MAS Updates 2025

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...

Key dates

24 July 2025

- Issuance of Consultation Paper (P012-2025) and QIS by MAS

05 September 2025

- Consultation closing date for feedback on proposals and QIS completion

08 December 2025

- Last revision date of related Notice 133 on Valuation and Capital Framework

Suggested considerations

• Complete and submit QIS for SIF and OIF general business (exemptions apply for certain reinsurers' OIF).
• Provide feedback on consultation questions, including standardized scenarios, "Own Bespoke" requirements, OIF materiality threshold, flood parameters, and governance for models.
• Review and prepare internal catastrophe models (vendor/proprietary) meeting proposed governance standards for OIF natural cat risks.
• Assess capital impacts under proposed charges and aggregation; update RBC 2 compliance programs accordingly.
• Monitor MAS website for final rules post-5 September 2025 (https://www.mas.gov.sg/regulation/circulars/id08_25).

What changed

• - Introduction of GI Cat risk charge: Captures natural (e.g., standardized flood for SIF; whole-of-portfolio for OIF) and man-made catastrophe risks (e.g., fire/explosion, economic events, pandemic)...
• SIF computation: Prescribed standardized scenarios (flood for natural; fire/explosion, economic event, pandemic for man-made) plus annual "Own Bespoke" scenario for material risks like earthquakes or...
• OIF computation: Standardized man-made scenarios plus annual "Own Bespoke" for man-made risks; natural cat on whole-of-portfolio basis using vendor/in-house models with governance requirements;...
• Aggregation approach: Specified method for combining GI Cat risk charges across funds.
• Accompanying QIS to assess impacts, building on prior studies (2021 preliminary, 2022 stress test, 2024 survey).