How Does Singapore Regulate Tokenised Funds?
Singapore regulates tokenised funds through existing law rather than a bespoke regime: a tokenised fund unit generally represents a unit in a collective investment scheme, so offerings of and dealings in it follow the usual CIS requirements under the Securities and Futures Act. Having settled the classification question by not treating it as a question, the Monetary Authority of Singapore directed its effort at the operational layer through Project Guardian — an international collaboration of industry and regulators that published the Guardian Fixed Income Framework and the Guardian Funds Framework in November 2024, followed by an Operational Guide for tokenised funds in November 2025 covering governance, NAV calculation, investor onboarding and compliance. Alongside these sit two infrastructure initiatives, Global Layer One and BLOOM. This guide covers what each addresses and what the model implies for issuers elsewhere.
TL;DR — Key Takeaways
- ✓The Legal Answer: A tokenised fund unit is a CIS unit. Offerings and dealings follow the usual Securities and Futures Act requirements — no bespoke regime was needed.
- ✓Where the Effort Went: Into operations. The Guardian Fixed Income Framework and Guardian Funds Framework (November 2024), then an Operational Guide for tokenised funds (November 2025).
- ✓The Taxonomy: The Guardian Composable Token Taxonomy is designed to enable vehicles holding multiple assets and to improve fund settlement efficiency.
- ✓The Infrastructure Layer: Global Layer One for shared settlement rules, data formats and programmable compliance templates; BLOOM for real-time cross-border settlement finality.
- ✓The Transferable Lesson: Classification is settled in every major jurisdiction. What determines whether a tokenised fund works is governance, NAV, onboarding and settlement.
The Question Singapore Declined to Ask
A tokenised fund unit in Singapore generally represents a unit in a collective investment scheme, which means offerings of and dealings in tokenised fund units follow the usual CIS requirements under the Securities and Futures Act. No new category was created, and no bespoke regime was drafted.
That decision looks obvious in retrospect and was not obvious at the time. Several jurisdictions spent years treating the classification of tokenised instruments as an open question requiring novel analysis. Singapore treated it as answered by the instrument's substance — a fund unit confers the rights a fund unit confers, and the medium recording it does not alter them — and redirected the effort to the questions that were genuinely unresolved.
A tokenised fund unit would generally represent a unit in a collective investment scheme, and “there is regulatory certainty that offerings of and dealings in tokenised fund units should follow the usual requirements applicable to CIS under the Securities and Futures Act.”
— Analysis of MAS's treatment of tokenised fund units under Singapore law
“Regulatory certainty” obtained by applying existing law is the cheapest form of certainty available, and it arrives immediately rather than after a legislative cycle. The US reached the same principle through staff statements and a joint interpretation; the delay was in getting there, not in the conclusion.
What Project Guardian Produced
Project Guardian is an international collaboration of industry and regulators led by MAS, and it produces frameworks rather than rules. Two were published in November 2024 — one for debt capital markets, one for funds — followed by an operational guide in November 2025 that addresses how a tokenised fund is actually run day to day.
| Output | When | What it addresses |
|---|---|---|
| Guardian Fixed Income Framework | November 2024 | An industry guide to implementing tokenisation in debt capital markets |
| Guardian Funds Framework | November 2024 | Best practices for tokenised funds, including the Guardian Composable Token Taxonomy |
| Operational Guide for tokenised funds | November 2025 | Governance, NAV calculation, investor onboarding and compliance |
| Global Layer One (GL1) | Launched 2024 | Shared infrastructure standards: settlement rules, data formats, cross-network connectivity, programmable compliance templates |
| BLOOM | October 2025 | Real-time cross-border settlement and the settlement-asset layer needed for finality |
Key Insight
The sequencing is the instructive part. Frameworks came first, an operational guide a year later, and settlement infrastructure alongside — which is the reverse of how tokenisation programmes usually proceed. Most start from a chain and a token standard and discover the governance, NAV and onboarding questions during implementation. Starting from what a fund manager, custodian and administrator each need to do, and only then asking what infrastructure supports it, produces a different and more usable set of answers. The technology choice is downstream of the operating model, not the other way round.
