Singapore has built upon its strengths as a global financial centre to become a leading global blockchain hub. It is home to a healthy blockchain ecosystem, comprising numerous players at the forefront of trends in areas such as asset tokenisation, cryptocurrency trading and custody, supply chain, insurance, digital identity and mobility.

The Monetary Authority of Singapore (MAS) has driven much of this momentum through flagship initiatives such as Project Guardian – under which financial institutions (FIs) have piloted asset tokenisation use cases for fixed income, foreign exchange and wealth management – and the Global Layer 1 (GL1) initiative, which seeks to develop an interoperable, regulatorily-compliant shared-ledger infrastructure for cross-border use in financial markets. Banks including DBS, OCBC and UOB have completed interbank overnight lending transactions using a Singapore-dollar wholesale central bank digital currency (CBDC), and MAS has announced plans to pilot tokenised MAS Bills settled through that wholesale CBDC.

To support the tokenisation wave, MAS also launched the BLOOM (Borderless, Liquid, Open, Online, Multi-currency) initiative in October 2025, to support industry experimentation with tokenised bank liabilities and regulated stablecoins for settlement.

These public-sector initiatives sit alongside a broad spectrum of private-sector adoption. The use of blockchain in Singapore runs the full gamut of public to private enterprises, including the following.

• Government registers for non-profit purposes – eg, OpenCerts, which allows employers to verify academic certificates from Singapore’s universities and higher learning institutions.
• Interoperable digital utilities for global trade – eg, TradeTrust, an IMDA-led open-source framework, allows secure, MLETR-compliant exchange and verification of electronic bills of lading across platforms. By early 2026, over 50 partners, including major carriers and platforms such as SGTraDex, digitised end-to-end trade documents, reducing fraud and double-financing.
• Regulated digital payment initiatives, notably XSGD, the world’s leading Singapore Dollar-pegged stablecoin issued by StraitsX, is one of the first digital assets to be acknowledged as substantively compliant with the MAS single currency stablecoin regulatory framework. XSGD serves as a critical settlement bridge for real-world commerce. It is currently utilised in the Project BLOOM initiative to power instant, cross-border QR payments between Singapore and regional neighbours, as well as to provide 24/7 programmable settlement for institutional treasury and merchant “scan-to-pay” services via the Grab and OKX ecosystems.
• Large private enterprises – eg, Senoko Energy, Singapore’s largest energy company, which partnered with Electrify, a Singaporean retail electricity marketplace start-up to launch a peer-to-peer energy trading platform, SolarShare.
• Financial services businesses leveraging blockchain in areas such as insurance, lending, asset securitisation and commodities trading.

While blockchain underpins a wide range of activities across Singapore’s economy, asset tokenisation has emerged as the dominant use case, with tokenised bonds, money market funds and cash management services already launched commercially.

Beyond MAS-led programmes, the Infocomm Media Development Authority (IMDA) also invests in blockchain innovation by seeding challenges and hackathons with funding and exposure, spurring innovation to support Singapore’s “Smart Nation” policy objectives. Additionally, Singapore has a thriving digital assets trading, custody and investment market, with exchanges, venture capital funds, crypto hedge funds, decentralised finance (DeFi) and non-fungible token (NFT) projects all contributing to an active market.

Notwithstanding this strong foundation, the blockchain landscape faces challenges. In 2025, Chia Der Jiun, managing director of MAS, outlined MAS’ priorities for the next ten years, focusing on two core themes: artificial intelligence (AI) and tokenisation. On AI, MAS seeks to anchor AI capabilities in Singapore’s financial sector, publishing governance guidelines for responsible use. On tokenisation, he noted that ecosystem fragmentation remains a concern: proprietary platforms risk creating “sub-scale walled gardens” with trapped liquidity, an issue that GL1 is specifically designed to address.

