On November 4, 2025, the Monetary Authority of Singapore (MAS) opened a new chapter in the regulation of real-world asset (RWA) tokenization. The "Guidelines on Tokenization of Capital Market Products" systematically defined the boundaries of tokenized assets for the first time through 17 typical cases, marking a shift from vague exploration to regulatory implementation in global RWA oversight, bringing unprecedented clarity to a market that has long been in a "gray area." This not only signifies Singapore's critical leap from "regulatory void" to "compliance implementation," but also provides a replicable paradigm for global RWA exploration.

In this innovation interwoven with systems and technology, MAS emphasized the principles of "economic substance over form" and "technology neutrality," allowing traditional finance and blockchain innovation to operate under the same regulatory framework. From bank capital allocation to cross-border asset flow, from institutional pilots to retail market expansion, Singapore's practices are reshaping market trust, optimizing risk control, and becoming an observation window for RWA compliance in the Asia-Pacific region and globally.

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

On November 14, 2025, the Monetary Authority of Singapore released the "Guidelines on Tokenization of Capital Market Products," providing the first comprehensive regulatory framework for the RWA sector. This initiative is not an isolated event but a key milestone in the evolution of Singapore's digital asset regulation. According to MAS's publicly available policy context, the construction of its regulatory system began with the Payment Services Act in 2019, gradually expanding to the Digital Token Offering Guidelines in 2020, the Digital Assets Consultation Paper in 2022, and ultimately forming a complete institutional system covering issuance, trading, and custody.

The market's demand for regulatory clarity has accumulated over the years. Chainalysis' "2025 Global Crypto Asset Adoption Index" shows that 24.4% of Singapore's adult population holds digital assets, ranking first in the Asia-Pacific region. Meanwhile, the Accenture "2025 Global Wealth Report" indicates that Asian family offices allocate 3%-5% of their assets to digital assets, but long-standing regulatory uncertainty has constrained further growth. The release of MAS's guidelines directly responds to the urgent market demand for clearer rules.

Notably, Singapore's decision to launch the guidelines at this time is closely related to international regulatory coordination. In June 2025, the Basel Committee on Banking Supervision officially implemented capital requirements for crypto assets, incorporating tokenized traditional assets into the banking capital framework; in October of the same year, the EU's "Crypto Asset Market Regulation" completed key legislative procedures. Singapore's guidelines resonate with global regulatory trends in both timing and content, reflecting its intention to build international compliance standards.

2. Regulatory Philosophy: Technology Neutrality Principle and Economic Substance Analysis

MAS clearly states in the guidelines that its regulatory philosophy is based on the principle of "same activity, same risk, same regulatory outcome." This statement originates from the International Organization of Securities Commissions' "Regulatory Principles for Financial Technology," but Singapore has transformed it into an actionable judgment standard through specific cases. According to Section 2.3 of the guidelines, the core of determining whether a token falls under capital market products is "economic substance analysis," which requires a comprehensive assessment of the token's characteristics, the issuer's intent, the overall structure, and the associated rights bundle.

Compared to the "Howey Test" relied upon by the U.S. SEC, the Singapore framework places greater emphasis on the comprehensive weighing of multidimensional factors. For example, in Case 3, a platform issued a diamond token with a buyback clause, which, despite being marketed as a "utility token," was deemed a bond due to the fixed-price buyback commitment. This judgment method bears similarities to Switzerland's FINMA "Token Classification Framework," but Singapore significantly enhances regulatory predictability through case-based examples.

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 the economic substance of tokens, leading to regulatory arbitrage. This stance contrasts with the Hong Kong Securities and Futures Commission's 2024 "Guidelines for Virtual Asset Trading Platforms," which still retains the "security token" classification but requires platforms to assess the nature on a case-by-case basis.

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

The Singapore framework provides project parties with a clear map to assess compliance paths from three dimensions:

The asset dimension determines the basic compliance costs. Highly liquid standardized assets, such as government bonds and stocks, are easier to tokenize, while non-standard assets require complex legal structures. For example, in Case 6, a tokenized fund that pools investor funds and entrusts professional management was deemed a collective investment scheme, requiring compliance with authorization, disclosure, and investment restrictions. In contrast, Case 16, representing a digital artwork NFT, was not included in regulation as it primarily conferred intellectual property rights.

The rights dimension is the core of regulatory qualification. The guidelines clarify boundaries through the comparison of Case 1 and Case 13: tokens representing company ownership with dividend rights are recognized as shares, while tokens that only confer governance voting rights on the platform are not considered capital market products. The closer the relationship between rights and financial attributes, the stricter the regulatory requirements.

The structure dimension concerns the compliance implementation path. Project parties need to assess whether they need to establish special purpose entities, whether custodial arrangements are necessary, and the audit requirements. In Case 5, a token packaged as a bond through a trust structure was determined to be an independent financial product, requiring the issuer to undertake separate disclosure obligations. While complex structures can partially isolate risks, they cannot change the economic substance of the underlying assets.

4. Impact on Banking: Capital Requirements and Business Model Reconstruction

In a consultation paper released in March 2025, MAS clarified that it would fully implement the Basel Committee's capital standards for banks regarding crypto assets. This framework categorizes crypto assets into two groups: Group 1 includes tokenized traditional assets and qualified stablecoins, with capital treatment based on the underlying assets; Group 2 includes unlicensed blockchain assets, subject to a 1250% risk weight.

