What Reserve Requirements Apply to MAS-Regulated Stablecoins?

Key takeaways

• MAS finalised its framework for single-currency stablecoins (SCS) pegged to the Singapore dollar or a G10 currency and issued in Singapore on 15 August 2023.
• Reserve assets are subject to requirements on composition, valuation, custody and audit, and issuers must return par value within five business days of a redemption request.
• Issuers must hold minimum base capital and liquid assets, and disclose their stabilising mechanism, holders' rights and reserve audit results.
• Only issuers meeting every requirement can use the label 'MAS-regulated stablecoin', and misrepresenting a token as MAS-regulated may attract penalties.
• On 1 September 2026 MAS consulted on amendments to the Payment Services Act to legislate the framework, including a stablecoin issuance licence; comments close on 16 October 2026.

What are the key facts on MAS stablecoin reserves?

MAS's stablecoin framework sets reserve, redemption, capital and disclosure standards for single-currency stablecoins issued in Singapore. It has applied as a framework since August 2023, and MAS is now consulting on putting it into the Payment Services Act with a dedicated licence, so the requirements below should be read as a floor that is likely to become more formal, not less.

Which stablecoins does the framework cover?

Single-currency stablecoins pegged to the Singapore dollar or any G10 currency and issued in Singapore. Stablecoins referencing a basket, or issued elsewhere, sit outside the framework and cannot use its label.

MAS's 15 August 2023 release applies the framework to these single-currency stablecoins. Only issuers that meet all the requirements can apply to have their tokens recognised as MAS-regulated stablecoins, and MAS warned that misrepresenting a token as MAS-regulated may be subject to penalties. Our guide to DPT customer asset segregation covers how service providers must hold customer tokens.

What does the 2023 framework require of reserves?

Reserve assets subject to requirements on composition, valuation, custody and audit, to give a high degree of assurance of value stability.

The framework's reserve requirements work together. Composition limits what the reserve can hold, valuation sets how it is measured against tokens in issue, custody keeps it separate and protected, and audit gives holders independent evidence. MAS also requires issuers to disclose the results of reserve audits to users, along with the value-stabilising mechanism and holders' rights, so that holders can judge the backing for themselves.

Evidencing the reserve day to day is an operational task. Tokens in circulation must be read from every network at a fixed time and agreed to the issuance ledger; reserve holdings must be agreed to bank and custodian statements at the same moment; and the comparison must be recorded with any differences and how they were resolved. An audit at period end can only confirm what those daily records already show.

What does the September 2026 consultation propose?

A new stablecoin issuance licence, with reserves at least equal to par value of tokens in circulation held in segregated trust accounts.

On 1 September 2026 MAS published draft amendments to the Payment Services Act to put the framework into law, with comments due by 16 October 2026 and subsidiary legislation to follow. According to the consultation, a new stablecoin issuance licence would be created, and only licensees could hold themselves out as issuers of MAS-regulated stablecoins. Issuers would keep reserve assets at least equal to the par value of stablecoins in circulation at all times, held in segregated trust accounts with permitted custodians, with attestation and audit requirements. MAS also sought views on a minimum proportion of reserves held as cash or bank deposits, on regular stress testing, and on prohibiting issuers from paying interest or other benefits to holders. Redemption would be honoured in the pegged currency within timeframes MAS prescribes.

The draft is subject to change after consultation. Issuers preparing now should build to the 2023 framework and design reserve, custody and reporting processes that can meet the stricter statutory form.

What else does the 2026 consultation cover?

Recovery and wind-down planning, controls over tokens in circulation, systemic stablecoins and foreign stablecoins.

According to the consultation, issuers would need board-approved recovery and wind-down plans shared with MAS at least annually, and the ability to trace, freeze or burn their stablecoins. Customer money would have to be safeguarded before issuance or direct redemption. MAS also proposed a regime for designating systemic stablecoins and for recognising foreign-regulated stablecoins case by case. If a licence were revoked or surrendered, the issuer would move into wind-down, and MAS could require orderly redemption first. These proposals matter for reserves because they decide how quickly, and in what order, reserve assets would be paid out in a failure.

How does Singapore compare with Hong Kong and the United States?

All three require full backing in high-quality assets; they differ on redemption speed and on how much detail sits in law.

Our guides to Hong Kong stablecoin reserve assets and GENIUS Act eligible reserves give the detail for the other two regimes.

How does the five-day redemption rule shape the reserve?

It requires enough of the reserve to be turned into cash within five business days to meet any realistic wave of requests.

