Guide to applying for and maintaining compliance for a Singapore clearing facility: ACH and RCH

Business and application categories

A clearing facility is infrastructure for the securities and derivatives markets; it is not the same as clearing membership for an ordinary brokerage. A Singapore company may apply to be an Approved Clearing House ACH or a Recognised Clearing House RCH; a foreign company may apply to be an RCH. The current minimum base capital is 10000000SGD for an ACH and 5000000SGD for a local RCH. The local threshold should not be mechanically applied to a foreign RCH. This article has been checked up to 2026-11-04 and explains classification, application materials, governance personnel, capital and liquidity, changes in control, and ongoing reporting obligations.

Business characteristics and suitability considerations

• Establish regulated clearing or settlement infrastructure within the scope of approved products, participants and activities, providing participating institutions with a common framework of rules and risk management.
• Where a central counterparty model is used, risks may be managed centrally through the novation of counterparties, margin and default management; the actual effect depends on the model, resources and quality of participants and does not eliminate risk.
• Clear admission criteria for participants, client asset arrangements and settlement processes can assist institutions with due diligence and access assessments, but do not guarantee bank account opening or admission as a clearing member.
• The foreign RCH recognition pathway may support an overseas clearing facility in serving Singapore participants that meet the licensing conditions, but does not automatically confer the right to operate an overseas market or conduct banking business in Singapore.

1. First determine whether the business operates a clearing facility, rather than merely providing back-office services

Part 3 of the Securities and Futures Act 2001 (SFA) aims to promote safe and efficient clearing facilities and reduce systemic risk. Section 49 generally prohibits establishing or operating a clearing facility without approval, recognition or an applicable exemption, and also restricts the use of relevant clearing house designations when holding out to the public without authorisation. An application should first assess the actual contractual arrangements against the legal definitions in Part 2 of the First Schedule; the presence of “clearing” or “settlement” in a company name alone is not determinative of licensing requirements. [1] [2]

It is necessary to clarify who assumes settlement obligations, whether counterparties are replaced, whether participants’ obligations are centrally handled, and who controls default management. Software development, reconciliation services, and a broker acting as a clearing member to process transactions for its own clients may fall at different regulatory levels from operating a facility serving participating institutions. If the business model provides technology only, the service contracts and actual decision-making powers should still be checked; if it involves platform matching, custody or trading activities, each should be assessed separately for other licensing requirements. ACH/RCH status does not cover all activities. [1] [3]

• Prepare a transaction lifecycle diagram identifying the parties responsible for orders, trades, clearing, margin, settlement and default management.
• Separately list the company’s own accounts, participant accounts and client asset accounts, and explain legal ownership and fund flows.

2. Classification logic for ACHs, local RCHs and foreign RCHs

Sections 50 to 52 of the SFA establish the local approval and foreign recognition pathways. A company incorporated in Singapore may apply to be an ACH or RCH, while a foreign company may apply to be an RCH. Section 8 of the Clearing Regulations requires MAS to consider the facility’s size and structure, the services provided, the products cleared, the investors or participants using the facility, and the parties affected if the facility encounters difficulties. The key consideration is systemic impact and regulatory need, not the applicant’s choice of the category with the lowest capital requirement. [1] [2]

For a foreign RCH, MAS may also consider the laws and supervisory practices of the home jurisdiction, the company’s own rules, and cooperation between regulators. Locating a group’s headquarters overseas does not mean its Singapore subsidiary automatically qualifies for foreign RCH treatment. Approval or recognition may restrict activities, products and participant types. If a local company later changes the facility’s classification, it must use Form 4 to process the change of status under section 54 of the SFA and section 9 of the Clearing Regulations. MAS may also review the classification on its own initiative. [1] [2]

• ACH and RCH are regulatory categories; a central counterparty and a non-central-counterparty are business-function designs and should not be conflated.
• Before submission, set out the respective responsibilities of the local entity, foreign legal entity and group service companies.