This classification has profound implications for banks' participation in the RWA market. For instance, DBS Bank's tokenized notes issued on Ethereum may fall under Group 1 due to their use of a licensed chain structure; however, similar products deployed on an unlicensed chain would face significantly higher capital requirements. JPMorgan's "2025 Tokenization Report" indicates that some European banks have adjusted their technology routes accordingly, prioritizing licensed chains or hybrid structures.

Banking business models are also being reconstructed. The head of the innovation department at Standard Chartered Bank noted that its tokenized bond issuance has shifted from "investor-oriented" to "capital efficiency-oriented," optimizing risk weights through structural design. This shift confirms the direct shaping power of regulatory rules on market behavior.

5. Competitive Cooperation: Regulatory Paths and Market Practices in Hong Kong and Singapore

Hong Kong and Singapore exhibit distinct differences in RWA regulation, primarily in three aspects:

In terms of legal framework, Hong Kong relies on the Securities and Futures Ordinance and the VASP licensing system, forming a license-centric regulatory model; Singapore, on the other hand, constructs a functional regulatory system based on the Securities and Futures Act, the Payment Services Act, and DTSP rules. The former places greater emphasis on institutional access, while the latter focuses more on the substance of economic activities.

In terms of regulatory culture, the Hong Kong Monetary Authority leads the government's green bond tokenization through the "Evergreen Program," reflecting a top-down promotion path; Singapore's "Guardian Program" collaborates with over 40 international institutions to build an industry co-governance ecosystem. This difference reflects the distinct market structures of the two regions—Hong Kong is backed by a domestic asset pool, while Singapore targets global liquidity.

In terms of technological integration, Hong Kong requires sandbox projects to connect to the Hong Kong dollar stablecoin settlement layer, reinforcing the status of sovereign currency; Singapore released the "Asset Tokenization Technology White Paper" 2.0 to promote cross-chain interoperability standards. The two represent the technological philosophies of "closed-loop control" and "open interconnection," respectively.

These institutional differences directly shape the strategic layout of financial institutions. HSBC adopts a dual-headquarters model, issuing mainland city investment bond tokens in Hong Kong while expanding retail REIT tokenization in Singapore; Ant Group's digital technology arm obtains licenses 1, 4, and 9 in Hong Kong to handle mainland-related assets while applying for a payment license in Singapore to build an XSGD settlement channel; JPMorgan Onyx chooses to conduct retail REITs in Singapore due to the easier replicability of regulatory standards globally.

Market practices clearly reflect the comparative advantages of the two regions: Hong Kong holds a unique position in connecting with mainland asset sides, while Singapore leads in rule output and technological standardization. CMB International achieved the first tokenization of a Hong Kong-Singapore mutual recognition fund through multi-chain deployment, providing a new paradigm for cross-market collaboration.

6. Regulatory Innovation: Disclosure Expansion, Control Definition, and Extraterritorial Jurisdiction

The MAS framework includes three groundbreaking innovations:

Disclosure requirements extend from financial to technical. Section 3.7 of the guidelines requires issuers to disclose technical details such as DLT type, smart contract audits, and private key management, and clarifies the mapping relationship between on-chain records and legal ownership. This "technical transparency" principle may become a global model.

The definition of control reshapes custodial boundaries. MAS defines "control" as "the ability to access or transfer tokens" without requiring exclusivity. This means that multi-signature wallet service providers and DeFi protocol administrators may be recognized as custodians and need to apply for corresponding licenses.

Extraterritorial jurisdiction blocks regulatory arbitrage. According to Section 339 of the Securities and Futures Act, MAS can exercise jurisdiction over foreign activities that have a "substantial impact on Singapore." Combined with the broad interpretation of "in or from Singapore" in the DTSP rules, the regulatory exemption space for offshore structures has been significantly narrowed.

The release of Singapore's guidelines accelerates global RWA regulatory coordination. The EU is incorporating tokenized assets into existing financial instrument regulation based on the MiCA framework; Japan's Financial Services Agency is revising the Financial Instruments and Exchange Act in 2025 to clarify that tokenized securities are subject to traditional rules; Abu Dhabi Global Market is constructing a flexible system under the FSRA digital asset framework within the Anglo-American legal system.

Technological drivers are also becoming increasingly significant. Ant Group's Layer 2 chain achieves 100,000 TPS, providing a foundation for millisecond-level settlement; Chainlink's DECO protocol verifies off-chain assets through zero-knowledge proofs, addressing information asymmetry issues. These innovations are driving RWA from "proof of concept" to "scale application."

The future landscape may present a dual-track evolution: Hong Kong becoming a digital issuance center for high-quality mainland assets, while Singapore focuses on rule output and cross-chain standards. However, the essence of competition between the two regions is the practice of balancing "compliance and innovation"—regulation must prevent risks without stifling innovation. As the Chief FinTech Officer of MAS stated, "Our goal is not the strictest rules, but the clearest rules."

Some sources of information:

· "MAS Releases RWA Issuance Guidance Framework! Detailed Explanation of Seventeen Token Cases! Can Hong Kong Copy the Homework?"

· "Singapore's New Tokenization Regulations 'Surprise' Renew the Battle for Asia-Pacific Financial Center"

· "Interpretation: The Commercialization Plan for Asset Tokenization by the Monetary Authority of Singapore"

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