Capital Markets & Trading in Singapore

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

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.