Singapore Regulatory Updates

Key dates

2025-12-30

MAS issued the revised Notices FAA-N27, 508 and SFA 04-N24 and published its response to feedback.

2026-08-24

MAS published the circular and FAQs explaining the revised misconduct-reporting requirements and the discontinuation of the existing system.

2027-01-01 Deadline

The revised Notices FAA-N27, 508 and SFA 04-N24 take effect; the existing Notices FAA-N14, 504 and SFA 04-N11 are cancelled; and the existing misconduct reporting system is discontinued.

2027-01-22 Deadline

Default deadline for reporting qualifying pre-2027 misconduct matters that were not reported under the cancelled Notice, calculated as 21 calendar days after 1 January 2027, unless MAS permits a longer period in writing.

Suggested considerations

• Compliance teams may wish to map existing misconduct, incident, whistleblowing, investigation, HR and police-referral processes to the revised definition and categories of reportable misconduct.
• Firms should consider establishing a documented escalation test for when reasonable grounds to believe misconduct occurred arise, rather than waiting for a final investigation finding, and configuring workflow controls around the 21-calendar-day initial-reporting deadline.
• Firms may wish to obtain and operationalise the prescribed misconduct-report, investigation-report and update-report formats before the existing system is discontinued.
• Internal investigation procedures should be reviewed to ensure that the prescribed investigation information, supporting evidence, investigator assessment, corrective action and appeal information can be produced concurrently with the initial MAS report where an investigation has commenced.
• Police-report handling should be updated so that available police reports and required accompanying details are captured and submitted with the misconduct report, with subsequent police or criminal-proceeding developments tracked for update reporting.
• Firms should consider controls for providing representatives with copies of initial misconduct reports and subsequent updates within the prescribed timelines, including appropriate treatment of former representatives and confidentiality or privilege issues.
• A transitional review of open matters may be appropriate to identify cases where reasonable grounds arose before 1 January 2027 but no report was filed under the cancelled Notice; those matters may need to be reported by 22 January 2027, subject to any written extension from MAS.
• Record-retention policies, case-management systems and management information should be tested against the minimum five-year retention requirement and the requirement that electronic records remain accessible, retrievable and readable.

What changed

From 1 January 2027, Notices FAA-N27, 508 and SFA 04-N24 replace and cancel the existing Notices FAA-N14, 504 and SFA 04-N11. The initial misconduct report must generally be submitted within 21 calendar days after the firm has reasonable grounds to believe that reportable misconduct was committed or is likely to have been committed; a conclusive investigation finding is not required before reporting.

Key dates

2026-08-19

MAS published the announcement of the proposed tax exemption, Hedge Fund Investment Programme and Investment Management Track.

2027-01-01

The proposed tax exemption is expected to apply from Year of Assessment 2027; the precise income-period mechanics and legislative commencement remain to be confirmed.

Suggested considerations

• Firms should inventory existing carried-interest, performance-fee, incentive-allocation and other profit-participation arrangements and identify whether returns are received directly or indirectly for fund-management services.
• Tax and legal teams may wish to map each relevant fund against Sections 13D, 13O, 13OA, 13U and 13V of the Income Tax Act 1947 and retain evidence of Singapore-based management and applicable economic-substance conditions.
• Firms should avoid treating the announcement as an immediately available exemption and should monitor Budget 2027 and subsequent legislation or administrative guidance for the effective scope, rate, thresholds, attribution rules and documentation requirements.
• Compliance teams may wish to review fund, management-company, partnership and individual remuneration agreements so that the commercial basis for any profit-related return is clearly documented and distinguishable from ordinary salary or bonus remuneration.
• Asset managers considering Singapore expansion should assess whether participation in the Hedge Fund Investment Programme or the proposed Investment Management Track could support their business and talent strategy, while awaiting eligibility and application details.
• Immigration and HR teams may wish to identify senior investment professionals whose compensation is materially linked to investment performance and assess the potential implications once revised ONE Pass criteria are published.
• Firms should continue applying existing tax, licensing, employment, payroll, conduct, books-and-records and anti-avoidance requirements; this announcement does not displace those obligations.

