Digital Asset LABMarket Structure Research
SINGAPORE TOKENISED SECURITIES MARKET MAP
A market that wrote no new law and applies the existing securities statute as it stands. What moves first here is not legislation but public–private projects.
01 · STATUS
“Approved,” “rule effective,” and “live in production” are different states. This site keeps them separate.
MAS states that existing requirements apply to tokenised and non-tokenised capital markets products alike, on the principle of “same activity, same risk, same regulatory outcome”. Tokenisation changes the form in which something is created, not its economic substance. The approach is technology-neutral and looks to the substance of the token.
Whether a digital token is a capital markets product under the Securities and Futures Act is decided by a holistic examination of its characteristics, intent and structure, and of the bundle of rights attaching to it. If it is, MAS then identifies which type — a share, a debenture, a unit in a collective investment scheme and so on.
A primary market platform needs a capital markets services licence; a trading platform is an organised market and must be an approved exchange or a recognised market operator; custody needs a capital markets services licence for custodial services. No bespoke category was created for tokenisation.
A collaboration between MAS and the industry with more than forty participating organisations, in three workstreams: asset and wealth management (led by Schroders), fixed income (led by ICMA) and foreign exchange (led by Ant Group and ISDA). MAS says the live implementations offer tangible evidence of commercial viability, operational resilience and regulatory alignment.
The Guardian Fixed Income Framework, an industry guide to implementing tokenisation in debt capital markets, and the Guardian Funds Framework, recommendations for tokenised funds. Neither is law; both are industry practice guidance.
Set out in a May 2024 whitepaper: a shared ledger for regulated financial assets, tokenised central bank money and commercial bank money. BNY, Citi, J.P. Morgan, MUFG and SG-FORGE take part, with staff from the ECB, Banque de France and the IMF observing. It is at the stage of exploring a non-profit organisation — not a running infrastructure.
Project Guardian is a wholesale initiative; its participants are banks, asset managers and market infrastructures. DBS Digital Exchange is members-only, serving institutional and accredited investors. A clear framework is not the same thing as retail access.
02 · OWNERSHIP
Using the SEC’s January 2026 taxonomy as the anchor, classification follows legal structure and authoritative ownership records—not the appearance of the token.
MAS describes tokenisation as using software to create a digital token that constitutes or represents a capital markets product. Rather than creating a new legal vessel as Switzerland did, or granting time-limited exemptions as the EU did, Singapore resolves it by applying the existing law.
There is no lighter path because something is a token. The offering rules apply in the same way whatever the form — that is the consistent logic of this market.
03 · TRADING ROUTES
Ownership model and trading venue are separate axes. The rules and settlement path differ by route.
A platform for trading tokenised securities, derivatives or units in a collective investment scheme may be an organised market. To operate one, a person must be approved by MAS as an approved exchange or recognised as a recognised market operator.
Operating a primary market platform requires a capital markets services licence for the relevant regulated activity. Having possession or control of customers' products requires a capital markets services licence for providing custodial services.
04 · REALITY CHECK
24/7 trading, instant settlement, self-custody and fractional buying are the four things most often promised. None of them apply uniformly across the models.
Important caveat: Both are permanent, but they were arrived at from opposite directions. “There is a framework” means different things in each.
Important caveat: When something is described as “approved by MAS”, it is worth separating a rule from a project deliverable.
05 · ECOSYSTEM
This is not a regulator-approved company list. It maps roles that firms have publicly disclosed or filed, with sources.
Both central bank and financial regulator. It publishes the guidance, grants the licences, and leads Project Guardian and GL1.
A members-only digital asset venue run by DBS, offering trading, tokenisation and custody to institutional and accredited investors. It is not a venue for individuals to trade directly.
A multi-member network formed by Citi, HSBC, Schroders, Standard Chartered and UOB to commercialise their respective tokenisation trials and scale usage.
A shared-ledger initiative led by BNY, Citi, J.P. Morgan, MUFG and SG-FORGE, joined by Euroclear and HSBC. It is at the stage of exploring an operating organisation.
MAS facilitating financial institutions' access to common settlement assets, including wholesale SGD CBDC, for market testing. DBS, OCBC, Standard Chartered and UOB are the initial participants.
06 · LICENCES
Registration, effectiveness of a filing, approval and exemption are different concepts. “The SEC is involved” does not mean the same thing in each case.
CautionExemptions exist (section 82 of the SFA). There is no special treatment for tokenisation.
CautionWhich of the two applies is addressed in the Guidelines on the Regulation of Markets (SFA02-G01).
CautionThe same disclosure is required as for a conventional security.
06 · REGULATION
Statutes, SEC orders, SRO filings, no-action letters, staff views and company plans are not given the same legal weight.
MAS stated that offers or issues of digital tokens are regulated where the tokens are products regulated under the Securities and Futures Act. The position has been consistent ever since.
Sets out a shared ledger able to handle regulated financial assets across borders. A concept, not an operating system.
Four strands: the Guardian Wholesale Network, an expanded GL1, two industry frameworks (GFIF and GFF), and the SGD testnet. None of these is legislation; they are implementation and guidance.
Succeeding the 2017 digital token offerings guide, this version extends to secondary trading, settlement and custody, bringing the tests and the licensing requirements into one document.
07 · SOURCES
SEC, DTCC/DTC, NYSE/ICE and Nasdaq are prioritized. Company materials are clearly identified as company sources.
Monetary Authority of Singapore (MAS) · 2025-11-14 · Primary source
Monetary Authority of Singapore (MAS) · 2025-11-14 · Primary source
Monetary Authority of Singapore (MAS) · Primary source
Monetary Authority of Singapore (MAS) · 2024-11-04 · Primary source
Monetary Authority of Singapore (MAS) · 2024-05 · Primary source
Monetary Authority of Singapore (MAS) · 2017-08-01 · Primary source
DBS · Company source
08 · METHODOLOGY
First identify what the investor legally holds, then identify the trading route, and finally verify the authoritative source and operating status. The word “tokenized” alone does not determine shareholder rights, counterparty risk or settlement cycle.