How to Secure a Singapore MPI/DPT Licence More Effectively
When teams first explore licensing options in Singapore, they often run into the same questions:
“We know we need an MPI or DPT licence — but what is MAS actually looking at?
Why do some applications move forward smoothly, while others remain stalled for months?”
In a previous CryptoLicense article, Singapore Crypto Licensing in 2026: PSA, MPI, DPT, and What You Actually Need, we discussed when companies should consider applying for an MPI or DPT licence.
In this article, we take a more practical approach. Drawing from real regulatory experience, we break down the actual MAS licensing path and focus on three questions that matter most in practice:
- Are you genuinely following a path that MAS recognises and supports?
- Are there hidden red flags in your current preparation?
- How can you reduce trial-and-error costs and improve your chances of approval?
Getting the Path Right First: How MPI and DPT Are Regulated in Practice
Under the Payment Services Act (PSA), Digital Payment Token (DPT) services are classified as a regulated payment service.
However, in practice, MAS rarely treats DPT as a licence that applicants can pursue at the beginning in isolation.
For most projects, the more realistic and regulator-aligned approach is:
Obtain an MPI licence first → then, based on actual operations, extend the licence via a formal variation to include DPT services.
It is important to note that an MPI licence is not static.
Where an applicant can demonstrate sufficient capital, staffing, compliance, and technical capabilities, MAS allows licence holders to expand their scope of regulated services through established regulatory processes.
There is, however, one non-negotiable prerequisite: capability must exist before the application is made.
Compared to whether all documents are submitted, MAS is far more concerned with whether an applicant can operate regulated activities in a sustainable and controlled manner over the long term.
In practice, three factors often determine whether an application continues to progress.
Common areas of scrutiny include:
- Whether the applicant maintains a genuine, long-term office presence in Singapore;
- Whether key management personnel are based in Singapore and actively involved in decision-making;
- Whether compliance and risk functions are genuinely operated locally, rather than outsourced or nominal.
MPI and DPT applications are not legal documentation projects — they are management capability assessments.
MAS will closely evaluate:
- Whether directors and senior management have relevant payments or fintech experience;
- Whether the CEO and CCO can directly engage with the regulator on substantive issues;
- Whether AML/CFT frameworks are operational and enforceable, rather than generic templates.
While the PSA sets minimum capital requirements, for projects involving cross-border services, DPT activities, or multiple regulated payment services, MAS typically expects a capital buffer well above the statutory minimum.
This buffer is assessed in light of operational risk, compliance costs, and potential downside scenarios.
- The applicant must be a company incorporated in Singapore, or a Singapore branch of a foreign company.
- A fixed place of business or registered office must be maintained for the secure storage of books and records.
MAS also requires that at least one person be designated at the business premises or registered office to handle customer queries or complaints.
- The statutory minimum paid-up capital is SGD 250,000.
In practice, however, MAS does not focus solely on this minimum figure. Greater emphasis is placed on whether the applicant maintains sufficient capital buffers beyond the baseline, taking into account business scale, service scope, and potential profit-and-loss volatility.
From a staffing perspective, MAS focuses on whether decision-making authority and accountability are substantively anchored in Singapore.
Typically, this means:
- At least one executive director who is a Singapore citizen or permanent resident (PR), or an executive director holding a valid Employment Pass (EP); and
- At least one director who is a Singapore citizen or PR.
The underlying logic is straightforward: key roles must be physically present in Singapore and accountable to the regulator.
The following materials do not represent the full MAS checklist, but they are the most critical documents that typically determine the direction and depth of regulatory review.
Applicants are required to submit a copy of their business profile as filed with the Accounting and Corporate Regulatory Authority (ACRA) of Singapore, together with organisation and shareholding charts.
These documents allow MAS to assess the applicant’s legal standing, ultimate control structure, and whether a clear and independent compliance function has been established.
Applicants are generally expected to provide financial statements for the past three years, demonstrating capital strength and financial sustainability aligned with the proposed scope of activities.
The business plan must clearly describe the actual operating model and explain how it complies with the PSA and other relevant legislation.
