Singapore's 37: what a deliberately small licensed population buys a regulator

As at 19 June 2026, 37 firms held an active Major Payment Institution licence for digital payment token services in Singapore. For one of the world's major financial centres, in one of the most sought-after jurisdictions in digital assets, that is a strikingly small number, and it has been small deliberately, for years.

The structure

Singapore, like Hong Kong, regulates crypto activity principally through the Payment Services Act, amended in 2022, extended to stablecoins in 2023 and broadened again in 2024. Digital payment token services sit in two tiers: Standard Payment Institution for smaller operators, and Major Payment Institution for firms handling significant volume. The 37 are all MPI holders, and they span licensed exchanges, institutional custodians, consumer payment platforms with crypto features and business-to-business crypto payment processors.

The requirements themselves are not exotic: AML and counter-terrorist financing programmes, customer due diligence, travel rule compliance. What distinguishes Singapore is not the content of the rulebook but the rate at which the authority has been willing to grant against it.

What restriction actually purchases

A regulator that licenses few firms is buying three things, and it is worth being precise about them because they are often confused with protectionism.

• Supervisory depth: a supervisor with 37 licensees can know them individually. At 370 it is running a sampling regime, and at 1,200 it is processing returns.
• Signal value, where a licence is known to be difficult to obtain, it functions as a credential that banks and counterparties will actually price. That is the whole economic value of a licence to the firm holding it.
• Failure containment: the reputational cost of a licensed firm collapsing falls on the regulator that licensed it. A smaller book means fewer such events and more capacity to see them coming.

The value of a licence to its holder is set by how hard it was for everyone else to get. A regulator that grants freely is issuing a receipt, not a credential.

The trade-off is real

Restriction is not costless. It concentrates market share among incumbents, raises the effective barrier for genuinely innovative smaller firms, and pushes activity that cannot obtain a licence into jurisdictions with weaker oversight rather than out of existence. A regulator choosing this path is accepting a smaller domestic sector in exchange for a more defensible one, and should say so plainly rather than presenting the outcome as a neutral consequence of high standards.