Senior Managers / Governance in Singapore

Key dates

2026-11-02

MAS announced the grant scheme, commenced Consultation Paper P018-2026, and the Infrastructure Capability Development Grant took effect.

2026-12-18 Deadline

Deadline for comments on MAS Consultation Paper P018-2026 concerning capital treatment for securitisation and infrastructure investments under RBC 2.

2026-03-31

Earlier RBC 2 revisions concerning differentiated capital treatment for qualifying infrastructure investments took effect; this is relevant background to the current consultation.

Suggested considerations

• Compliance and regulatory affairs teams should review Consultation Paper P018-2026 and consider submitting comments to MAS by 18 December 2026.
• Insurers should distinguish the currently effective RBC 2 requirements from the proposed capital treatments and avoid applying the proposed lower charges before the relevant amendments take effect.
• Investment, risk and actuarial teams should inventory infrastructure debt, infrastructure equity and securitisation exposures and assess which assets could potentially satisfy the proposed credit-quality, contractual-revenue, demand-risk, counterparty, securitisation, diversification and liquidity criteria.
• Firms should review their investment due-diligence, valuation, credit-assessment and documentation processes so that qualifying characteristics can be evidenced and maintained throughout the investment lifecycle.
• Insurers considering the grant should contact MAS to obtain the Infrastructure Capability Development Grant terms, eligibility requirements, application process, eligible-cost rules and reporting conditions.
• Firms should monitor MAS updates on standardised disclosure templates, assessment guidance and fund-manager declarations and assess whether investment mandates and manager reporting can support those formats.
• Insurers should monitor MAS recognition of additional external credit assessment institutions and review whether expanded recognised-rating coverage could affect sourcing, eligibility or capital calculations.
• Governance committees should consider whether proposed infrastructure allocations remain consistent with policyholder protection, asset-liability management, concentration limits, liquidity needs and existing investment-risk policies.

What changed

The Infrastructure Capability Development Grant takes effect on 2 November 2026 and will be funded through the Financial Sector Development Fund. It may support dedicated investment teams, staff capability development, and professional services used to establish or expand infrastructure investment activities in Singapore; insurers must approach MAS for scheme details and eligibility conditions. MAS is consulting on further amendments to the insurance capital framework under RBC 2.

Key dates

2026-11-02

MAS published Circular ID 12/26 and opened consultation P018-2026 on capital treatment for securitisation and infrastructure investments under RBC 2.

2026-11-02

The S$30 million Infrastructure Capability Development Grant for Insurers took effect, subject to MAS grant arrangements.

2026-12-18 Deadline

Deadline for submitting comments on consultation P018-2026.

2026-03-31

Earlier finalised RBC 2 revisions to the capital treatment of securitisation and infrastructure investments took effect; the current consultation proposes further refinements to that framework.

Suggested considerations

• Compliance and capital teams should review the consultation paper and consider submitting comments to MAS by 18 December 2026, particularly on eligibility tests, evidence requirements, capital calibrations and implementation timing.
• Firms should map current and planned infrastructure debt, infrastructure equity, infrastructure-fund and securitisation exposures against the proposed qualifying criteria, distinguishing assets that could benefit from lower charges from assets that would remain subject to existing treatment.
• Investment, risk and finance functions should assess whether existing due diligence, valuation, credit assessment, look-through analysis and documentation can evidence contractual revenues, demand-risk limitations, counterparty strength, tranche seniority, investment grade status, diversification, liquidity and simplicity, transparency and comparability.
• Firms should monitor amendments to MAS Notice 133 and Notice FHC-N133 and avoid reflecting proposed capital relief in regulatory capital planning, pricing or investment limits until the proposals are finalised and effective.
• Insurers may wish to assess whether they qualify for or could benefit from the Infrastructure Capability Development Grant and identify capability gaps in origination, underwriting, infrastructure valuation, credit analysis and ongoing monitoring.
• Governance teams should establish a process for monitoring the additional external credit assessment institutions, standardised disclosure templates, fund-manager declarations and assessment guidance that MAS may introduce.
• Groups with infrastructure investments held through funds or structured products should confirm whether the final treatment will permit look-through and should not assume that infrastructure-backed structured products qualify for infrastructure treatment rather than structured-product treatment.

What changed

This is a consultation and does not itself amend Notice 133 or impose new binding capital requirements. MAS is proposing lower capital charges for rated infrastructure debt that satisfies specified credit-quality and other qualifying criteria; for qualifying infrastructure equity and debt investments with risk mitigants such as long-term contractual or regulated revenues, limited demand-risk exposure and strong counterparties; and for senior investment-grade securitisation tranches meeting relevant simplicity, transparency and comparability criteria or specified diversification and liquidity...

Key dates

2026-10-28

MAS published its statement reinforcing banks’ existing environmental-risk management expectations in the context of transboundary haze, pollution and deforestation.