What changed

MAS and the Ministry of Finance plan to introduce a tax exemption from Year of Assessment 2027 for qualifying profit-related returns arising from fund-management services. The exemption is intended to cover a contractual share of profits of funds qualifying under Sections 13D, 13O, 13OA, 13U or 13V of the Income Tax Act 1947, where the funds are managed by Singapore-based fund managers and the returns are received directly or indirectly by corporate entities, partnerships or individuals for providing fund-management services.

Key dates

23 August 2018

– Initial version of CMI 27/2018 “Controls and Disclosures to be Implemented by Licensed Securities-Based Crowdfunding Operators” published by MAS

08 October 2018

– MAS publishes FAQs on Lending-based Crowdfunding, clarifying licensing and prospectus requirements and interacting with SCF-related guidance

05 March 2021

– Updated version of CMI 27/2018 and Annex A / A1 / A2 for issuer default notification uploaded, refining default reporting and controls expected of SCF operators

21 January 2025

– Revision of Guidelines on Criteria for the Grant of a Capital Markets Services Licence (SFA 04-G01), which interact with licensing expectations for SCF operators

14 July 2026

– Last revised date of circular CMI 27/2018, signalling the most recent MAS expectations on controls and disclosures for licensed SCF operators

Suggested considerations

• Review existing issuer due diligence policies and procedures and update them to align with MAS’s expectations on structured checks, documentation, and investor disclosure of due diligence scope for all SCF offers.
• Implement a formal policy prohibiting the use of new loans to repay existing overdue loans, except where legitimate reasons exist; define those reasons, approval thresholds and documentation requirements for exceptions.
• Enhance lending workflows to ensure that, when new loans are extended to borrowers with outstanding loans, the platform system automatically collates and presents total outstanding exposure and the rationale for the new loan to investors in pre-investment disclosures.
• Develop and approve a detailed issuer default management framework that defines escalation triggers, recovery options, decision criteria, investor communication templates, and record-keeping requirements.
• Update investor terms and conditions and consent mechanisms so that investors explicitly agree to any potential recovery-related costs, with clear fee schedules and scenarios disclosed before costs are incurred.

What changed

• - Licensed SCF operators must implement structured due diligence checks on issuers, including clear policies on information to be obtained, risk assessment criteria and documentation standards, and...
• Lending-based SCF operators are generally prohibited from allowing a borrower to take up a new loan to repay an existing overdue loan, unless there are legitimate, documented reasons to extend a new...
• Where a lending-based SCF operator does extend a new loan to a borrower with outstanding loans, it must disclose the borrower’s total outstanding loans and the reasons for extending the new loan so...
• SCF operators must establish formal policies and procedures for issuer default management, documenting circumstances under which the operator will pursue various recovery options (e.g.
• Operators must disclose to investors the different recovery options and associated costs and must seek and obtain investors’ consent before incurring any recovery-related costs that will be borne by...

Key dates

07 July 2026

- MAS publishes Circular ID 08/26 and Consultation Paper P013-2026 on the Proposed Framework for Protected Cell Companies in Singapore, opening the consultation

07 August 2026

- Closing date for submissions to MAS on the PCC consultation paper

Suggested considerations

• Review the MAS Consultation Paper P013-2026 in detail and map proposed PCC requirements against your current and planned captive, reinsurance, ILS and sovereign risk pool structures.
• Conduct an internal impact assessment on how PCC introduction would affect corporate structuring, capital allocation, risk management, and policyholder/investor protections within your group.
• Identify potential use cases for PCCs (e.g. multi‑cell captives, collateralised reinsurance platforms, ILS issuance vehicles, sovereign risk pools) and assess legal, tax, accounting and regulatory implications for each use case.
• Engage legal, compliance, actuarial and treasury functions to develop a coordinated response to MAS addressing prudential treatment, segregation mechanics, governance expectations and disclosure considerations for PCCs.
• Prepare and submit detailed consultation feedback to MAS by 07 August 2026, including any requested clarifications, suggested safeguards, or recommended scope limitations or expansions for PCC usage.