Par redemption within five business days means the reserve cannot rely on assets that take longer to sell, or that might sell below par in stress. An issuer should model its largest plausible redemption over five business days, from its own history and from stress scenarios, and hold enough cash and very short assets to meet it without forced sales. The 2026 consultation's questions on a minimum cash or deposit proportion and on stress testing point the same way.

Redemption also has a processing side. The issuer needs a documented path from a holder's request to payment: identity and eligibility checks, burning or locking the tokens, selling or drawing reserve assets, and paying in the pegged currency. Each step must fit inside five business days on a busy day, not only an average one. Rehearsing a large redemption, with real timings from custodians and banks, is the most reliable way to prove the window can be met.

How does a reserve check work?

It compares the reserve's value with tokens in circulation, and tests whether the reserve can meet five business days of redemptions in a stressed scenario.

Worked example. An issuer has 300,000,000 Singapore dollar stablecoins in circulation at the end of a day.

The reserve exceeds par by S$4.0 million, or 1.3%. The issuer's stress scenario assumes 25% of tokens, S$75.0 million, are redeemed over five business days. Cash of S$60.0 million plus near-maturity securities easily covers it. If its scenario rose to 90%, S$270.0 million, it would need to sell longer securities at market prices, and a 2% price fall on S$64.0 million would cost S$1.3 million, leaving only S$2.7 million of the buffer.

How should issuers prepare while the law is drafted?

By building to the stricter of the 2023 framework and the draft, so that no redesign is needed once the law is passed.

The draft puts reserves, custody and redemption into statute and adds licensing, so issuers should assume the requirements will become more formal, not less. Practical steps include placing reserves in trust accounts with custodians that would qualify, setting an internal buffer above par, building daily reconciliation of supply against reserves, arranging an attestation provider, and writing the recovery and wind-down plan the consultation describes. An issuer that can already show every day's position will find the move to a licensed regime largely administrative.

What should a Singapore stablecoin issuer check?

These checks prepare for both the 2023 framework and the draft law. Most of them are operational controls that take months to build and test, so they are worth starting before the statute is final, not after the licence application opens.

• Confirm the token is single-currency, pegged to the Singapore dollar or a G10 currency, and issued in Singapore.
• Value reserves at least daily against tokens in circulation at par.
• Hold reserves in segregated trust accounts with suitable custodians.
• Model five business days of redemptions in stress and size cash accordingly.
• Arrange independent attestation and audit, and publish the results.
• Hold the minimum base capital and liquid assets.
• Respond to the consultation by 16 October 2026 if the draft affects the business model.

How does Safeheld help?

Safeheld reconciles tokens in circulation, reserve accounts and custodian holdings every day and shows the reserve ratio from confirmed figures.

See daily reconciliation and stablecoin reserve reconciliation.

Frequently asked questions

Which stablecoins does the MAS framework cover?

Single-currency stablecoins pegged to the Singapore dollar or any G10 currency and issued in Singapore.

How quickly must an MAS-regulated stablecoin be redeemed?

Under the 2023 framework, issuers must return par value within five business days of a redemption request.

What reserve requirements apply?

Reserve assets are subject to requirements on composition, valuation, custody and audit. The 2026 draft law would require reserves at least equal to the par value of stablecoins in circulation, held in segregated trust accounts.

Who can use the label 'MAS-regulated stablecoin'?

Only issuers that meet all the framework's requirements. Misrepresenting a token as MAS-regulated may be subject to penalties.

Is the MAS stablecoin framework law yet?

MAS consulted on draft amendments to the Payment Services Act on 1 September 2026, with comments closing on 16 October 2026. The framework is not yet in statute.

Can MAS-regulated stablecoin issuers pay interest?

The 2026 consultation proposes prohibiting issuers from paying interest or other benefits to holders for holding the stablecoin.

What happens if an issuer's licence is revoked under the draft law?

According to the consultation, revocation or surrender would trigger wind-down or winding-up, and MAS could require orderly redemption of stablecoins first.

What capital must issuers hold?

Minimum base capital and liquid assets, under the 2023 framework, to reduce insolvency risk and allow an orderly wind-down.

References

• MAS, MAS finalises stablecoin regulatory framework (15 August 2023)
• Payment Services Act 2019 (Singapore Statutes Online)

About Safeheld

Safeheld is reconciliation and regulatory financial control software for regulated firms that hold client money. For stablecoin issuers it reconciles supply, reserve accounts and custodians every day so the reserve ratio is known before each attestation. To discuss your digital asset operations, contact us at safeheld.com/contact.

This article is general information on Singapore stablecoin rules and is not legal or regulatory advice.