These structural concerns are compounded by an expanding regulatory perimeter. Businesses offering blockchain-based services will have to flexibly adapt and adjust to enhanced regulation and licensing in Singapore. The amendments to the Payment Services Act 2019 (the “PS Act”) came into force in April 2024 while the provisions relating to digital token service providers (DTSPs) under the Financial Services and Markets Act (FSMA) came into force on 30 June 2025 (see 1.1.3 Regulation of Blockchain Technology, 2.1 Regulators and International Alignment and 2.2 Crypto-Asset Regulatory Frameworks).

The broadening of regulatory oversight also extends to stablecoins, where draft legislation to implement a dedicated regime is being finalised. Under this framework, certain activities relating to single currency pegged stablecoin issuance will be separately regulated. Presently, MAS has granted in-principle approval under the PS Act to three entities, which will issue stablecoins that substantively comply with the upcoming stablecoin regulatory framework. At the time of writing, MAS is still working on the legislative amendments.

As the regulatory framework for blockchain matures, intellectual property (IP) considerations also warrant attention. Singapore’s technology-neutral regulatory approach means that blockchain activity is governed by existing IP laws rather than bespoke legislation. The primary form of IP protection for blockchain projects is copyright over source code, for which an appropriate open-source or proprietary licence may be opted for.

The MAS offers a FinTech Regulatory Sandbox to encourage local projects to pursue innovative financial products and services within a secure, efficient and low-regulatory-pressure environment.

There are three options: Sandbox, Sandbox Express and Sandbox Plus. The Sandbox option is for more complex business models where customisation is required to balance the risks and benefits of the experiment. The Sandbox Express option is for activities where risks are low and well understood by the market. It relies on disclosures and predetermined rules, providing a faster option for market testing. The Sandbox Plus option expands the eligibility criteria to include early adopters of technological innovation. It also provides financial grants for first movers in technology innovation.

A successful use case of the Sandbox is DigiFT Tech (Singapore) Pte Ltd, a Singapore-based regulated exchange for on-chain real world assets. It exited the Sandbox on 30 November 2023 and holds a capital markets services (CMS) licence for dealing in capital markets products (CMPs) that are securities or units in a collective investment scheme. It is also a recognised market operator (RMO) under the SFA.

Singapore adopts a generally progressive and technology-agnostic approach to blockchain regulation, focusing on regulating the underlying activity rather than the enabling technology itself. There is no single piece of legislation governing the use of blockchain in Singapore. Existing legislation and regulations have instead been, and are continually being, expanded or clarified to address blockchain use issues.

Singapore’s regulatory regime centres on three key statutes: the Securities and Futures Act (SFA), the PS Act and the FSMA (see 2.2 Crypto-Asset Regulatory Frameworks). The SFA governs the capital markets and financial investments sector in Singapore and covers digital assets with the characteristics of CMPs, while the PS Act regulates payment services (PSs), including those involving digital payment tokens (DPTs) provided in Singapore. The FSMA extends AML/CFT obligations to DTSPs operating from Singapore and providing digital token (DT) services outside Singapore.

While the MAS encourages innovation (see 1.1.1 Evolution of Uses of Blockchain) and has published guidance like the Guide on the Tokenisation of Capital Markets Products and the FAQs on the Payment Services Act (PS Act), it has also implemented robust retail investor protection measures, including restrictions on the marketing of DPT services to the general public and a prohibition on facilitating the staking and lending of retail customers’ assets by PS Act-regulated licensees. Furthermore, entities regulated under the SFA, PS Act and FSMA remain subject to MAS guidelines on outsourcing and technology risk management. MAS expects, among other things, such regulated entities to conduct due diligence on the service provider and ensure that certain terms, such as the scope of the outsourcing arrangement, performance, operational, internal control and risk management standards, be included in the outsourcing agreement.

Data protection obligations are set out in the Personal Data Protection Act (PDPA), which applies irrespective of the technology used to process personal data (PD). Firms deploying blockchain solutions must therefore ensure compliance with the PDPA’s requirements regarding the collection, use, disclosure and storage of PD.