What changed

• - MAS proposes introducing a Protected Cell Company (PCC) as a new corporate structure comprising a single legal entity with assets and liabilities statutorily segregated into distinct cells within...
• The PCC structure is intended to be available only to MAS-licensed entities engaged in captive insurance, insurance‑linked securities (ILS) and sovereign risk pooling activities, not generally to all...
• Each PCC will have a core and multiple cells, with ring‑fencing of assets and liabilities such that creditors of one cell should not have recourse to assets of other cells or the core, subject to...
• The framework is positioned to enable multiple risk issuances and programs within one vehicle, improving cost and operational efficiency compared with establishing multiple standalone insurers or...
• MAS signals that the PCC framework will complement existing special purpose reinsurance and alternative risk‑transfer structures, and is conceptually aligned with Singapore’s broader approach to...

Key dates

Q2 2026 (April–June 2026)

- Period covered by MAS’ “Key Enforcement Actions Taken by MAS in Q2 2026” enforcement round-up

14 May 2026

- Effective date of MAS’ revocation of the Major Payment Institution licence of Bsquared Technology Pte Ltd (BSQ)

18 May 2026

- MAS announced reprimands against senior management of Havenport Investments Pte Ltd and a $40,000 composition fine on the firm for regulatory breaches

19 May 2026

- Mr Tan Chun Yong and Mr Xie Jianfeng were convicted and sentenced (10 weeks’ imprisonment and a $200,000 fine respectively) for trading-related offences under the SFA

20 May 2026

- MAS published the outcomes of the SFA trading-related convictions and confirmed revocation of BSQ’s MPI licence with effect from 14 May 2026

Suggested considerations

• Review and, where necessary, enhance senior management and board-level oversight frameworks to ensure that responsibilities for MAS regulatory compliance are clearly allocated, documented, and evidenced (e.g. through committee charters, management information, and challenge records).
• Conduct a targeted compliance review at fund managers and other CMS licence holders to assess adherence to MAS regulations, focusing on areas previously cited in MAS enforcement actions (e.g. internal controls, client asset safeguards, and recordkeeping).
• For Major Payment Institutions and other payment providers, perform a comprehensive gap analysis of risk management frameworks, conflict-of-interest policies, and compliance with MAS Guidelines on Outsourcing, including due diligence, ongoing monitoring, and intra-group/related-party arrangements.
• Implement or strengthen formal governance around the accuracy and completeness of all information submitted to MAS (licence applications, regulatory returns, inspection responses), including sign-off controls, documentation standards, and verification procedures.
• For licensed trust companies and other AML/CFT-obliged entities, review and update AML/CFT policies, customer due diligence (CDD) and enhanced due diligence (EDD) procedures, ongoing monitoring, and suspicious transaction reporting processes in line with MAS Notices and Guidelines.

What changed

• - MAS reaffirmed its willingness to hold senior management personally accountable where they fail to ensure their institution complies with MAS regulations, as illustrated by reprimands against...
• MAS demonstrated continued zero tolerance for trading-related offences under the Securities and Futures Act (SFA), supporting criminal prosecutions that resulted in imprisonment and substantial fines...
• MAS confirmed that Major Payment Institution (MPI) licences can and will be revoked where inspections reveal significant weaknesses in risk management, conflict-of-interest policies, and...
• MAS signalled continued priority on AML/CFT supervision and enforcement by imposing a $300,000 composition penalty on a licensed trust company (Padang Trust Singapore Pte.
• MAS underscored its ongoing focus on insider trading and market abuse by imposing a civil penalty on an individual for insider trading in shares of a Singapore-listed (now delisted) company.