Suggested considerations

• Banks should consider mapping customers, counterparties and financed activities that may be linked to open burning, deforestation, peatland development or other haze-related pollution, at both customer and portfolio level.
• Compliance and risk teams may wish to establish a process for capturing, validating and escalating relevant NEA information and notices issued under the Transboundary Haze Pollution Act.
• Banks should consider enhancing customer due diligence for potentially haze-linked customers, including obtaining evidence of land ownership or control, fire-prevention and response arrangements, concession and supply-chain information, environmental permits, incident history and remediation measures.
• Banks may wish to document customer engagement, responses, management decisions and escalation criteria so that the rationale for continuing, conditioning, reducing or terminating exposure is demonstrable.
• Credit committees and relationship teams should consider incorporating environmental-risk findings into new-financing approvals, renewals, covenant-setting, pricing, collateral assessments and ongoing monitoring.
• For higher-risk customers, banks may wish to consider enhanced measures such as site visits, independent environmental expertise, satellite or geospatial monitoring and contractual rights to obtain information or suspend further drawdowns.
• Banks should consider defining governance triggers for cases involving suspected or confirmed breaches, with senior-management or board escalation where exposure limits or relationship exit is contemplated.
• Banks may wish to review public environmental-risk disclosures and transition plans for consistency with the strengthened supervisory focus, while recognising that the statement itself does not create a new disclosure deadline.

What changed

MAS has expressly linked banks’ environmental-risk processes to haze-related pollution and deforestation risks. Banks should consider relevant information released by the National Environment Agency under the Transboundary Haze Pollution Act and engage customers potentially connected to haze-producing activities to obtain sufficient information about their role, including controls to prevent, detect and stop fires.

Key dates

2026-10-12

MAS announced the enhanced safeguards and published its response to the consultation on public prospecting activities.

Suggested considerations

• Compliance teams may wish to map all roadshows, promotional booths and other public prospecting activities against the forthcoming restriction to designated areas at commercial premises.
• Firms should consider identifying suitably qualified event supervisors, defining their responsibilities and documenting escalation and intervention procedures for representative misconduct.
• Firms should consider revising scripts and training so representatives clearly state their marketing purpose before engagement and obtain consumer consent before proceeding.
• Firms may wish to establish monitoring, sampling and management-information controls to evidence that consent was obtained and that solicitation was not persistent or otherwise inappropriate.
• Firms should review policies, representative procedures, venue approval processes, third-party arrangements and supervisory testing for continued street canvassing or door-to-door activity, which remains prohibited.
• Compliance teams may wish to track the 2027 issuance of the updated Guidelines and calculate the applicable nine-month transition period from the actual issuance date rather than from this announcement.
• Firms should consider aligning physical prospecting controls with their existing controls for digital advertising activities introduced in September 2025.

What changed

Financial institutions will be expected to conduct public prospecting only in designated areas at commercial premises. They will need to appoint suitably qualified individuals to oversee representatives’ conduct at such events. Representatives must disclose at the outset that they intend to market financial products or services and obtain the consumer’s consent before continuing the engagement. Street canvassing and door-to-door prospecting remain prohibited.

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 issued the Guidelines on Artificial Intelligence Risk Management following its November 2025 consultation.

2027-10-07 Deadline

The Guidelines take effect. FIs should meet the expectations in Sections 3 and 4 from this date.

2027-10-07

MAS intends to consult the financial sector during 2027 on what additional guidance on agentic AI would be useful.

2028-10-07 Deadline

FIs should meet the expectations in Sections 5 and 6 by this date under the phased implementation timetable.

Suggested considerations

• FIs should establish or update an enterprise inventory of AI systems, models, embedded AI functionality and third-party AI services, using a level of granularity appropriate to their risk profile.
• Compliance and risk teams may wish to classify individual AI use cases by materiality, including potential effects on customers, prudential soundness, operational resilience, other financial institutions and the wider financial system.
• Boards and senior management should consider documenting AI risk appetite, ownership, escalation routes and the allocation of responsibilities across business, risk, compliance, technology, cybersecurity, data and model-governance functions.
• FIs should map existing AI controls across the lifecycle, including data governance, development and validation, testing, human oversight, cybersecurity, monitoring, incident management and change management, and identify gaps against the Guidelines.
• Procurement, outsourcing and third-party-risk functions should consider adding AI-specific due diligence, assurance, contractual rights, performance monitoring, incident notification and exit or substitution arrangements for external AI providers.
• FIs should assess whether existing governance committees and risk frameworks provide sufficient cross-functional oversight, rather than assuming that a new dedicated AI committee is necessary.
• FIs may wish to define evidence that supports proportionality decisions, including why basic policies and procedures are adequate for lower-materiality AI use cases.
• Implementation planning should distinguish the expectations in Sections 3 and 4, which should be met from 7 October 2027, from Sections 5 and 6, which should be met by 7 October 2028.

What changed

The Guidelines introduce an enterprise- and use-case-level framework for managing AI risk. Boards and senior management are expected to oversee AI risk, define accountabilities, set risk appetite, and maintain suitable risk-management frameworks, policies and procedures; existing governance structures may be used and a dedicated AI committee is not required solely for compliance.

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

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

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

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.