Monetary Authority of Singapore Releases First RWA Regulatory Document! 17 Major Cases Clarify Compliance Boundaries for the First Time—Will Hong Kong Follow Suit?

On November 4, 2025, the Monetary Authority of Singapore (MAS) ushered in a new chapter in the regulation of real-world asset (RWA) tokenization. The “Capital Markets Products Tokenization Guidelines,” through 17 typical cases, systematically defined the boundaries of tokenized assets for the first time, marking a shift in global RWA regulation from vague exploration to the implementation of clear rules. This brings unprecedented regulatory clarity to a market long trapped in a “gray area.” It not only signifies Singapore’s critical leap from “regulatory limbo” to “compliant implementation,” but also provides a replicable model for global RWA exploration.

In this innovation that intertwines institutions and technology, MAS emphasizes the principles of “economic substance over form” and “technology neutrality,” enabling traditional finance and blockchain innovation to operate under a unified regulatory framework. From bank capital allocation to cross-border asset flows, from institutional pilots to retail market expansion, Singapore’s practices are reshaping market trust, optimizing risk controls, and serving as an observation window for RWA compliance in the Asia-Pacific and globally.

I. Regulatory Turning Point: From Policy Evolution to Market Response

On November 14, 2025, MAS released the “Capital Markets Products Tokenization Guidelines,” providing the RWA sector its first comprehensive regulatory framework. This move is not an isolated event, but a key milestone in the evolution of Singapore’s digital asset regulation. According to MAS’s public policy trajectory, its regulatory system began with the 2019 Payment Services Act, gradually expanding to the 2020 Digital Token Offerings Guidelines and the 2022 Digital Asset Consultation Paper, culminating in today’s comprehensive system covering issuance, trading, and custody.

The market demand for regulatory clarity has been building for years. The Chainalysis “2025 Global Crypto Adoption Index” shows that 24.4% of Singapore’s adult population holds digital assets, ranking first in the Asia-Pacific region. Meanwhile, Capgemini’s “2025 Global Wealth Report” points out that Asian family offices allocate 3%-5% of their assets to digital assets, but regulatory uncertainty has long restricted further growth. The release of MAS’s new guidelines directly responds to the market’s urgent need for clear rules.

It is noteworthy that Singapore’s timing for these guidelines is closely tied to international regulatory coordination. In June 2025, the Basel Committee on Banking Supervision officially implemented crypto asset capital requirements, bringing tokenized traditional assets into the banking capital framework; in October of the same year, the EU’s “Markets in Crypto-Assets Regulation” completed key legislative procedures. Singapore’s guidelines, in both timing and substance, align with global regulatory trends, reflecting its intent to help shape international compliance standards.

II. Regulatory Philosophy: Technology Neutrality and Economic Substance Analysis

In its guidelines, MAS clarifies its regulatory philosophy is based on the principle of “same activity, same risk, same regulatory outcome.” This originates from the International Organization of Securities Commissions’ fintech regulatory principles, but Singapore translates it into actionable standards through concrete cases. According to Section 2.3 of the guidelines, the core of determining whether a token qualifies as a capital markets product is “economic substance analysis,” requiring a comprehensive assessment of the token’s features, the issuer’s intent, overall structure, and the bundle of rights attached.

Compared to the US SEC’s reliance on the “Howey Test,” Singapore’s framework emphasizes a multi-dimensional, balanced approach. For example, in Case 3, a platform issues diamond tokens with a repurchase clause; despite being marketed as “utility tokens,” the fixed price repurchase commitment leads to their classification as bonds. This approach is similar to the Swiss FINMA’s “token classification framework,” but Singapore significantly improves regulatory predictability through its case-based method.

The guidelines also explicitly exclude the legal effect of industry terms such as “security tokens” and “utility tokens.” MAS explains in the appendix that such labels may obscure a token’s economic substance, leading to regulatory arbitrage. This position contrasts with the Hong Kong SFC’s 2024 “Virtual Asset Trading Platform Guidelines,” which retains the “security token” category but requires platforms to assess each case individually.

III. Three-Dimensional Compliance Map: Asset Type, Rights Attributes, and Legal Structure

The Singapore framework provides project teams with a clear map for assessing compliance along three dimensions:

The asset dimension determines the baseline compliance cost. Highly liquid, standardized assets like government bonds and stocks are easier to tokenize, while non-standard assets require complex legal structures. For example, in Case 6, tokenized funds pooling investor money and managed by professionals are classified as collective investment schemes, subject to licensing, disclosure, and investment restrictions. Meanwhile, in Case 16, NFTs representing digital artworks primarily confer intellectual property rights and are not regulated.

The rights dimension is central to regulatory classification. The guidelines illustrate boundaries through Cases 1 and 13: tokens representing company ownership with dividend rights are considered shares, while tokens granting only platform governance voting rights are not deemed capital markets products. The closer the rights are linked to financial attributes, the stricter the regulatory requirements.

The structure dimension concerns the implementation path for compliance. Projects must assess whether to set up special purpose vehicles, require custody arrangements, and conduct audits. In Case 5, tokens wrapping bonds using a trust structure are treated as independent financial products, with the issuer bearing separate disclosure obligations. While complex structures may partially isolate risks, they cannot change the underlying asset’s economic substance.