Suggested considerations

• Conduct immediate AML/CFT control gap assessments, focusing on customer due diligence (CDD), transaction monitoring, source-of-funds verification, and suspicious transaction reporting (STR) timelines; integrate proliferation financing (PF) risks.
• Enhance senior management oversight and accountability, ensuring compliance functions are resourced and independent; review director/representative conduct for fraud or ML risks.[MAS publication]
• For CMS licensees and LFMCs: Update risk assessments for high-risk clients (e.g., trusts, beneficial ownership), automate quarterly reporting (e.g., QDC for mandates >SGD 500m), and train staff on accelerated STRs.
• Perform thematic reviews of past flagged transactions and escalate unresolved suspicious activities to avoid composition penalties or POs.
• All FIs: Prepare for heightened MAS inspections by documenting governance, including liquidity frameworks and cyber/AI risks tied to financial crime.

What changed

This is not a regulatory change document but a retrospective enforcement summary; no new requirements are imposed. It highlights MAS's ongoing application of existing powers under the Financial Services and Markets Act 2022 (FSMA), Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992 (CDSA), and related frameworks, emphasizing deterrence via POs, composition penalties, civil penalties, and criminal referrals.[MAS publication] Related context shows MAS reinforcing AML/CFT expectations, such as robust controls, senior management oversight, and escalation of...

Key dates

23 October 2025

Wang Qiming convicted; (four charges: forgery, money laundering, obstructing justice; 24 months' imprisonment)

24 October 2025

Liu Kai convicted; (one charge: using forged document to cheat Julius Baer; 4 months' imprisonment)

17 March 2026

POs issued and effective; (16 years for Wang, 7 years for Liu; immediate prohibitions apply)

Suggested considerations

• Screen existing/prospective staff: Immediately verify no employment of Wang/Liu or prior prohibited individuals (e.g., via MAS enforcement list); cease any roles if discovered.
• Enhance RM onboarding/monitoring: Review KYC/CDD for HNWIs, especially from high-risk jurisdictions (e.g., Fujian-linked); audit forgery detection in documents.
• Senior manager accountability: Ensure policies for AML audits, risk assessments; train on fit and proper obligations under FSMA Guidelines.
• Report breaches: Disclose any inadvertent involvement to MAS promptly.
• Firm-wide review: For scandal-linked FIs (e.g., 9 fined S$27.45m, 4 Blue Ocean staff POs), confirm remediation; others benchmark controls against MAS actions.

What changed

• This is not a new regulation but an enforcement action applying existing FSMA powers. Key elements include:
• MAS deeming individuals "not fit and proper" under Guidelines on Fit and Proper Criteria (section 7, FSMA), based on convictions for forgery (Penal Code), money laundering (Corruption, Drug...
• POs prohibit: (i) carrying on MAS-regulated activities; (ii) direct/indirect management of financial institutions; (iii) acting as director/partner/manager of financial institutions; (iv)...
• Durations reflect misconduct gravity: 16 years for Wang (four convictions, 24 months' jail, six taken into consideration); 7 years for Liu (one conviction, 4 months' jail). No broader regulatory...

Key dates

1 January 2024

– Original Notice FHC-N133 effective date

8 December 2025

– Last revision to Notice FHC-N133 prior to this circular

1 January 2026

– Earlier amendments to AT1/T2 capital criteria became effective (as proposed in prior consultation)

16 March 2026

– ID 05/26 circular issued; revised Notice 133 and Notice FHC-N133 effective immediately

Suggested considerations

• *Immediate (within 30 days):
• N133 documents (156 KB PDF available on MAS website)
• *Short-term (30-90 days):
• insurance entity risk charges using the new explicit risk charging approach
• type criteria

What changed

The revised notices introduce several substantive amendments to the valuation and capital framework: Equity Counter-Cyclical Adjustment (CCA) The introduction of equity CCA represents a significant methodological shift in how insurers must calculate capital requirements for equity risk exposure. This mechanism adjusts capital charges based on equity market volatility cycles, requiring insurers to implement dynamic risk modeling rather than static capital calculations. Structured Products Capital Treatment New capital treatment rules for structured products establish specific valuation and...

