Reporting & Disclosure 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

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

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

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.