Singapore’s data protection regime under the PDPA does not include a general “right to be forgotten” equivalent to that found under the EU’s General Data Protection Regulation. However, the PDPA does impose obligations on organisations to cease retaining PD when it is no longer necessary for any business or legal purpose, and to ensure the accuracy of PD used to make decisions affecting individuals. Blockchain’s immutable nature presents challenges in meeting these obligations, and organisations using blockchain-based products should carefully consider how PD is recorded on-chain, and explore storing PD off-chain and referencing it only through hashed or anonymised identifiers.

The enforceability of smart contracts in Singapore has not been definitively judicially or legislatively determined. However, the reasoning in the Quoine case (see 1.2.1 Property Considerations) implies that an agreement encoded by way of a smart contract can be legally enforceable, provided that the typical elements for constituting a binding contract are present, namely:

• offer;
• acceptance;
• consideration; and
• the intention to create legal relations.

This approach is supported by the IMDA. In its Consultation Paper on the Review of the Electronic Transactions Act (ETA), the IMDA affirmed that the ETA does not prevent the use and formation of legal contracts embodied in smart contracts and that a contract by sole virtue of its automatic formation is unlikely to be denied validity or enforceability. The IMDA also noted that, depending on their specific technical implementation, cryptographic hashes may, at the very least, constitute possible components of electronic signatures for the purposes of party intention and authentication to create a contract.

Apart from satisfying the general elements of contractual validity, certain contracts are subject to additional statutory formalities. For example, Section 6 of the Civil Law Act mandates that contracts for the sale of immovable property must be in “writing” and signed to be enforceable. Fulfilling the “writing” requirement may be challenging for a smart contract involving the sale of immovable property, making its enforceability uncertain.

Meanwhile, the question of whether smart contracts may fulfil the “writing” requirement pursuant to Section 7 of the ETA remains open to judicial determination. That provision provides that an “electronic record” will constitute “writing”. The ETA defines an “electronic record” as “a record generated, communicated, received or stored by electronic means in an information system or for transmission from one information system to another”. To date, the Singapore courts have only discussed the ETA in relation to the validity of contracts formed via email or internet transactions. Whether the definition of “electronic records” under the ETA extends to smart contracts remains unclear.

Singapore is home to several trade groups, such as the Association of Crypto Currency Enterprises and Start-ups Singapore (ACCESS), the Blockchain Association of Singapore (BAS) and the Digital Assets Association (DAA), which are designed to be platforms for members to engage with various stakeholders in the space to discover solutions and promote best practices.

Digital Assets as Property

The judge in ByBit Fintech Ltd v Ho Kai Xin [2023] 5 SLR 1748 (the “Bybit Fintech Case”) ruled that USDT is property capable of being held on trust. The case involved the theft of a number of USDT by the claimant’s ex-employee. The judge in the Bybit Fintech Case observed generally that, in principle, the holder of a crypto-asset has an intangible property right that is enforceable in court. The reason for this is twofold.

Firstly, it clearly satisfies the traditional Ainsworth definition of property rights: property rights must be definable, identifiable by third parties, capable of being assumed by third parties and have some degree of permanence or stability. Secondly, it is properly considered a thing in action. In particular, by rejecting the argument that crypto-assets should not be classified as things in action because there is no individual counterparty to the right of holders of these assets, the court recognised that the category of things in action has been expanded over time to ultimately include incorporeal rights such as copyrights.

More recently, the Singapore High Court (SGHC) in Cheong Jun Yoong v Three Arrows Capital Ltd [2024] SGHC 21 (the “Three Arrows Case”) stated that it cannot be seriously disputed that crypto-assets constitute property.

Determining Ownership of Digital Assets

The manner of determining ownership of digital assets under Singapore law has not been conclusively determined at the time of writing as the exact legal nature of digital assets remains unclear. The concept of “ownership” vis-à-vis a digital asset under Singapore law has not been directly challenged in any reported case to date.