Key dates

18 October 2023

Consultation Paper on Guidelines on Transition Planning for Insurers issued; (P013-2023)

18 December 2023

Consultation closing date

05 March 2026

MAS response to consultation and issuance of final Guidelines/addendum; Last Revised Date for related Environmental Risk Management Guidelines; .[https://www.mas.gov.sg/regulation/circulars/id04_26]

Suggested considerations

• Establish Transition Planning Process: Develop risk-proportionate frameworks for identifying, assessing, and managing climate transition/physical risks, integrated into governance, risk management, and strategy.
• Conduct Assessments: Perform scenario analyses (short/medium/long-term), materiality reviews, and multi-year planning beyond typical horizons.
• Engage Stakeholders: Collaborate with customers, asset managers, and investees to support decarbonization/adaptation plans; avoid premature withdrawal of finance/insurance.
• Disclose Risks: Report meaningfully on climate risks, interdependencies (e.g., climate-nature), and trade-offs to stakeholders.
• Board Oversight: Ensure senior management/governance integration, with documentation for MAS supervision.

What changed

• - Addendum to Existing Guidelines: Supplements the Guidelines on Environmental Risk Management with specific guidance on transition planning processes, focusing on managing transition risks (e.g.,...
• Risk-Proportionate Approach: Insurers must establish transition planning proportionate to factors like business size, exposure, and complexity, including internal strategic planning, risk management,...
• Holistic Integration: Emphasizes multi-year assessments, scenario analysis, and collaboration over divestment, accepting short-term emissions increases if aligned with net-zero pathways; integrates...
• Supervisory Expectations: Non-binding but sets clear MAS benchmarks for "sound" practices, building granularity on prior environmental risk frameworks.

Key dates

19 February 2021

19 March 2021; - Consultation period on proposed revisions to Notices 124, 125, and 126

30 September 2022

- Last revision of MAS Notice 126 on ERM, including ORSA guidelines (effective 01 January 2023)

30 September 2022

- MAS response to consultation feedback on ERM revisions

02 January 2026

- Publication of ID 01/26 circular reminding of ORSA submission requirements under Notice 126

Suggested considerations

• Review current ORSA processes to confirm entity-specific reports are produced, not mere group report adoptions.
• Conduct gap analysis against Notice 126: Ensure ORSA covers risk identification, solvency assessment, stress testing (e.g., macroeconomic, liquidity), and forward-looking horizons aligned with business planning.
• Update board and senior management oversight of ERM, documenting rationale for any group influences while maintaining local tailoring.
• Submit ORSA reports to MAS as per ongoing Notice 126 timelines (typically annually); remediate any past lapses via voluntary disclosure if needed.
• Enhance internal controls, training, and audit trails for ORSA compliance to avoid future observations.

What changed

No new regulatory changes are introduced; this is a reminder and clarification of existing MAS Notice 126 requirements on ORSA submissions. Key emphasis: Insurers cannot fully rely on group ORSA reports—local entities must produce their own tailored ORSA reports reflecting entity-specific risks, time horizons, and business strategies. It reinforces ORSA as a core ERM tool involving own risk assessment, solvency projections, and stress testing (e.g., macroeconomic scenarios).

Key dates

2022-04-19

MAS opened Consultation P002-2022 on revised misconduct-reporting Notices.

2022-05-20

Consultation P002-2022 closed.

2025-12-30

MAS issued the consultation response and Revised Notices FAA-N27, Notice 508 and SFA 04-N24.

2026-06-30

MAS targeted the second quarter of 2026 for sharing finalised misconduct and investigation-report templates; the source does not specify a precise day.

2027-01-01 Deadline

The Revised Notices take effect and affected firms must comply with the revised misconduct-reporting framework.