3. Clearing products, central counterparty models and commercial value

Clearing securities, exchange-traded derivatives and over-the-counter derivatives gives rise to different credit, market, liquidity and settlement risks. Describe the product terms, settlement currencies, settlement cycles, price sources, margin methodology and membership criteria for each product. If the facility acts as a central counterparty (CCP), explain the mechanism for novating transactions and the obligations assumed by the clearing house. If a CCP model is not used, explain the arrangements for netting, settlement finality and participant default. [1] [3]

The value of a regulated clearing facility lies in providing enforceable common rules that enable participants to assess its margin, default-management and settlement mechanisms; it is not that “a licence permits public fundraising”. Securities tokenisation or distributed ledger technology does not alter the principle that regulation follows the substance of the business. First clarify the legal rights represented by a token, its transfer mechanism and the settlement asset, and then assess the SFA or other legislation. Do not describe digital payment tokens, security tokens and ordinary technical credentials collectively as capital markets products that can be cleared. [1] [3]

• For each product, specify cash or physical settlement, the participant scope, settlement banks and ultimate legal responsibilities.
• Review approval conditions and the required regulatory process before adding a product, rather than launching it directly on the existing system.

4. Shareholder suitability, ultimate controllers and source of funds

MAS’s admission assessment covers the applicant’s track record, financial soundness, corporate governance, and the fitness and propriety of shareholders and personnel. Section 51 of the SFA sets out grounds for refusal of approval or recognition, including the winding up of a company or major shareholder, failure to meet debts, fraud or offences involving dishonesty, insufficient experience of personnel and failure to meet the fit and proper criteria. FSG-G01 emphasises competence, honesty and integrity, and financial soundness. Information should cover direct shareholders, the indirect control chain and ultimate beneficial owners; providing only the name of the top-level holding company is insufficient. [1] [3] [6]

The capital arrangements should be supported by evidence of the source and availability of funds, including financial statements of the contributing entity, ownership structure, funds flow and existing financing obligations. If parent-company support is to be relied on, explain whether the commitment is binding and whether it can be delivered promptly under stress scenarios. An individual or company is not automatically fit and proper merely because it has no criminal record; regulatory sanctions, civil disputes, bankruptcy, financial integrity and past management conduct may also affect MAS’s assessment. [1] [6]

• Prepare a group structure chart that traces ownership to the ultimate controller and identifies direct and indirect voting rights, related parties and common ownership arrangements.
• Fully disclose all adverse background matters and provide factual explanations, evidence of remediation and their current status.

5. Directors, CEO, compliance and risk teams

Sections 57 and 75 of the SFA require an ACH and RCH to have adequate human resources and governance arrangements, and to appoint a suitable chairperson, CEO, directors and key management personnel. Staffing should cover clearing risk, collateral and funds management, day-to-day operations, technology security, legal compliance and internal audit. The verified materials do not support applying requirements such as “a fixed number of two responsible persons”, “the CEO must invariably have ten years of experience” or general CMS representative examination requirements. Numbers, independence and local-residency arrangements should be determined by reference to the facility type, current governance regulations and MAS’s individual conditions. [1] [3] [6]

The appointment of the chairperson, CEO and directors of an ACH requires prior MAS approval under section 71 of the SFA; a local RCH likewise requires prior approval under section 81AC. MAS may further specify that appointments to key management positions or committees require approval. Resignations or removals must be notified in writing as soon as possible. For ACH governance, refer to the 2024 Regulations on Corporate Governance for Approved Exchanges, Approved Clearing Houses, Licensed Trade Repositories and Approved Holding Companies; do not mechanically cite the superseded 2005 version. Having a local director for company registration does not, by itself, satisfy the facility governance requirements. [1] [7] [8]

ACH must also check the 2024 corporate governance regulations: as a general rule, at least one-third of the board must be Singapore citizens or permanent residents, and independent directors must constitute a majority. Nomination, remuneration, audit, conflicts of interest and risk management committees must be established. The nomination committee must comprise at least five directors, and prior approval for the relevant appointments must be obtained in accordance with sections 9 and 15. Sections 6(2) and 9(2) provide alternative independence rules where a single substantial shareholder holds at least 50% of the share capital or voting rights. Other applicable exceptions and the composition of each committee must also be checked. This paragraph concerns ACH and should not be applied mechanically to RCH; nor does it establish a uniform staffing structure for all clearing institutions. [7]

• Prepare for key personnel their CVs, specific clearing project experience, responsibilities, reporting lines, outside appointments and conflict-of-interest disclosures.
• It is advisable for compliance and risk control to have independent escalation channels, with clear arrangements for unattended duties, staff departures and replacements in a crisis. This is a preparation recommendation, not a uniform minimum staffing requirement.