The Composable Token Taxonomy and Why It Exists
The Guardian Composable Token Taxonomy is designed to enable investment vehicles holding multiple assets and to improve fund settlement efficiency. Its premise is that a fund is not a single homogeneous claim but a structure holding a portfolio, and that tokenisation should represent that structure rather than flatten it.
The practical problem it addresses appears the moment a tokenised fund holds anything interesting. A money market fund holding short-dated instruments, a multi-asset vehicle, a fund holding other funds — each needs its composition to be representable, because settlement, valuation and redemption all depend on what is actually inside. A taxonomy that treats every token as an opaque unit forces that information back into off-chain systems, which is where reconciliation problems originate.
Multi-asset vehicles
A vehicle holding several assets needs its composition represented rather than summarised, so that a holder's claim on the underlying can be resolved without consulting a separate system.
Settlement efficiency
Where composition is representable, settlement can operate on components rather than requiring full redemption and re-subscription — the same efficiency argument that drives tokenised collateral.
Fund-of-fund structures
A tokenised fund holding another tokenised instrument creates a dependency chain. A composable taxonomy makes that chain expressible instead of leaving it as an undisclosed operational fact.
The third item connects to a live risk in the US market, where tokenised funds holding other tokenised funds create operational dependencies invisible in the position — examined in what happens when tokenized treasuries become DeFi collateral. A taxonomy that can express composition is a partial answer to a problem that market is currently discovering the hard way.
Three Jurisdictions, One Conclusion, Different Routes
Singapore, the US and the EU have converged on the same principle — tokenisation does not change what an instrument is — while arriving by materially different paths. For an issuer operating across them, the convergence is more useful than the differences, because it means one classification analysis holds in all three.
| Jurisdiction | Route to the conclusion | What was added |
|---|---|---|
| Singapore | Existing CIS law under the Securities and Futures Act applies as-is | Industry frameworks, an operational guide, and settlement infrastructure |
| United States | SEC staff statement (January 2026) and joint SEC-CFTC interpretation (March 2026) | A five-category taxonomy and structural models for tokenized securities |
| European Union | MiCA's perimeter plus the DLT Pilot Regime for financial instruments | A sandbox regime and national approvals such as the Irish UCITS case |
The EU row has a live illustration: the Central Bank of Ireland approved a tokenised UCITS money market fund share class in July 2026 under existing fund law, with the tokenisation confined to the record-keeping layer. That structure is examined in how a regulated UCITS fund tokenizes on a public chain, and it demonstrates the same principle Singapore stated in the abstract.
What an Issuer Should Take From This
The transferable lesson is a reallocation of attention. Legal classification of tokenised fund units is settled in every major jurisdiction that has addressed it, so effort spent seeking further clarity there has low returns. The unresolved questions — governance, NAV calculation, onboarding, settlement finality, compliance mechanics — are the ones MAS built frameworks around, and they are where a programme succeeds or fails.
Settled — stop waiting
- A tokenised fund unit is a fund unit
- Existing fund law applies to offerings and dealings
- Recording technology does not change classification
- The same holds in the US, EU and Singapore
Unsettled — build here
- Governance and who can act on the fund
- NAV calculation and its on-chain expression
- Investor onboarding and eligibility enforcement
- Settlement finality across two records
Caveats
- Frameworks are industry guidance, not binding rules
- Licensing and marketing rules still differ by jurisdiction
- CIS treatment does not resolve custody questions
- Cross-border distribution remains its own analysis
The first caveat is worth stating plainly. A Guardian framework is not law, and complying with it does not discharge a regulatory obligation. Its value is different and still substantial: it represents what a broad group of institutions and their regulator concluded good practice looks like, which is the nearest thing to a market standard available while formal rules stay silent on operational detail.
How Blockmaze Maps to the Operational Layer
The areas the Guardian operational guide covers — governance, NAV, onboarding, compliance — are precisely the areas where a fund's on-chain representation either supports the operating model or fights it. That is a protocol-layer concern rather than a token standard concern.