Suggested considerations

• Firms should map their representative and broking-staff populations, regulated activities and product lines to the applicable Notice, including the separate FAA and IA reporting treatment where conduct involves both a designated investment product and a long-term accident and health policy.
• Compliance teams may wish to update misconduct taxonomies and escalation criteria to cover Part 12 SFA market-conduct breaches, fraud, dishonesty, illegal monetary gains, client detriment, gross negligence, inappropriate advice, misrepresentation and inadequate disclosure, while documenting how non-reportable internal-policy breaches are distinguished from reportable underlying conduct.
• Firms should design procedures that identify when reasonable grounds arise and start the 21-calendar-day reporting clock without waiting for conclusive findings of culpability.
• Firms should establish decision trees for simultaneous misconduct and investigation reports, later investigation reports, update reports, police-report assessments and developments received from law enforcement or public sources.
• Firms should implement controls to provide reports and updates to current and former representatives, including identity verification, secure transmission, reasonable attempts using last-known contact details, acknowledgement or mailing evidence, and documented exceptions where disclosure could prejudice an investigation.
• Firms should review disciplinary frameworks, proportionality factors, fine calibration, appeal processes and governance to evidence a fair and transparent assessment of severity and client impact.
• Firms should enhance record-retention procedures to preserve relevant investigation, reporting, representative-notification and submission records in accessible and retrievable form for at least five years.
• Firms should monitor MAS implementation materials and final reporting templates, which MAS targeted to publish by the second quarter of 2026, and test operational readiness before the effective date.

What changed

The revised instruments are Notice FAA-N27 under the Financial Advisers Act 2001, Notice 508 under the Insurance Act 1966, and Notice SFA 04-N24 under the Securities and Futures Act 2001. A firm must generally submit a misconduct report within 21 calendar days after it has reasonable grounds to believe that misconduct was committed; conclusive proof of culpability is not required.

Key dates

16 December 2025

- Circular published, announcing updated template and process

1 February 2026

- Mandatory use of updated FI Incident Reporting Template on MAS-Tx for all subsequent incident reports (initial notifications follow existing prescribed timelines). https://www.mas.gov.sg/regulation/circulars/circular-on-financial-institution-incident-reporting

Suggested considerations

• Review and familiarize with the updated FI Incident Reporting Template (downloadable from MAS site).
• Integrate MAS-Tx platform access and training for compliance, IT, and risk teams to handle submissions.
• Update internal incident response plans to ensure initial notifications occur "as soon as possible but no later than prescribed timelines" under relevant rules (e.g., Technology Risk Management Notices), followed by template-based reports via MAS-Tx post-1 February 2026.
• Conduct gap analysis against related TRM Notices (e.g., FSM-N05 for banks, FSM-N25 for trust companies) to align incident detection and reporting. https://panorays.com/blog/mas-trm-compliance/
• Test processes via simulations, as recommended in TRM guidelines for incident response readiness. https://panorays.com/blog/mas-trm-compliance/

What changed

• - Updated Reporting Template: FIs must use the new FI Incident Reporting Template (65.8 KB) for submitting details of reportable incidents on MAS-Tx, replacing prior formats.
• Dual Reporting Process: Initial notification required "as soon as possible, but no later than the timeline prescribed" in relevant acts, regulations, notices, circulars, or guidelines; followed by...
• Platform Mandate: All subsequent reports must be filed through MAS-FI Transactions Platform (MAS-Tx), streamlining MAS oversight.

Key dates

1 January 2026

- Effective date; capital instruments subject to new criteria and non-retail restriction

Suggested considerations

• Review and update capital instruments: Assess existing and planned AT1/Tier 2 issuances against new criteria; amend terms if needed to qualify under RBC 2.
• Implement distribution controls: Establish processes to ensure instruments are sold exclusively to non-retail investors in Singapore (e.g., accredited investors, institutions); update investor eligibility checks, prospectuses, and distribution agreements.
• Update internal policies: Revise capital management, valuation, and reporting procedures per amended Notice 133/FHC-N133; integrate into RBC 2 calculations.
• Board/ senior management oversight: Document compliance gap analysis, remediation plans, and training for finance/treasury teams.
• Reporting: Monitor and report capital positions under RBC 2, notifying MAS of material changes.