6. Corporate entity, genuine address and operational readiness

A local applicant should first have the relevant Singapore legal entity status and appoint at least one director who meets the local residency requirement. A company secretary must be appointed within six months of incorporation, and the sole director cannot also be the secretary. ACRA requires the registered office address to be in Singapore, capable of receiving legal documents and open to the public as required, for at least three hours each business day. The registered office need not be the same as the actual place of business, but a registered agent’s address must not be equated with a clearing facility having a genuine operational team and systems. [8] [9]

Application materials should accurately distinguish the registered office, actual operating office, primary data centre, disaster recovery site and outsourcing locations, and provide evidence of rights of use, staff working arrangements and regulatory access. A foreign RCH should explain the location of its home-country headquarters and the facility’s actual location, and confirm with MAS whether any additional local contact or operating arrangements are required; it should not be assumed in every case that it must first establish a local subsidiary. The MAS address verified for this article is 10 Shenton Way, MAS Building, Singapore 079117. This is the regulator’s address, not the business address of an applicant or advisory firm, and does not mean that an application may be submitted in person without an appointment. [10]

• Keep evidence of the right to use the premises, leases or service agreements, and data centre, cloud service and disaster recovery contracts.
• Do not promote unverified Singapore offices, on-site staff or regulatory contact arrangements as having been established.

7. Base capital: scope of application of 10000000 and 5000000

Section 7 of the Clearing Regulations requires an ACH to demonstrate that it can maintain base capital of not less than 10000000SGD, and a local RCH to maintain not less than 5000000SGD. The statutory calculation of base capital includes paid-up ordinary share capital, qualifying irredeemable non-cumulative preference share capital, retained earnings or losses in the latest audited accounts, and reserves established solely for the clearing fund, less interim losses and dividends declared after the latest audited accounts. Accordingly, nominal registered capital, ordinary shareholder loans and margins paid by members cannot be treated as qualifying base capital without analysis. [2]

The 5000000SGD threshold for an overseas RCH cannot be assumed to apply directly based on the summary on the MAS application page: section 7 expressly limits this amount to Singapore-incorporated companies. An overseas institution must still demonstrate financial soundness, comply with its home-country resource regime and satisfy MAS recognition conditions. 唐上永（唐生）, Business Manager, explains: capital preparations should at a minimum be separately assessed for base capital, default resources for clearing, day-to-day liquidity and operating expenditure. This is a budgeting breakdown recommendation, not a regulatory formula under which all four amounts may be offset against one another. [1] [2] [3]

• Prepare a capital calculation working paper stating the account date, component items, losses, dividends and whether funds are restricted.
• Recalculate capital headroom under scenarios involving insufficient income or business expansion to avoid falling below requirements soon after approval.

8. ACH's current liquidity and solvency framework

ACH must not check only minimum base capital. MAS Notice SFA 02/02A/03-N01 also sets liquidity and solvency requirements, covering the calculation of liquid assets, eligible capital, liquidity resource requirements and total risk requirements. Amendments to the clearing regulations published in 2025-07 as S492/2025 take effect from 2025-10-01 and incorporate reporting and capital planning relating to this Notice into the regulations. Preparations in 2026 should not continue to describe these changes as unimplemented 2025 consultation proposals. [4] [5]

We obtained the MAS Notice explanatory page and current SSO provisions for this review, but not the full calculation text of all Notice appendices. Accordingly, we do not present the six-month operating expenditure formula, specific risk weights or warning ratios from the consultation stage as a complete statement of current calculation rules. Applicants should obtain the complete Notice in force at the relevant time and confirm which assets may be included, capital deductions, currency mismatches, liquidity stress tests and Notice trigger conditions. Whether an RCH is subject to specific equivalent or additional requirements should be confirmed against its recognition conditions; the Notice specifically directed at ACH should not be applied mechanically merely because of a similar name. [2] [4]

• Manage capital buffers separately from immediately available liquidity, and conduct stress calculations for each.
• The extent to which any group funding, credit facility or clearing fund may be counted should be confirmed item by item under the applicable rules.