Nevertheless, following the approach of the Singapore Court of Appeal (SGCA) in Quoine Pte Ltd v B2C2 Ltd [2020] SGCA (I) 02 (the “Quoine case”) and the SGHC in the Three Arrows Case, it is anticipated that ownership of digital assets will be determined by analogy to other assets. A person who has acquired knowledge and control of a private key through lawful means will therefore generally be treated as the owner of that digital asset, in the same way that a person in lawful possession of a tangible asset is presumed to be the owner.

Existing laws will then apply to each fact-specific scenario. For example:

• a person may hold the key on behalf of another, as a custodian or intermediary. In this case, ownership may be determined by established laws on agency or trust;
• a digital asset may have multiple keys – in this case, ownership may be shared or separated between the holders, perhaps by reference to different functions of the asset;
• a person who has obtained a private key unlawfully, such as through hacking, will not be treated as the lawful owner; or
• in non-anonymous systems where the owners are identified in the transaction ledger, the status of the record (eg, whether treated as definitive or merely evidential) will depend on the rules of the blockchain system that the parties have agreed to.

There is also no legal test for determining when transfers of digital assets can be considered final given that each blockchain may have different mechanisms for determining when a block containing the transaction can be reverted (eg, slashing a validator’s stake) and may differ in confirmation times and numbers before another block can be added. However, for commercial certainty, parties can contractually agree that a transfer has occurred on the basis that a certain number of confirmations on the blockchain network have been provided.

Enforcement of Property Rights Over Digital Assets

From an enforcement perspective, in relation to a claim over stolen cryptocurrencies, the SGHC, in CLM v CLN and others [2022] SGHC 46, granted a proprietary injunction and a worldwide freezing injunction to prevent the dissipation of allegedly stolen cryptocurrencies against unidentified persons believed to have participated in or assisted with the alleged theft. The Court also ordered two cryptocurrency exchanges to provide information and documents relating to the accounts that were credited with some of the allegedly stolen cryptocurrencies.

Similarly, on 13 May 2022, the SGHC in Janesh s/o Rajkumar v Unknown Person (“CHEFPIERRE”) [2022] SGHC 264 (the “Janesh case”) issued a worldwide proprietary injunction to block any potential sale and ownership transfer of a unique Bored Ape Yacht Club NFT (BAYC No 2162) (BAYC NFT) against an unknown person known as “Chefpierre”. Following an application by Rajkumar, the Court granted the worldwide proprietary injunction. At the time of writing, this injunction remains uncontested.

Use of Digital Assets as Collateral

The use of digital assets as security has not been explored in case law, legal precedent or legislation in Singapore. Nevertheless, following the approach of the SGCA in the Quoine case, it is anticipated that security over digital assets will be determined by analogy to other assets. Traditional common law forms of security interests such as assignments, mortgages, charges and pledges may therefore be considered.

Assignments, mortgages or charges could all be applicable to digital assets categorised as securities or currency (when stored in online wallets). Physical digital asset wallets could also be pledged as security, to the extent that these physical wallets can be considered goods or personal chattels.

There are no express regulatory restrictions under the PS Act on which banks or payment partners a digital payment token service provider (DPTSP) may use for its general, day-to-day banking needs. However, specific regulatory requirements effectively constrain the choice of partners for certain critical functions.

Under the PS Act, a major payment institution licensee providing a DPT service is required to safeguard relevant money received from, or on account of, customers by either procuring an undertaking or guarantee from a bank in Singapore or a prescribed FI, or depositing the funds into a trust account maintained with such an institution. This means that the safeguarding partner must be a qualifying institution located in Singapore; an offshore bank or unregulated entity would not satisfy this requirement.

Separately, DPTSPs licensed under the PS Act are subject to consumer protection measures introduced in October 2024, which oblige them to segregate customers’ assets (fiat and DPTs) from their own assets and place them in trust accounts for the benefit of customers. Where a DPTSP chooses to engage a safeguarding person located outside of Singapore, it must be satisfied that the safeguarding person meets the standards set out in the Payment Services Regulations and the Guidelines on the Provision of Consumer Protection Safeguards by Digital Payment Token Service Providers.

