Jurisdiction guide·Policy
Singapore, Dubai and Switzerland: three models of regulated digital-asset activity
A licensing map is not a league table. The useful comparison is entity, activity and instrument—not which city is 'pro-crypto'.
Published 21 Jul 2026/Updated 8 Aug 2026/12 min/Global
Institutional tokenisation programmes often collect city names as if they were product features. Singapore, Dubai and Switzerland are not interchangeable backdrops. They encode different answers to the same four questions: which legal person is in scope, which activity is licensed, which instrument characterisation applies, and what public register exists to evidence the result.
Singapore — activity inside payments and capital markets
MAS treats digital payment tokens as a payments perimeter under the Payment Services Act, with a separate, well-developed capital-markets regime when the instrument is a capital-markets product. The public evidence is licence type, exemption, and (where relevant) prospectus or authorised-scheme documents. A DPT licence does not make a tokenised bond a payment token.
Dubai — three perimeters, one city-state
Mainland Dubai (VARA), ADGM (FSRA) and DIFC (DFSA) are distinct legal and supervisory systems. VARA is a virtual-asset regulator with activity-based licences. ADGM's FSRA built an earlier virtual-asset framework inside a financial-centre model. DFSA distinguishes Investment Tokens from Crypto Tokens. Marketing that says 'Dubai regulated' without naming the authority is incomplete on its face.
Switzerland — DLT as market infrastructure
The DLT Act's ledger-based securities and DLT trading-facility licence are the distinctive Swiss contribution: they treat tokenisation as a securities-law and market-infrastructure problem, not only a payments problem. FINMA guidance still requires a case-by-case characterisation (payment, utility, asset token). A Zug foundation plus a token is not, without more, a DLT trading facility.
What this proves
These jurisdictions publish identifiable licensing perimeters and, in varying degrees, public registers or licence lists that can be cited as Tier 1 evidence of entity status.
What it does not prove
That one model is 'more regulated', or that a licence in one perimeter passports the instrument into the others.
RCA publishes source-linked intelligence for professionals. Nothing here is a token-buying call, a legal opinion, or an “approved / safe / regulated” badge. Every material claim is dated. Incomplete files stay incomplete.