On this basis, MAS typically requires a legal opinion issued by a Singapore law firm experienced in payments regulation, providing a professional assessment of whether the proposed services constitute regulated payment services.
Applicants must submit AML/CFT policies, enterprise-wide risk assessments, and implementation arrangements, together with clear identification of the compliance officer and AML/CFT officer.
All applications must be submitted through MAS’s designated online system.
Application fees are calculated based on the types of payment services applied for and are generally non-refundable — underscoring the importance of making accurate strategic assessments before submitting an application.
Following submission, MAS conducts a substantive review based on the admission criteria set out under the Payment Services Act (PSA) and MAS Guidelines PS-G01.
The scope of review typically includes:
- Whether shareholders and senior management meet the Fit and Proper requirements;
- Whether the management team possesses relevant and demonstrable industry experience;
- The applicant’s financial position and capital adequacy;
- Whether compliance, technology, and operational capabilities are appropriately aligned with the proposed business scale.
During this phase, MAS will often engage the applicant through open meetings and written queries, requesting further clarification on business processes, compliance execution, and technical architecture.
In parallel, MAS may conduct interviews with key senior executives to assess both their professional competence and their practical understanding of the applicable regulatory framework.
Applicants that successfully pass multiple rounds of review will be issued an In-Principle Approval (IPA).
Following receipt of the IPA, companies are typically given up to six months to complete final readiness work — including team build-out, capital injection, and technical implementation — before the licence is formally granted.
At this stage, MAS’s focus shifts from design to execution: the question is no longer what you plan to do, but whether you can actually operate as proposed.
Obtaining an MPI licence does not mark the end of regulatory engagement. Instead, it signals the beginning of ongoing supervision.
Through periodic reporting, audits, and continuous supervisory dialogue, MAS assesses whether an MPI licensee has developed sufficient operational maturity to support DPT activities.
In most cases, DPT is not a simple checkbox on the MPI application form. Rather, it is a separate regulatory upgrade, typically pursued only after the applicant has demonstrated stable, compliant operations under the MPI framework.
According to our experience, DPT applications are rarely put on hold because they are not allowed. More often, they are stalled because the applicant is not yet ready.
Looking at successful cases, most approved applicants tend to share two foundational characteristics:
- They already operate a business of meaningful scale, with demonstrable experience in transaction flows, risk scenarios, and user behaviour;
- They maintain sufficiently strong capital reserves to sustain higher-frequency, higher-intensity compliance investment and ongoing operational costs.
From MAS’s perspective, a DPT licence is not a starting point. It is effectively a regulatory upgrade built upon existing capabilities.
Against that backdrop, common reasons for delay include:
- Treating DPT as an add-on option during the MPI stage, rather than as a distinct regulatory escalation;
- Compliance manuals that are disconnected from actual business flows, fund flows, and token flows;
- Inadequate technical infrastructure in areas such as wallet management, private key controls, and transaction monitoring;
- Inability to clearly identify and trace Ultimate Beneficial Owners (UBOs).
Ultimately, MAS applies a consistent and transparent test when assessing DPT applications:
Where operational maturity and capital depth have yet to reach that threshold, applications are often slowed or paused, even if they appear structurally compliant on paper.
- Avoid template-driven compliance
AML/CFT, KYC and TRM frameworks must reflect your actual business flows. MAS can immediately tell when policies are generic and disconnected from operations.
- Build capability before applying
If your team, systems and processes are not ready, applying early usually slows things down. Licensing should follow operational readiness.
- Ensure your core executives can stand up to scrutiny
MAS places significant weight on the people running the business. Through meetings, interviews and multiple queries, they assess whether management truly understands the risks and regulatory framework.
- Plan your upgrade path in advance
If DPT is part of your long-term strategy, design your MPI structure with that in mind. Retrofitting later is far more difficult.
- Write your business plan for execution, not ambition
MAS is not evaluating how big you can become. They are evaluating whether you can operate safely and sustainably.
Singapore’s regulatory framework is not designed to reward the most aggressive innovators. It is designed to select the most resilient long-term participants.
If you are evaluating an MPI or DPT application — or assessing whether your current structure is ready to move forward — feel free to reach out to CryptoLicense.