9. Application forms and document checklist

The MAS application page specifies Form 1; section 6 of the clearing regulations further requires submission with Forms 2 and 3, relevant appendices and the information required. The forms and appendices for clearing facilities must be used; CMS or payment services application forms cannot be substituted. We recommend maintaining a version-controlled checklist that maps each response to the business plan, group chart, financial projections and rulebook. Preparation recommendations beyond the officially specified materials should be clearly distinguished from documents that are legally required. [2] [3]

A complete application package will generally require company incorporation documents and constitution, shareholder control chain, backgrounds of directors and management, home-country regulatory materials, business and financial projections, evidence of capital and source of funds, and participant agreements and business rules. At facility level, explain the risk model, collateral management, settlement banks, client assets, default management, recovery and exit arrangements, and attach system architecture, business continuity and outsourcing oversight materials. Whether an independent legal opinion, model validation and system testing reports are mandatory should be determined from the latest forms and MAS requests, rather than asserting that all applications require the same set of reports. [1] [3]

• The business plan should describe target products, participants, market demand, revenue sources, fees and capacity growth.
• Financial projections should reflect recruitment, technology, audit, annual regulatory fees, capital replenishment and stress scenarios on a consistent basis.
• Overseas applicants should prepare an explanation of home-country authorisation, supervisory scope and restrictions on cross-border information sharing.

10. Risk framework, rulebook and default management

Sections 57 and 75 of the SFA require a facility to operate safely and efficiently, with fair and objective admission criteria and business rules that support the facility's operations and member supervision. Application materials must not consist only of an abstract risk manual; they must explain how the specific clearing mechanism addresses participant default, concentration, mispricing and settlement failure. For a CCP, prepare explanations of margin and collateral rules, the default fund or other financial resources, the order of use, stress testing, model validation and default drills. Whether a particular international quantitative standard applies should be checked against the current MAS Notice and the actual product scope. [1] [3] [11]

For ACH, section 12 of the clearing regulations requires prior MAS approval for changes to the risk management framework, including collateral types, valuation methods, methods for determining margin and the size of financial resources supporting member defaults. Links or related collaborative arrangements with other clearing facilities, markets or trade repositories are also subject to prior notification and approval procedures. The project should include regulatory checkpoints in its contract and system change governance; it must not go live first and seek approval later. Nor should collaborations involving only joint marketing be treated in the same way as actual facility links without distinction. [2]

• The rulebook explains admission and exit, member oversight, defaults, disputes, fees and the clearing house’s discretion.
• Clearly specify the legal ownership of each category of risk resources, whether they can be deployed immediately, and the replenishment arrangements following deployment.

11. Systems, disaster recovery and outsourcing controls

Both ACHs and RCHs must have adequate system resources to deal with automated-system disruptions and other emergencies. Sections 16 and 38 of the Clearing Regulations respectively require a business continuity plan to be maintained and periodically reviewed and tested in accordance with that plan; sections 19 and 40 require reasonable protection of the integrity and security of user information in transit and in storage. The systems proposal should explain access permissions, change releases, transaction records, end-of-day reconciliations, monitoring, recovery capabilities, and the test results for peak capacity and abnormal scenarios. [1] [2]

Using cloud services or shared group technology does not transfer the clearing house’s regulatory responsibilities. Applicants should explain service-provider oversight, data locations, regulatory access to information, subcontracting, access by key personnel, disaster-recovery failover and exit alternatives. An ACH must notify MAS immediately when it activates its business continuity plan; both ACHs and RCHs are required to notify MAS immediately if the integrity or security of user information is compromised. Do not treat “having purchased cloud services” or “using blockchain” as proof of system security and continuity. [2]

• It is advisable to test scenarios involving a loss of connectivity, settlement-bank failure, cyberattack and a major member default occurring at the same time.
• Outsourcing contracts should support access to information, audits, recovery and orderly termination; confirm the specific terms against applicable regulatory requirements.

