MAS Stablecoin Consultation Paper: What Issuers Must Build

Video transcript

MAS wants its stablecoin framework written into law. Its September consultation paper is still only a proposal, but the engineering duties are already clear enough to start building.

Consultation closed on October 16, 2026. As of November 5, MAS has published no response, and no amendment bill has been introduced in Parliament.

A new stablecoin issuance license would require separate reserves, redemption at par, safeguarded customer money, no interest for holders, and published auditor attestations.

Under the draft, breaching reserve or redemption duties could bring fines of up to two hundred fifty thousand Singapore dollars. Log each redemption request on receipt, since that starts the clock.

MAS proposes board-reviewed stress tests at least quarterly, covering a redemption run, a reserve fire sale and a payment outage. Critical weaknesses could mean extra buffers.

On a live token, wind-down is engineering. Stop minting, keep redemption open, close every bridge route, then retire privileged roles.

Paragraph three point two two would require the capability to trace, freeze and burn coins tied to illicit activity, tested on every chain.

Guardian has run more than fifty engagements on USDT zero, Tether's omnichain stablecoin, including fork tests that caught a gap in a network cutoff.

Read the full article for the complete build list, or talk to Guardian about testing your redemption, freeze and wind-down systems.

MAS published consultation paper P015-2026 on September 1, 2026. It proposes amendments to the Payment Services Act 2019 that would put its 2023 stablecoin framework into law.

Consultation closed on October 16, 2026. As of November 5, 2026, MAS has published no response, and Parliament's list of bills shows no Payment Services Act amendment bill.

Detail will follow in subsidiary legislation and a Notice. The engineering duties are already clear enough to start building.

This article explains the technical and security side of MAS consultation paper P015-2026. It is not legal advice; confirm how it applies to you with counsel.

Where P015-2026 Stands

The framework covers single-currency stablecoins issued in Singapore and pegged to the Singapore dollar or a G10 currency. MAS expects to authorize or recognize only a limited number.

Our stablecoin regulation guide compares Singapore with the US, EU, Hong Kong and the UK.

The License and Core Obligations

A new "stablecoin issuance" license class would let only licensees present themselves as issuers of an MAS-regulated stablecoin.

Issuance covers minting, putting coins into circulation, managing reserves and redeeming at par. Every obligation sits with the licensed issuer.

Licensees could not carry on other regulated activities, such as other payment services or banking. They could still transmit or safeguard their own coin.

Banks would issue through a separate non-bank entity.

The draft law and paper set these core duties:

• Reserves: a separate pool per coin, at least the par value of coins in circulation.
• Redemption: at par, within a time MAS will prescribe. The 2023 framework said five business days.
• Safeguarding: customer money until coins are delivered, and redemption money until the holder receives it.
• Interest ban: no interest, return or other benefit tied to holding the coin.
• Attestation: an auditor attests the reserves; the issuer publishes each report.

Under the draft, breaching the reserve or redemption duty would be an offence, with fines of up to S$250,000.

The redemption clock in draft section 21B runs from receipt of the request. Log that moment, not just the payout. The UK's PS26/10 starts its clock when the coin arrives instead.

Stress Tests, Recovery and Wind-Down

MAS says issuers should have risk management covering operational risks, including fraud and cyber, plus compliance and financial stability risks.

Quarterly stress tests

MAS proposes stress tests at least quarterly, covering idiosyncratic and systemic shocks, reviewed by the board and shared with MAS.

Liquidity plans should address extreme but plausible scenarios, such as:

• a redemption run;
• reserve assets that cannot be sold quickly at par;
• payment or settlement outages.

Where tests reveal critical vulnerabilities, MAS could impose extra capital, liquidity or reserve buffers.

Recovery and wind-down plans

Recovery plans keep critical functions running through a major disruption, such as missed redemptions. Wind-down plans set the steps, resources and timeline for an orderly exit.

Both would be board-approved and shared with MAS at least annually, with the financial resources behind them independently verified.

A departing issuer could use reserves only to pay redemptions until MAS is satisfied none are outstanding.

On a live token, wind-down is engineering: stop minting, keep redemption open, close every bridge route, then retire the privileged roles.

Technology risk

The paper says issuers would face MAS's existing technology risk requirements, without naming the instrument.

For reference, Notice FSM-N13 applies today to digital payment token service providers, not to stablecoin issuers. It sets:

• at most 4 hours of unscheduled downtime per critical system in 12 months;
• a recovery time objective of 4 hours or less, validated yearly;
• notice to MAS within 1 hour of a severe incident;
• a root cause report within 14 days.