What changed

• - Amendments add additional criteria for capital instruments to qualify as AT1 or Tier 2 Capital, aligning with international prudential standards under RBC 2 (Risk-Based Capital 2 framework).
• Key condition: Instruments must be sold only to persons who are not retail investors in Singapore, prohibiting retail distribution to mitigate risks from less sophisticated investors.
• Updates apply to valuation and capital requirements in Notice 133 (for licensed insurers) and Notice FHC-N133 (for Designated Financial Holding Companies).
• Follows MAS review of consultation feedback, proceeding with proposed enhancements originally outlined in the March 2025 Consultation Paper.

Key dates

30 October 2025

- Publication date of ID 14/25 and FAS 16/2025 circular notifying amendments

Suggested considerations

• Download and review the full amendment document (ID 14/25 and FAS 16/2025) from https://www.mas.gov.sg/regulation/circulars/id14_25.
• Assess current training and competency programs against updated Annex 1 (MAS Notice 211) and Appendix 1 (MAS Notice 502), focusing on minimum standards and best practices for staff.
• Update internal policies, CPD requirements, and staff certification processes to incorporate changes, including any new "fit and proper" clarifications.
• Conduct gap analysis for affected representatives and implement training by any specified effective date; maintain records for MAS audits.
• For brokers and composite insurers, ensure alignment across general and life business lines if overlapping.

What changed

The amendments target Annex 1 of MAS Notice 211 (applicable to direct general insurers) and Appendix 1 of MAS Notice 502 (applicable to insurance brokers), both addressing Minimum and Best Practice Training and Competency Standards. Specific changes are not detailed in the notification summary but likely include clarifications on applicability, "fit and proper" criteria for staff, and enhanced continuing professional development (CPD) requirements, as referenced in related Notice 211 updates.

Suggested considerations

• Review and update internal capital models, valuation policies, and investment portfolios for structured products and infrastructure assets to align with new risk charges and definitions.
• Assess eligibility of current holdings against refined qualifying criteria (e.g., infrastructure corporates at ≥75% threshold) and prepare look-through analyses for funds.
• Monitor MAS updates on the sustainable infrastructure pilot program and evaluate participation if applicable.
• Conduct gap analysis on MAS Notice 133 revisions once finalized; test systems for equity correlation factors and reduced unrated debt periods.
• Document compliance readiness and report to senior management/board ahead of 31 March 2026 effective date.

What changed

• - Structured Products: Removes the 50% risk charge option on full market value; recognizes credit ratings from external institutions for securitized asset tranches; applies 50% loading for rated...
• Infrastructure Investments: Adopts Insurance Capital Standard (ICS)-aligned definitions (e.g., adding "Water utilities", "Waste management utilities", "Energy utilities"); refines qualifying criteria...
• Pilot Program: MAS is collaborating on a pilot for sustainable infrastructure projects with risk-appropriate capital charges and investment caps to build insurer expertise.

Suggested considerations

• Review Existing/Planned Issuances: Inventory AT1/Tier 2 instruments against new criteria; ensure compliance with non-retail investor restriction (e.g., verify distribution channels and investor classifications).
• Update Capital Planning: Amend internal models and RBC 2 calculations per updated Notices 133/FHC-N133; test eligibility of instruments for loss absorption (e.g., callability, maturity ≥5 years for Tier 2).
• Investor Documentation: Implement controls to confirm sales exclude Singapore retail investors; update prospectuses and distribution agreements.
• Reporting & Disclosure: Integrate changes into valuation/capital reporting under RBC 2; seek MAS approval if needed for non-standard instruments.
• Training & Governance: Train compliance/treasury teams; board oversight for capital planning impacts.

What changed

• - Additional Criteria for AT1 and Tier 2 Instruments: Introduces new eligibility criteria for capital instruments to qualify as AT1 or Tier 2 under RBC 2, enhancing loss absorption features (e.g.,...
• Investor Restriction: Instruments must be sold only to persons who are not retail investors in Singapore to qualify, reducing retail exposure risk.
• Notice Amendments: Formalizes updates via ID 15/25, amending Notice 133 (for insurers) and Notice FHC-N133 (for Designated Financial Holding Companies), effective 1 January 2026. These align with...