12. Application process, window and timetable

A practical preparation sequence is to first develop a description of the business and regulatory scope, confirm the classification and documentation arrangements with MAS, then complete the corporate entity, key personnel, capital, rules and systems proposal, submit a complete application and respond to queries, and finally complete pre-launch preparations in accordance with the approval conditions. The MAS application page publishes a non-refundable application fee of 4,000SGD and a Form 1 channel, and does not describe a uniform annual tender window for clearing facilities; the actual submission method, payment and pre-application engagement procedures should still be verified against MAS’s current instructions. [2] [3]

The approximately 9 months stated by MAS applies only to RCH applications that meet the admission criteria, involve a simple model and are complete and clear. Complex cross-border structures, inaccurate information, risk models requiring adjustment or key personnel not being in place will extend the review. This does not support a promise of approval within nine months, and the date of company registration must not be treated as the date on which clearing operations may commence. Where the same published standard timeframe is not available for an ACH, the project should be managed against preparation milestones rather than a pre-sold, guaranteed approval date. [3]

• Contracts should state that regulatory decisions, requests for further information and commencement conditions may change the plan, and should not promise approval or a fixed approval date.
• Maintain a record of MAS queries, including the question, person responsible, supporting evidence, response version and follow-up actions.

13. Approval boundaries for acquisitions, capital increases and changes of control

Share transactions involving an ACH should be handled under section 70 of the SFA: MAS approval must be obtained before entering into a share acquisition agreement that would result in the buyer becoming a substantial shareholder. Prior approval is also required to become a 12% or 20% controller. A substantial shareholding under section 2 of the SFA is generally assessed by reference to not less than 5% of the relevant voting rights, subject to the share-class and attribution-of-interest rules; this must not be simplified to “approval is required only above 10%”. Connected parties, indirect voting control and concert-party arrangements should also be considered; the review must not be limited to the buyer’s directly registered shareholding. [1]

For a local RCH, prior MAS approval is required to become a 20% controller under section 81AA of the SFA, and the chairperson, CEO and directors require prior approval under section 81AC. After becoming aware of an acquisition or disposal of a substantial shareholding, an RCH also has an obligation under section 34 of the Clearing Regulations to notify MAS as soon as practicable; this is a separate procedure from approval for a local RCH 20% controller. An offshore RCH should check the home-country shareholding approval requirements and MAS recognition conditions; the local thresholds must not be applied automatically. Acquisition due diligence should also check capital shortfalls, unresolved regulatory issues, default resources, client assets, member agreements, systems licences and historical obligations; “buying a licence” does not mean that eligibility can be transferred separately from the corporate entity. [1] [2]

• For an ACH, first obtain legal advice on whether section 70 restricts signing the agreement; it should not be assumed that making completion conditional on approval in the contract is sufficient.
• Check whether capital increases, convertible instruments, voting agreements and group reorganisations trigger control thresholds.
• After obtaining the required MAS approval, ACRA information must still be updated in accordance with company law procedures; the two do not substitute for each other.

14. Material-event notifications and clearing-interruption timeframes

Sections 58 and 76 of the SFA require ACHs and RCHs to report, as soon as practicable, material changes to application information and matters that may affect the performance of financial obligations. Section 11 of the current Clearing Regulations distinguishes between levels of interruption for an ACH: a clearing or settlement interruption that has a severe and widespread operational impact, or materially affects services to participants, must be notified within 1 hour after discovery; other interruptions of that kind must be notified within 1 day after discovery. Reports on specified incidents and adverse developments, covering the circumstances, immediate remediation and follow-up measures, must also be submitted within 14 days after their occurrence, unless MAS permits an extension. [1] [2]

An ACH that proposes to enter into a loan arrangement within the prescribed scope as borrower, guarantor or provider of security will generally need to give at least 14 days’ prior notice. Exclusions, including ordinary credit facilities for liquidity management, and circumstances in which MAS permits a shorter period should be checked individually. Section 34 for an RCH covers material litigation, other regulatory sanctions, the admission or withdrawal of a settlement bank, settlement failures, substantial shareholding changes and other material adverse developments; the ACH’s 1 hour or 1 day rules must not automatically be stated as uniform statutory timeframes for all RCHs. An RCH must still check its recognition conditions, technical notification requirements and MAS’s written requirements. [2]

• The incident-response process should specify the time of discovery, impact rating, person responsible for the initial report, MAS contact channel and arrangements for supplementary reports.
• Notifications concerning a proposed declaration of member default or commencement of default procedures must be handled under the respective provisions; do not wait until the annual report to disclose them.