The broader regulatory trajectory in Singapore points towards licensed DPTSPs being required to maintain relationships with qualifying FI, particularly for the safeguarding of customer money. The MAS has also confirmed that there are no rules preventing banks from doing business with DPTSPs. As Singapore’s licensing regime matures and provides greater regulatory certainty, this may in turn encourage banks to reassess their risk appetite for servicing firms providing digital asset services.

At the time of writing, there is no ESG/sustainable finance-specific legislation that applies to digital assets in Singapore.

Taxation matters in relation to use of blockchain or cryptocurrencies are covered under existing tax legislation in Singapore, principally the Income Tax Act (ITA) and the Goods and Services Tax Act (GSTA). The Inland Revenue Authority of Singapore (IRAS) has also released specific guidance outlining how the legislation applies to blockchain and cryptocurrency matters.

Revenue for Goods or Services Using Cryptocurrency

Businesses that accept cryptocurrency as consideration are subject to taxes on their income as set out in the ITA. These transactions will be considered as barter trade, and the relevant revenue will be based on the value of the goods or services provided. Taxation will be based on net profits (after deducting allowable expenses under the ITA). The current corporate income tax rate stands at 17%.

Investing and Trading in Cryptocurrency

Individuals or businesses that buy and sell cryptocurrencies as part of their business will be charged income tax on profits derived from trading in cryptocurrency. Profits derived by individuals or businesses that mine and trade cryptocurrency in exchange for money are also subject to income tax, as these will be considered revenue.

However, individuals or businesses that invest in cryptocurrency for long-term investment purposes may be exempt from income tax for the disposal of these cryptocurrencies, as these will be considered capital gains (which are not subject to tax) rather than revenue.

Distinguishing these two situations depends on the facts and circumstances of each case. When determining if gains from disposable of cryptocurrency are taxable, factors such as purpose, frequency of transactions and holding periods are relevant.

Taxes on Proceeds of an Initial Coin Offering (ICO)

Taxes on ICO proceeds are dependent on whether the proceeds are considered as revenue and are sourced in Singapore. Generally, for an ICO of a utility token, ICO proceeds will be treated as deferred revenue (taxable under the ITA). However, for an ICO of a security token, ICO proceeds will be capital in nature and therefore not taxable.

To ascertain if the activities giving rise to the ICO proceeds are carried on in Singapore and if the income will be determined to be sourced in Singapore, the following factors (among others) will be considered:

• whether the company has a physical presence in Singapore;
• where and how the marketing and promotion of the ICO is conducted;
• whether the participants in the ICO are predominantly based inside or outside Singapore; and
• whether the developers behind the blockchain technology are based inside or outside Singapore.

GST on the Sale of Cryptocurrency

Singapore has a value-added tax regime under the GSTA, whereby GST is levied on the supply of goods and services in Singapore and the import of goods into Singapore. GST is an indirect tax applied on the sale price of goods and services provided by GST-registered business entities in Singapore. The current GST rate is 9%.

The supply of cryptocurrency that falls within the definition of “DPTs” under the GSTA is no longer subject to GST. Specifically, the use of DPTs as payment for goods or services will no longer be construed as a supply of a service; GST need not be accounted for on their use. Furthermore, a supply of DPTs in exchange for fiat currency or other DPTs and the provision of any loan, advance or credit of DPTs will be exempt from GST.

However, where tokens do not fall within the definition of DPTs under the GSTA, the tax treatment remains unclear. It is possible that GST can apply to the supply of these tokens. If GST applies, the question as to when GST is payable becomes difficult. For instance, payment for such tokens may have been made as payment for future services or benefits. Crystallising the time at which the payment for such tokens can be considered to have been earned by the supplier of tokens (and GST chargeable at such point in time) may be challenging.

