MAS Policy Statements

Key dates

2026-10-07

MAS published its written parliamentary reply stating that LIA’s next review of severe-stage critical illness definitions will commence in 2027 and that updated definitions will apply to new products sold.

2027-01-01

The LIA review is expected to commence during 2027; the publication does not specify an exact commencement date or impose a firm for firms to act by this date.

2025-10-01

The LIA Critical Illness Framework 2024 was required to be adopted for new products no later than this date, according to independent industry and LIA-related materials; this is relevant background rather than a new deadline created by the MAS reply.

Suggested considerations

• Compliance teams may wish to monitor the LIA’s 2027 review, consultation materials, final framework amendments, implementation dates, and any MAS communications that follow.
• Insurers should consider mapping current severe-stage definitions to the procedures and clinical severity criteria that may be affected, including identifying products whose claims triggers are particularly dependent on a named surgical procedure.
• Product governance, actuarial, underwriting, claims, legal, and compliance functions may wish to assess how alternative disease- and severity-based triggers could affect coverage scope, expected claims frequency, reserves, reinsurance, and pricing.
• Firms should consider documenting whether existing policy wordings can continue to be administered consistently with their contractual terms and should avoid treating any future framework revision as automatically applicable to in-force policies.
• Insurers developing new products should consider preparing customer disclosures explaining the relevant disease, severity, diagnostic evidence, exclusions, waiting periods, and any procedure-independent claims criteria.
• Compliance teams may wish to review product approval and change-control processes so that future LIA definition changes are reflected consistently in policy documents, benefit illustrations, sales materials, claims manuals, staff training, and complaint-handling procedures.
• Actuarial and product teams should consider reassessing premiums and claims assumptions before launching products using revised definitions, since MAS expressly notes that premiums depend on the probability of claims materialising.

What changed

No immediate statutory requirement, product withdrawal, or mandatory amendment to existing policies was introduced. LIA’s 2027 review will consider procedure-neutral or less procedure-dependent definitions for certain medical conditions, while retaining the use of procedures where they provide objective evidence of severity, recovery duration, and financial impact. Any resulting changes will apply to new products sold; existing policies remain governed by their contractual definitions and terms.

Key dates

2026-10-07

MAS published the written parliamentary reply and stated that approximately 4,000 households could face cash shortfalls under the severe stress scenario.

Suggested considerations

• Compliance and consumer-credit teams may wish to confirm that mortgage portfolios have documented processes for identifying deteriorating repayment performance and other early indicators of financial stress.
• Banks should consider reviewing whether frontline and collections staff consistently contact borrowers early, assess individual circumstances, and record the rationale for any restructuring, refinancing, forbearance, or other assistance offered.
• Mortgage lenders may wish to test whether vulnerable segments identified by the MAS stress test, including lower-income middle-aged HDB borrowers and borrowers with sizeable private-housing loan balances, are adequately represented in portfolio monitoring and scenario analysis.
• Firms should consider maintaining clear customer communications directing borrowers who anticipate repayment difficulty to contact the lender before arrears arise.
• Banks and relevant agencies may wish to review referral arrangements with HDB, Credit Counselling Singapore, and appropriate social-service agencies, including escalation and hand-off procedures.
• Risk committees may wish to retain evidence that severe interest-rate, income-reduction, unemployment, and liquidity-buffer scenarios are considered in mortgage portfolio risk management, while distinguishing scenario-based vulnerabilities from actual current borrower distress.
• Firms should avoid describing the approximately 4,000-household figure as a forecast of current arrears or as an individually identified list of affected customers.

What changed

No binding regulatory requirement, threshold, reporting obligation, or enforcement measure was introduced by this parliamentary reply. MAS confirmed that financial institutions monitor repayment performance and engage borrowers showing signs of financial stress, with assistance tailored to individual circumstances. HDB-financed borrowers may approach HDB for restructuring discussions, bank-financed borrowers may approach their banks, and borrowers already experiencing debt repayment difficulties may seek counselling and debt-management guidance from Credit Counselling Singapore.

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.

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

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...