15. Periodic reporting, capital plans and audit maintenance

Section 14 of the clearing regulations requires ACH to submit an annual report, directors’ report, auditors’ long form report and report on the discharge of its duties within three months after the end of the financial year; the corresponding profit and loss statements and balance sheets must be submitted within forty-five days after the end of each of the first three quarters. The newly introduced liquidity and solvency reports are generally due within thirty days after the end of each of the first three quarters and within sixty days after the end of the final quarter; the capital plan is generally due within thirty days after the start of each financial year. Deadlines may be extended with MAS approval under the relevant provisions. Different reports should not be combined into a single “annual filing” date. [2] [5]

Under section 36 of the Clearing Regulations, an RCH generally submits its annual report within 3 months after the end of the financial year and must submit any other reports required by MAS. Under section 73 of the SFA, an ACH must appoint an auditor annually and obtain MAS approval; corresponding procedures apply to a change of auditor. Section 73A requires an auditor who discovers a specified material irregularity to report it to MAS immediately in writing. The small-company audit exemption under the Companies Act does not directly displace the specific audit obligations of an ACH. The maintenance budget should include audit, rule updates, risk validation, system exercises and regulatory annual fees. Annual fees are set out in the Second Schedule to the Clearing Regulations and must not be conflated with the 4,000SGD application fee. [1] [2] [3]

• Establish a regulatory calendar driven by the financial year and quarters, distinguishing the MAS, ACRA and IRAS filing streams.
• Annual fees depend on the ACH product category and business volume, and separate arrangements apply to RCHs; obtain the complete fee schedule and calculate costs before submitting the budget.

16. Member client funds, asset segregation and information protection

The Clearing Regulations contain rules on client funds and assets for ACHs and qualifying local RCHs. Applicability depends on whether the facility holds funds or assets paid by a member under contracts with its clients in the course of clearing or settlement activities. Identify members’ proprietary positions separately from client positions, and, under the applicable rules, place client money in trust accounts and assets in custody accounts, distinguishing them from the facility’s and members’ own assets. Client money is not general operating capital of the clearing house, and statutory restrictions on its use cannot be disregarded merely because it constitutes margin. [1] [2]

For specified transactions, members must also inform clients that they may elect to have their funds or assets in accounts kept separately from those of other clients. Account segregation, account structures and restrictions on the use of assets in the event of default should be reflected consistently in the rules, agreements and systems. The client-asset arrangements of an offshore RCH must not be directly subject to the division of the Regulations that applies only to Singapore-incorporated companies; they must be considered in light of home-country law and recognition conditions. Sections 64 and 81 of the SFA require user information to be kept confidential. Disclosures to outsourcing providers or professional advisers must satisfy the permitted conditions and be limited to what is necessary; confidentiality obligations must not be used as a reason to refuse lawful regulatory access to information. [1] [2]

• Before account opening and member onboarding, confirm account identifiers, authorisations, reconciliations, permitted investment purposes and the ability to transfer assets.
• Model client assets separately from member-default handling, and specify which assets may not be used across clients or across members.

17. Ongoing ACRA and IRAS compliance

While the company remains in existence, MAS status does not exempt it from ACRA maintenance requirements. ACRA’s official guidance requires company information, directors and other officers, share transfers and relevant shareholder information to be updated within 14 days as required. Annual returns for local unlisted companies are generally due within 7 months after the end of the financial year; different timeframes apply in specific circumstances, such as where the register of members includes overseas branches. Applicable registers of controllers and nominee arrangements should also be maintained, but any statutory exemptions must be confirmed; it must not be stated categorically that all licensed institutions are exempt from registration. [9] [12] [13]

IRAS publishes the general corporate income tax rate as 17% of chargeable income, not 17% of turnover, and not as a guaranteed concession for a licensed clearing house. Estimated Chargeable Income (ECI) is generally due within 3 months after the end of the financial year, except where the relevant exemption conditions or other conditions apply; Form C-S, C-S Lite or Form C is generally due each year on November 30. Tax records generally must be kept for at least 5 years from the relevant Year of Assessment; this tax record-retention period does not replace all record-retention requirements for clearing transactions or regulatory records. Cross-border expenses, related-party transactions and tax residency should be assessed separately based on the actual circumstances. [14]

• ACRA annual returns and IRAS tax filings are separate obligations; filing with one agency does not discharge the obligation to the other.
• Coordinate company changes, tax filings and prior MAS approvals to avoid completing a company registration change only to discover that it is not permitted by the regulator.

