapore and pegged to the Singapore dollar or a G10 currency.


Qualifying issuers would need to satisfy requirements addressing reserve assets, redemption, capital, disclosures and business restrictions before using the “MAS-regulated stablecoin” label.


Other digital tokens may continue circulating without that designation.


A business should therefore never record “stablecoin” as though it were one standard financial product. It must identify the particular token, issuer, jurisdiction, contractual terms and regulatory status.


Two tokens both claiming to represent one US dollar may expose their holders to very different risks.


One may be backed by segregated, high-quality liquid assets held with regulated custodians. Another may depend on affiliated entities, opaque investments or an algorithm intended to maintain its value.


The displayed price may be the same.


The legal and financial substance is not.


Reserve backing is an asset-management function


MAS’s framework is intended to require reserves with a value at least equal to the par value of stablecoins in circulation. Permitted reserves are expected to focus on cash, cash equivalents and qualifying short-term debt securities, supported by risk-management and custody requirements.


That sounds straightforward: one dollar of safe assets for every dollar of tokens.


In practice, reserve management is operationally demanding.


Assets must be valued. Maturities must be managed. Custody arrangements must remain legally effective. Concentration and liquidity risks must be monitored. Redemptions may surge when confidence is weakest.


A reserve can appear sufficient on an ordinary day and become difficult to realise during stress.


Accounting firms, auditors, custodians and boards therefore have important roles.


Reconciliation must connect tokens issued, tokens redeemed, assets held and liabilities outstanding. Exceptions should be investigated quickly. Disclosures must explain what “backed” means rather than allowing customers to imagine an unspecified vault of cash.


The technology may operate continuously.


Governance cannot be allowed to operate quarterly.


Redemption is where the promise becomes real


A token trading near one dollar on an exchange is not the same as a legal right to receive one dollar from the issuer.


Market liquidity can disappear. Intermediaries can fail. Prices can deviate from the peg.


MAS’s proposed model includes redemption at par within five business days after a valid request, subject to the eventual legislation and applicable terms.


For users, the critical questions remain practical.


Who can redeem directly? Is redemption available to every holder or only approved customers? What identification and anti-money-laundering checks apply? Are there minimum amounts or fees? What happens if the token was obtained through an overseas exchange?


A startup accepting stablecoins from customers must know whether it possesses a direct claim against the issuer or merely an asset it hopes another market participant will buy.


Liquidity should be tested before it is urgently needed.


The worst time to discover the redemption process is when employees and suppliers are waiting to be paid.


A regulated token is not a bank deposit


Businesses may see the MAS label and mentally place the token beside cash at bank.


That would be careless.


A stablecoin is not automatically a bank deposit. It should not be assumed to carry deposit-insurance protection or the same legal relationship that exists between a customer and a bank.


The issuer’s reserve arrangements, segregation requirements and capital buffers are designed to protect stability and redemption. They do not eliminate every operational, cybersecurity, legal or counterparty risk.


Startups should reflect this distinction in treasury policies.


How much value may be held in stablecoins? Which tokens and service providers are approved? Who controls wallets and private keys? Is dual authorisation required? How are lost credentials, unauthorised transactions and network disruptions handled?


Treasury management does not stop being necessary because money has become programmable.


It becomes more complicated.


Cross-border use creates a jurisdiction map


Stablecoins are marketed as borderless.


Regulation is not.


A Singapore company may use a token issued elsewhere, through an exchange incorporated in another jurisdiction, to pay a supplier in a third country. Each component can introduce licensing, sanctions, tax, accounting and enforceability questions.


MAS’s consultation also contemplates a recognition regime for qualifying foreign stablecoin issuers subject to adequate oversight in their home jurisdictions.


Recognition could support cross-border confidence. It will not create a single global rulebook.


A founder should map:

  • Where the issuer is established;

  • Where the token is issued;

  • Which platform provides custody or exchange;

  • Where the sender and recipient are located;

  • Whether any regulated payment activity is being conducted; and

  • Which party performs customer and transaction screening.


“On-chain” describes how a transaction is recorded.


It does not explain which laws apply to it.


Accounting must follow substance


Stablecoin transactions can look deceptively simple in a wallet.


A token arrives. Another leaves. The remaining balance appears on a dashboard.


The accounting questions begin immediately.


How should the token be classified under the applicable financial-reporting framework? Is it cash, a financial asset, an intangible asset or something else based on its contractual features and use? How should transaction fees and exchange differences be treated? What evidence supports ownership and year-end valuation?


There is no responsible universal answer based solely on the word “stablecoin”.


Companies need records connecting wallet addresses to legal entities and authorised persons. They must preserve transaction histories and explain transfers between corporate and custodial wallets. Controls should prevent founders from mixing personal and company assets.


Auditors will need evidence beyond a screenshot.


A visible balance can demonstrate that tokens exist at an address. It does not necessarily prove that the reporting company controls them or that no undisclosed person also holds the credentials.


Regulation may favour serious builders


Compliance will increase costs.


Issuers may need substantial capital, specialist staff, custody arrangements, attestations, audits and recovery plans. Some innovators will argue that these requirements make entry difficult and protect established institutions.


That concern deserves consideration.


Excessively burdensome regulation can push activity offshore or prevent useful experiments. Stablecoin business models must also remain economically viable when high-quality reserves generate limited returns and holders expect low-cost redemption.


But a token marketed as stable money should face a high standard.


If an issuer cannot explain its reserves, honour redemptions or survive operational disruption, the innovation is not a better form of money. It is a confidence mechanism waiting to be tested.


The framework may make Singapore less attractive to casual issuers.


It can make the jurisdiction more attractive to credible ones.


The label is the beginning of diligence


The proposed MAS framework can improve trust by making a meaningful regulatory distinction visible to users.


That is valuable.


Yet labels inevitably become shortcuts. A founder sees “MAS-regulated” and stops asking questions. A board approves stablecoin payments without limits. An accountant treats the wallet balance as cash. A customer assumes the Government guarantees the peg.


None of those conclusions follows automatically.


The proper response to regulation is not blind confidence.


It is better-directed diligence.


Identify the token. Verify the issuer. Understand the reserves. Read the redemption terms. Assess custody. Map the jurisdictions. Establish accounting and treasury controls.


A stablecoin can maintain its value only if the legal and operational machinery behind it works.


Singapore is proposing rules for that machinery.


Businesses should stop staring at the one-dollar price—and start looking underneath it.



Sources:


Comments

Rated 0 out of 5 stars.
No ratings yet

Add a rating
bottom of page