Eligibility Enforced at Onboarding and Transfer
Investor eligibility is evaluated at the protocol level, so CIS distribution restrictions hold as a property of the instrument rather than as a control in a distributor's system.
Composition Declared
Where a vehicle holds multiple assets or another tokenised instrument, the composition is recorded against it — the problem the Guardian Composable Token Taxonomy exists to address.
Governance Powers Explicit
Who may act on the instrument, and under what authority, is declared rather than latent in contract code, which is what a fund governance framework requires to be auditable.
Jurisdictional Rule Sets
Distribution and eligibility rules differ by jurisdiction even where classification agrees, so rules are held per jurisdiction rather than as a single global policy.
The last point is the one that survives the convergence. Three jurisdictions agreeing that a tokenised fund unit is a fund unit does not mean they agree on who may be sold one, and a programme distributing across all three needs those differences enforced rather than documented — the problem set out in navigating cross-border RWA regulatory challenges.
Building a Tokenised Fund Across Jurisdictions?
Blockmaze provides the compliance layer that enforces investor eligibility per jurisdiction, declares vehicle composition and governance powers, and keeps the operating model auditable.
Frequently Asked Questions
What is Project Guardian?
An international collaboration of industry participants and regulators, led by the Monetary Authority of Singapore, exploring the use of fund and asset tokenisation. It operates through industry groups that produce frameworks rather than through rulemaking, which is the distinguishing feature of Singapore's approach. Rather than drafting a bespoke regulatory regime for tokenised instruments, MAS convened market participants to work out the operational and technical questions, while treating the legal classification of the instruments as already settled under existing law.
How are tokenised fund units regulated in Singapore?
As collective investment schemes. A tokenised fund unit would generally represent a unit in a collective investment scheme, so there is regulatory certainty that offerings of and dealings in tokenised fund units follow the usual requirements applicable to a CIS under the Securities and Futures Act. This is the same principle US and EU regulators reached independently: the recording technology does not change the legal character of the instrument. A fund unit is a fund unit whether it sits in a register or on a ledger.
What are the Guardian frameworks?
Two industry frameworks published in November 2024. The Guardian Fixed Income Framework provides an industry guide to implementing tokenisation in debt capital markets. The Guardian Funds Framework delivers recommendations for tokenised fund best practices, including the Guardian Composable Token Taxonomy, which is designed to enable investment vehicles holding multiple assets and to improve fund settlement efficiency. MAS followed these with an Operational Guide for tokenised funds in November 2025, covering governance, NAV calculation, investor onboarding and compliance.
What are Global Layer One and BLOOM?
Infrastructure initiatives addressing the layers beneath individual tokenisation projects. Global Layer One, launched in 2024, explores shared infrastructure standards for tokenised assets at scale — common settlement rules, data formats, cross-network connectivity, control principles alignment, market infrastructure specifications and programmable compliance templates. BLOOM, launched in October 2025, extends settlement capability to real-time cross-border settlement for tokenised assets, developing the settlement-asset layer that tokenised assets need to be exchanged safely and with finality.
How does the Singapore approach differ from the US and EU?
In where the effort went, not in the legal conclusion. All three arrived at the same classification principle — tokenisation does not change what an instrument is. The US did so through SEC staff statements and a joint SEC-CFTC interpretation; the EU through MiCA's perimeter and the DLT Pilot Regime; Singapore by treating the Securities and Futures Act as already sufficient. What Singapore added is the operational layer: frameworks, taxonomies and an operational guide that address how tokenised funds actually run, which is the part legal classification leaves open.
What should an issuer take from the Singapore model?
That the binding constraints on a tokenised fund are operational rather than classificatory. Once it is settled that a tokenised fund unit is a CIS unit — which it is, in every major jurisdiction that has addressed it — the remaining work is governance, NAV calculation, onboarding, settlement and compliance mechanics. MAS structured its programme around exactly that observation. An issuer waiting for legal clarity before building is waiting for something that has already arrived, while the questions that actually determine whether a fund works remain unaddressed.
Related Articles
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How Does the UK Regulate Tokenized Funds?
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Tokenized Fund Structures: A Layer-0 RWA Guide
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