Trace, Freeze and Burn

Paragraph 3.22 would require "technical capabilities to trace, freeze and/or burn" coins used for or in support of illicit activities. A Notice will set the specifics.

MAS also asks whether to go further, with verified identity for every holder, restrictions on unhosted wallets, and ongoing monitoring of coins in circulation.

Each capability is a system to build and test on every chain:

• Trace: index every transfer and screen holder addresses.
• Freeze: stop an address moving value through transfers, permits, bridges and redemption.
• Burn: destroy a frozen balance, behind a higher approval threshold.

Our freeze requirements comparison sets MAS beside the GENIUS Act and Hong Kong, with one role design for all three.

Systemic and Offshore Stablecoins

Designated systemic stablecoins

A new Part 2A would let MAS designate a stablecoin as systemic, wherever it is issued. Factors include size, links to payment and financial systems, and substitutability.

Designated issuers would meet core requirements plus recovery and resolution plans. If they fall short, MAS could direct licensed crypto service providers to stop offering or delist the coin.

MAS could require any issuer of a token that aims to hold a stable value to report issuance and redemption data on coins circulating in Singapore, even if not called a stablecoin.

Multi-jurisdictional issuance

MAS barred co-issuance in 2023. It now proposes case-by-case exemptions, under a new section 100A, for one fungible coin issued from Singapore and abroad. Conditions include:

• a foreign co-issuer under a substantively equivalent framework;
• reserves of at least 100% of all coins outstanding, including issuer-held coins;
• the stricter composition rule across jurisdictions;
• a rebalancing or attribution model approved before issuance, with daily records;
• comparable redemption fees and timelines.

An attribution model has to know which issuer backs which coins, chain by chain, every day.

A new Part 2B would also let MAS recognize a limited number of foreign-regulated stablecoins, case by case.

What to Build Before the Bill

Start with these:

• A daily reserve-to-supply reconciliation across every chain.
• A redemption log that timestamps each request on receipt.
• Segregated accounts for subscription and redemption money in transit.
• A quarterly stress test: a run, a fire sale and a payment outage.
• Recovery and wind-down runbooks for each chain, rehearsed on a fork.
• Trace, freeze and burn tooling, tested on every chain and path.
• A critical system list, and recovery and incident targets that meet FSM-N13's 4 hours and 1 hour.

How Guardian Helps

Guardian's regulatory readiness assessment works out which provisions reach you, including a MAS license, and tests where you stand against each one.

Its operational resilience assessment names critical business services as MAS does, then tests scenarios such as a chain halt and a depeg.

Since January 2025, Guardian has run more than 50 engagements on USDT0, Tether's omnichain stablecoin. Two findings show these duties in code.

• Freeze: in USDT's Arbitrum upgrade, an informational finding showed a blocklisted address could still call guarded functions through aliased cross-chain messages. Its transfers stayed blocked.
• Wind-down: as USDT0 prepared to cut off the Corn network in May 2026, fork tests showed the queued transactions left Rootstock able to send to Corn.

Our stablecoin security guide covers the rest of an issuer's attack surface.

Frequently Asked Questions

Has Singapore passed its stablecoin law?

No. MAS's consultation on the Payment Services Act amendments closed on October 16, 2026. As of November 5, 2026, MAS has published no response, and no amendment bill appears in Parliament's list of bills introduced.

Will MAS require stablecoin issuers to freeze tokens?

MAS has proposed it. Paragraph 3.22 of P015-2026 would require technical capabilities to trace, freeze and/or burn stablecoins found to be used for or in support of illicit activities, with specifics in a later Notice.

Can one stablecoin be issued from Singapore and another country?

MAS proposes to allow it case by case under a new section 100A. Foreign co-issuers would need a substantively equivalent framework, and reserves across all issuers would need to cover at least 100% of coins outstanding.

Sources

• MAS: Consultation on Proposed Amendments to the Payment Services Act 2019 for Stablecoins Regulation, P015-2026 (September 1, 2026)
• MAS: Consultation Paper P015-2026 (PDF, September 2026)
• MAS: Annex C, draft amendments to the Payment Services Act (PDF, September 2026)
• MAS: MAS Consults on Legislative Amendments to Implement Stablecoin Regulatory Framework (September 1, 2026)
• MAS: MAS Finalises Stablecoin Regulatory Framework (August 15, 2023)
• MAS: Notice FSM-N13 Technology Risk Management (May 9, 2024)
• Parliament of Singapore: Bills introduced (accessed November 5, 2026)
• Guardian: USDT0 client story
• Guardian: USDT Arbitrum Upgrade report (January 23, 2025)
• Guardian: USDT0 Corn Network Delisting report (May 27, 2026)