18. Do not extend clearing eligibility to other financial licences

The MAS application page makes clear that an ACH or RCH proposing to conduct other SFA-regulated activities should contact its regulatory liaison and assess whether an additional licence or an applicable exemption is required. Operating a market, dealing in securities, fund management, payment services or deposit-taking cannot be undertaken solely by virtue of clearing status. The former RFMC regime for fund management was abolished on 2024-08-01 and must not continue to be promoted as a currently available light-touch registration route. The application window for the 2019 round of digital bank licences closed on 2019-12-31; as at the date of this search, no new public announcement of an open window was found. The old announcement must not be presented as a window open in 2026; whether new arrangements exist should be confirmed with MAS at the relevant time. [3] [15] [16]

Where tokenisation activities also involve a DTSP, note that MAS stated clearly on 2025-06-06 that, with effect from 2025-06-30, only persons covered by the regime that provide the relevant digital payment token or capital markets product token services solely to customers outside Singapore require a licence, but MAS has set a high bar and will generally not issue licences. Offshore RCH recognition, serving overseas customers only or using offshore servers must not be treated as a way to circumvent this strict policy. The specific activities must still be assessed separately under the FSMA, SFA and payment regulations; this article does not provide a complete application guide for digital banking, fund management or DTSPs. [17]

• Prepare a licence and exemption matrix for each actual activity to avoid vague claims of a “one-stop financial licence”.

19. Orderly exit, professional explanation and information-use disclaimer

ACH/RCH status does not require periodic renewal, but that does not mean it is unconditionally permanent; cancellation, revocation and ongoing compliance with approval conditions are governed by the SFA. Where an operator proposes to cease its last facility, section 10 of the Clearing Regulations generally requires an application for cancellation to be made no later than 3 months before the proposed cessation date. Arrangements should first be made for outstanding positions, client assets, member notifications, settlement obligations, record retention and service migration; the company must not be struck off before the interests of clearing participants have been addressed. An ACH must also maintain recovery and orderly wind-down plans on an ongoing basis, rather than preparing them only when losses arise. [1] [2] [3]

Prepared and attributed by: 仁港永胜（香港）有限公司; professionally explained by 唐上永（唐生), Business Manager. Effective approaches in the user’s own guide concerning business positioning, document consistency, localised governance, capital planning and ongoing maintenance have been reorganised in light of clearing facility rules. The guide’s general CMS personnel, capital and AML notices have not been presented as requirements specific to clearing houses, and unverified claims about success rates, resource networks and licensing track records have not been retained. Legal and regulatory facts are attributed to the official sources below; the analysis of external organisations or authors is not misrepresented as original legal advice from the company. [18]

This document was checked on 2026-11-04 and is intended for preliminary project assessment and preparation. It does not replace a decision by MAS, advice from a Singapore-qualified lawyer or the latest complete notices. Where historical MAS PDF links and some SSO Schedule extracts were incomplete, the material was cross-checked against readable current SSO provisions and official explanations. No numerical commitments are made for capital-notice formulas, governance details or fee calculations that have not been fully verified. Before formal submission, signing an acquisition agreement or expanding the business, the regulations, forms, approval conditions and written regulatory requirements in force at that time should be reconfirmed.

• Advisers may assist with classification, coordinating materials, rules and compliance arrangements, but cannot replace MAS approval or guarantee that a licence will be granted.