Blockchain-based businesses are subject to the same winding-up and restructuring provisions under the Insolvency, Restructuring and Dissolution Act that apply to all companies.

In the context of insolvency proceedings, the asset’s location is often the of utmost importance when establishing sufficient nexus to the relevant jurisdiction. The Three Arrows Case provided much needed clarity on ascertaining the location of a digital asset. In that case, the High Court held that the location of a digital asset was best determined by looking at where it was controlled, as digital assets do not have a physical presence and exist as a record in a computer network. The residence of the person who controls the private key of the wallet holding the digital assets will therefore be treated as the location of the digital asset.

In respect of resolution requirements, the MAS expects licensed DPTSPs to resolve disputes with retail customers through mediation, arbitration, and/or litigation.

Singapore’s Financial Industry Disputes Resolution Centre (FIDReC) is an independent alternative dispute resolution institution that facilitates the resolution of disputes between consumers and FIs through mediation and adjudication. While the MAS does not require DPTSPs to use FIDReC’s services, it has indicated support for industry associations to come together to discuss membership arrangements with FIDReC.

See 1.1.5 Industry and Trade Bodies.

The MAS has clarified that most stablecoins today may be regulated as DPTs rather than as e-money. There is therefore no distinction in treatment between algorithmic stablecoins and asset-backed stablecoins (see also 6.1 Payments).

In 2024, the MAS also finalised its new stablecoin framework. This framework will apply to single-currency stablecoins issued in Singapore that are pegged to either the SGD or any G10 currency.

The MAS will be expanding the regulatory regime under the PS Act to include a new PS known as a “stablecoin issuance service” (SIS), which will cover the issuance of single-currency stablecoins whose circulation value exceeds SGD5 million and are issued by an entity based in Singapore. Only stablecoins backed by very low-risk reserve assets (such as cash, cash equivalents or certain short-term debt securities) will fall within this new regulatory framework, and they will be labelled as “MAS-regulated stablecoins”. Issuers of these stablecoins are required to hold reserve assets equivalent to at least 100% of the par value of the outstanding single currency stablecoins in circulation at all times (including those held by the issuer). Furthermore, the reserve assets must be denominated in the same currency as the pegged currency of the stablecoin, with the value of such reserve assets calculated daily on a mark-to-market basis. These issuers are also required to maintain reserve assets in distinct, segregated accounts separate from their own non-reserve assets. These segregated accounts may be held with FIs licensed for custodial services in Singapore by MAS, or by overseas-based custodians provided that certain conditions are met. The base capital requirements for a SIS provider will be higher than those required of e-money issuers and DPTSPs regulated under the current PS Act – ie, the higher of SGD1 million or 50% of the annual operating expenses of the issuer.

In terms of business restrictions, under the new SIS, MAS does not intend to allow an issuer of MAS-regulated stablecoins to take on business offerings such as lending services, dealing or fund management services, which introduce additional risks to the issuer. That said, such activities can still be conducted from other related entities that the issuer does not have a stake in.

It is unlikely that algorithmic stablecoins can satisfy these requirements for the issuers to be regulated as SIS. These issuers will be regulated under the existing PS Act as DPTSPs instead.

See above 6.2.1 Fiat Currency and Algorithmic Stablecoins.

While the business restrictions imposed on the DPTSPs could constrain the issuer’s ability to pay interest or yield in certain ways (see 6.2.1 Fiat Currency and Algorithmic Stablecoins and 2.2 Crypto-Asset Regulatory Frameworks), there is no explicit prohibition on the payment of interest, whether by the issuer or any other related entity.

A stablecoin arrangement in Singapore is considered systemic if its disruption could significantly impact users, the financial system or public confidence. Factors include transaction volume, stablecoin value in circulation, user base, market share, interconnections with FIs, operational complexity and alternatives. According to the initial consultation on the single currency stablecoin framework in 2022, MAS does not consider any stablecoin arrangement in Singapore to be likely to qualify as posing a systemic risk.