Key dates

29 September 2025

- Publication and issuance of ID 11/25 amendments to MAS Notice 321

1 October 2025

- Effective date for Notice 321 (Amendments) 2025

At least 1 month before launch

- MAS approval submission for industry-new DPI features; notification for insurer-new features

Within 7 working days after launch

- Notification for no-new-features DPIs

Suggested considerations

• Review and update DPI manufacturing processes to comply with standardized features in Appendix A of Notice 321, ensuring premiums ≤ non-DPI equivalents and benefits ≥ equivalents.
• Implement streamlined filing: Seek MAS approval for novel products (1-month lead), notify for insurer-novel or standard products as specified.
• For distribution: Deploy safeguards (affordability checks, info disclosure), non-advisory channels, and client query mechanisms (phone/email helplines).
• Obtain MAS written approval before offering new/re-priced DPIs; adhere to any specified launch dates.
• Update internal policies for pricing (no negating savings via margins), naming ("DIRECT" prefix), and risk assumptions matching non-DPIs.

What changed

• The amendments primarily streamline approval processes for DPI products under Notice 321 and related Notice 302:
• For new or re-priced DPIs with features entirely new to Singapore’s life insurance industry, insurers must seek MAS approval at least one month before launch.
• For DPIs with features new only to the insurer, notify MAS at least one month prior to launch.
• DPIs with no new features require notification within seven working days after launch. These changes ease prior stringent requirements while upholding core DPI mandates: standardized products (term...

Key dates

27 March 2025

– MAS issued original consultation paper on proposed equity CCA

28 April 2025

– Consultation period closed

25 August 2025

– MAS published response to consultation feedback

08 December 2025

– Last revision date for related Notices 133 and FHC-N133

1 January 2026

– **Effective implementation date for equity CCA**

Suggested considerations

• *Immediate Compliance Steps (by January 1, 2026):
• *System Implementation – Develop or modify capital calculation systems to incorporate monthly average YoY equity return calculations
• *Data Infrastructure – Establish daily equity return tracking mechanisms and monthly aggregation processes
• *Policy Documentation – Update internal capital management policies to reflect mandatory CCA application
• *Governance Alignment – Ensure board and senior management understand the mandatory nature and cannot exercise discretion to opt out during market stress

What changed

• Mandatory CCA Implementation MAS will proceed with introducing the CCA as a mandatory requirement across all insurers.
• Determining YoY returns on a daily basis
• Computing the average YoY returns over the preceding one-month period This change addresses concerns that daily calculations created excessive sensitivity to timing and duration of market stress...

Key dates

1 January 2024

- Effective date of baseline Notice FHC-N133 (pre-amendment)

24 July 2025

- Issuance of Consultation Paper P011-2025 on Proposed Changes to the Group Capital Framework

25 August 2025

- Consultation closing date (now passed as of February 2026)

Suggested considerations

• Gap analysis: Model impacts on group financial resources, identify data/ system gaps for NIE/JV risk assessments, and simulate capital shortfalls under new limits.
• Stakeholder engagement: If not already done, firms that submitted feedback by 25 August 2025 should track MAS response; prepare internal policy updates and board reporting on potential capital adjustments.
• Ongoing: Enhance monitoring of non-insurance subsidiaries and JVs; update valuation processes to align with RBC 2 consolidation once finalized.

What changed

• The proposals target refinements to the group capital framework in Notice FHC-N133 (effective 1 January 2024) and include:
• Risk charging approach for non-insurance entities (NIEs): Introduce a standardized method to assess and charge capital for risks posed by NIEs within the DFHC group, with potential additional charges...
• Enhanced capital treatment for joint ventures (JVs): Strengthen requirements to better reflect JV risks in group capital computations.
• Limit on recognition of capital from non-controlling interests (NCIs): Cap the amount of NCI capital recognized in group financial resources to account for its non-fungible nature (currently, NCI...