Frequently Asked Questions

Sources and usage notes

1. [1] Singapore Statutes Online: Securities and Futures Act 2001, current Part 3 and Section 2(opens in a new window)https://sso.agc.gov.sg/Act/SFA2001?ProvIds=P13-
2. [2] Singapore Statutes Online: Securities and Futures (Clearing Facilities) Regulations 2013, current capital, approval and ongoing obligations(opens in a new window)https://sso.agc.gov.sg/SL/SFA2001-S464-2013
3. [3] MAS: Application for an Approved Clearing House or Recognised Clearing House; capital, fees and processing time(opens in a new window)https://www.mas.gov.sg/regulation/capital-markets/apply-for-licensing-or-registration-of-capital-market-entities/copy-of-approved-clearing-house-ach-or-recognised-clearing-house-rch-licence
4. [4] MAS: Notice SFA 02/02A/03-N01, explanatory page on capital and liquidity requirements for ACHs and other institutions(opens in a new window)https://www.mas.gov.sg/regulation/notices/notice-sfa-02-02a-03-n01
5. [5] Singapore Statutes Online: Clearing Facilities Amendment No. 2 Regulations 2025, effective from 2025-10-01(opens in a new window)https://sso.agc.gov.sg/SL-Supp/S492-2025/Published/20250716
6. [6] MAS：Guidelines on Fit and Proper Criteria，FSG-G01(opens in a new window)https://www.mas.gov.sg/regulation/guidelines/guidelines-on-fit-and-proper-criteria
7. [7] Singapore Statutes Online: Corporate Governance Regulations 2024 for clearing facilities and other institutions; obtain the complete version to verify the specific governance provisions(opens in a new window)https://sso.agc.gov.sg/SL/SFA2001-S355-2024?ViewType=Print
8. [8] ACRA：Choosing company directors and other key officers(opens in a new window)https://www.acra.gov.sg/register/business/registering-different-business-structures/local-company/appointing-company-directors-other-key-officers/
9. [9] ACRA: Registering a local company via Bizfile and registered office address requirements(opens in a new window)https://www.acra.gov.sg/register/business/registering-different-business-structures/local-company/registering-via-bizfile/
10. [10] MAS: Contact Us and Singapore office address(opens in a new window)https://www.mas.gov.sg/contact-us
11. [11] MAS: Notice SFA 02A/03-N01 Financial Market Infrastructure Standards; confirm the applicable standards against the complete notice(opens in a new window)https://www.mas.gov.sg/regulation/notices/notice-sfa-02a03-n01
12. [12] ACRA：Updating company information, officers and shareholders(opens in a new window)https://www.acra.gov.sg/manage/companies/legal-requirements-common-offences/maintaining-local-companys-information-registers/updating-company-information-officers-shareholders/
13. [13] ACRA：Deadline and requirements for annual returns(opens in a new window)https://www.acra.gov.sg/manage/companies/legal-requirements-common-offences/filing-annual-returns-companies/deadline-requirements/
14. [14] IRAS：Basic Guide to Corporate Income Tax for Companies(opens in a new window)https://www.iras.gov.sg/taxes/corporate-income-tax/basics-of-corporate-income-tax/basic-guide-to-corporate-income-tax-for-companies
15. [15] MAS: 2024 enforcement announcement confirming that the RFMC regime was abolished on 2024-08-01(opens in a new window)https://www.mas.gov.sg/regulation/enforcement/enforcement-actions/2024/mas-takes-enforcement-actions-against-cciam-and-its-former-ceo-for-breaches-of-the-sfr
16. [16] MAS: Receives 21 Applications for Digital Bank Licences, the previous application window closed on 2019-12-31; this is not an announcement of a new 2026 application window(opens in a new window)https://www.mas.gov.sg/news/media-releases/2020/mas-receives-21-applications-for-digital-bank-licences
17. [17] MAS: Clarifies Regulatory Regime for Digital Token Service Providers, 2025-06-06(opens in a new window)https://www.mas.gov.sg/news/media-releases/2025/mas-clarifies-regulatory-regime-for-digital-token-service-providers
18. [18] User’s own materials: 仁港永胜 Singapore MAS Guide; used only for business organisation and attribution, and not as a substitute for official legal sources(opens in a new window)https://www.jrp-hk.com/html/sg_mas_guide_final.html
19. Supplementary: MAS Guidelines on the Regulation of Clearing Facilities explanatory page; the historical PDF could not be fully accessed for this review(opens in a new window)https://www.mas.gov.sg/regulation/guidelines/guidelines-on-regulation-of-clearing-facilities
20. Supplementary: Part II of the current Clearing Regulations, sections 6 to 10(opens in a new window)https://sso.agc.gov.sg/SL/SFA2001-S464-2013?ProvIds=P1II-
21. Supplementary: Part III of the current Clearing Regulations, ACH notices, reporting and customer assets(opens in a new window)https://sso.agc.gov.sg/SL/SFA2001-S464-2013?ProvIds=P1III-
22. Supplementary: Part IV of the current Clearing Regulations, RCH notices, reporting and local customer assets(opens in a new window)https://sso.agc.gov.sg/SL/SFA2001-S464-2013?ProvIds=P1IV-