Raymond Cheung
Chartered Actuary · CRO · Board Adviser · Singapore
MAS opened a consultation on 1 September 2026 to convert its Single-Currency Stablecoin framework from supervisory expectation into enforceable law under the Payment Services Act — with a new power to designate any stablecoin as systemic. Boards that have been treating stablecoin exposure as a treasury or payments-ops sandbox item now need to treat it as a standing risk-register entry.
I've sat in board risk discussions where stablecoin exposure got waved off in under a minute — 'that's a treasury team question' — and moved on to the next agenda item. MAS just made that answer obsolete. On 1 September, it opened a consultation on amendments to the Payment Services Act that would give its Single-Currency Stablecoin framework the force of law, not just the weight of supervisory guidance a board could reasonably treat as a soft expectation.
From stated policy to enforceable statute
The framework MAS finalised in 2023 has, until now, operated as policy: firms were expected to comply, but the label 'MAS-regulated stablecoin' wasn't backed by a licensing regime with real teeth. The proposed amendments change that. They introduce a licensing regime for Singapore-incorporated issuers of stablecoins pegged to the Singapore dollar or a G10 currency, a recognition regime for foreign issuers already subject to comparable oversight at home, and — the detail I'd flag first to any board — a new MAS power to designate a specific stablecoin as systemic if it could pose risk to, or disrupt, Singapore's financial system. Only licensed issuers will be permitted to call themselves 'MAS-regulated,' which turns a marketing claim into a legal one.
“A systemic designation power means a stablecoin your business touches today, quietly and through a vendor, can become a named regulatory risk tomorrow without your board ever having voted on exposure to it.”
Why this reaches boards that have never issued a token
This isn't only a compliance question for the handful of firms seeking a licence. Value stability, capital, redemption-at-par, and disclosure requirements now become testable legal obligations rather than best-practice expectations — which changes the due-diligence bar for any company holding stablecoins on its balance sheet, using them for cross-border settlement, or embedding them in a payments product built on top of someone else's rails. A board that has never discussed stablecoins directly may still be carrying counterparty exposure to one through a payments partner, and the systemic-designation power means that exposure's risk profile can change on MAS's timetable, not the board's.
- Does anyone on management know which, if any, stablecoins the business is exposed to — directly or through a payments or treasury vendor?
- If MAS designated one of those as systemic, is there a process to identify and reassess that exposure within days, or would the board find out from a news alert?
- Has risk or treasury been asked to respond to the consultation, or map its implications, ahead of the 16 October 2026 deadline?
The consultation closes on 16 October. Boards don't need a position on the legislative detail to act now — they need a straight answer to one question: where does this business actually touch a stablecoin, and who is watching it. That answer should exist before the framework becomes law, not after.
Common Questions
What is MAS's Single-Currency Stablecoin (MAS-SCS) framework?
It's MAS's regulatory framework, finalised in 2023, for stablecoins pegged to the Singapore dollar or other G10 currencies, covering value stability, capital, redemption at par, and disclosure. Until the September 2026 consultation, it operated as supervisory policy rather than enforceable statute.
What changes under the proposed Payment Services Act amendments?
The amendments would create a licensing regime for Singapore-incorporated stablecoin issuers, a recognition regime for comparably regulated foreign issuers, and give MAS power to designate specific stablecoins as systemic if they could pose risk to Singapore's financial system. Only MAS-licensed issuers would be permitted to describe their tokens as 'MAS-regulated stablecoins.'
Does this affect companies that don't issue stablecoins themselves?
Yes. Any company holding stablecoins, using them for settlement, or relying on a payments vendor built on stablecoin rails carries exposure that the new systemic-designation power can reclassify as higher-risk on MAS's timetable. Boards should map that exposure now rather than waiting for the framework to take legal effect.
About the author
Raymond Cheung is a Chartered Actuary, C-suite executive and board adviser with more than 20 years of experience across Asia in risk management, insurance, ESG and corporate governance. He is the CEO of CER Consultancy and an accredited trainer at SMU Academy and the Singapore College of Insurance.