IV. Impact on Banking: Capital Requirements and Business Model Restructuring

In a consultation paper released in March 2025, MAS clarified it would fully implement the Basel Committee’s capital standards for bank crypto assets. The framework divides crypto assets into two groups: Group 1 includes tokenized traditional assets and qualifying stablecoins, with capital treatment based on the underlying assets; Group 2 includes permissionless blockchain assets, subject to a 1250% risk weighting.

This classification has far-reaching implications for banks participating in the RWA market. For example, tokenized notes issued by DBS Bank on Ethereum, because they use a permissioned chain, may fall into Group 1; similar products issued on a permissionless chain would face much higher capital requirements. According to JPMorgan’s “2025 Tokenization Report,” some European banks have adjusted their technology strategies accordingly, prioritizing permissioned or hybrid architectures.

Bank business models are also being restructured. The head of Standard Chartered’s innovation unit noted that their tokenized bond issuance is shifting from “investor-oriented” to “capital efficiency-oriented,” optimizing risk weights through architectural design. This shift demonstrates the direct impact of regulatory rules on market behavior.

V. City Competition and Cooperation: Regulatory Paths and Market Practices in Hong Kong and Singapore

Hong Kong and Singapore show distinct differences in RWA regulation, mainly in three aspects:

At the legal framework level, Hong Kong relies on the Securities and Futures Ordinance and VASP licensing, forming a license-centered regulatory model; Singapore builds a functional regulatory system based on the Securities and Futures Act, Payment Services Act, and DTSP rules. The former focuses more on institutional entry, the latter on the economic substance of activities.

In regulatory culture, Hong Kong’s HKMA leads the government’s green bond tokenization through the “Evergreen Program,” reflecting a top-down approach; Singapore’s “Project Guardian” brings together over 40 international institutions to build an industry co-governance ecosystem. This difference highlights the contrasting market structures: Hong Kong is backed by Mainland China’s asset pool, while Singapore targets global liquidity.

On the technology integration front, Hong Kong requires sandbox projects to connect to the HKD stablecoin settlement layer, reinforcing sovereign currency status; Singapore’s “Asset Tokenization Technology Whitepaper 2.0” promotes cross-chain interoperability standards. These represent “closed-loop controllable” versus “open and interconnected” technology philosophies.

These institutional differences directly shape financial institutions’ strategic layouts. HSBC employs a dual-headquarters model, issuing Mainland Chinese municipal bonds in tokenized form in Hong Kong, and expanding tokenized REITs retail business in Singapore; Ant Group secures 1, 4, and 9 licenses in Hong Kong for handling Mainland-linked assets, and applies for a payment license in Singapore to build the XSGD settlement channel; JPMorgan Onyx chooses Singapore for retail REITs due to the greater global replicability of its regulatory standards.

Market practices clearly reflect the comparative advantages of each location: Hong Kong’s unique position in connecting to Mainland assets, and Singapore’s leadership in rule-setting and technical standardization. CMB International achieved the first Hong Kong-Singapore recognized fund tokenization through multi-chain deployment, offering a new paradigm for cross-market collaboration.

VI. Regulatory Innovation: Expanded Disclosure, Control Definition, and Extraterritorial Jurisdiction

The MAS framework includes three breakthrough innovations:

Disclosure requirements now extend from finance to technology. Section 3.7 of the guidelines requires issuers to disclose DLT type, smart contract audits, private key management, and to clarify the mapping between on-chain records and legal rights. This “technology transparency” principle may become a global benchmark.

The definition of control reshapes custody boundaries. MAS defines “control” as “the ability to access or transfer tokens,” without requiring exclusivity. This means multisig wallet providers and DeFi protocol administrators may be considered custodians and need corresponding licenses.

Extraterritorial jurisdiction closes regulatory loopholes. According to Section 339 of the Securities and Futures Act, MAS can exercise jurisdiction over overseas activities that have a “substantial effect in Singapore.” Combined with the broad interpretation of “in or from Singapore” under the DTSP rules, the space for regulatory exemptions through offshore structuring is greatly reduced.

The release of Singapore’s guidelines is accelerating global RWA regulatory coordination. The EU’s MiCA framework brings tokenized assets under existing financial regulations; Japan’s FSA will revise the Financial Instruments and Exchange Act in 2025 to clarify that tokenized securities fall under traditional rules; Abu Dhabi Global Market is building a flexible regime for digital assets under common law through the FSRA framework.

Technology is also playing an increasingly prominent role. Ant Group’s Layer 2 chain achieves 100,000 TPS, enabling millisecond-level settlement; Chainlink’s DECO protocol uses zero-knowledge proofs to verify off-chain assets, addressing information asymmetry. These innovations are propelling RWA from “proof of concept” to “scalable application.”

The future landscape may see a dual-track evolution: Hong Kong as the digital issuance center for high-quality Mainland assets, Singapore focusing on rule-setting and cross-chain standards. However, the core of the competition is the balancing act between “compliance and innovation”—regulation must guard against risks without stifling innovation. As MAS’s Chief FinTech Officer said: “Our goal is not the strictest rules, but the clearest rules.”

Some of the sources for this article:

· “MAS Releases RWA Issuance Guidance Framework! Seventeen Token Case Studies Explained! Can Hong Kong Copy the Homework?” · “Singapore’s Tokenization Regulations ‘Surprise’—The Asia-Pacific Financial Center Battle Is On Again” · “Interpretation: MAS’s Commercialization Plan for Asset Tokenization”