Circular on (i) FAQs on the Misconduct Reporting Requirements under the Financial Advisers Act, Insurance Act and Securities and Futures Act; and (ii) Discontinuation of the Existing Misconduct Reporting System with effect from 1 January 2027

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. The revised framework updates the categories of reportable misconduct, including misconduct involving market-conduct breaches and acts involving fraud, dishonesty, illegal monetary gains or similar offences. Where the firm has commenced an internal investigation, it must submit the prescribed investigation report at the same time as the misconduct report. Where available, it must also submit a

Who is affected

• Licensed financial advisers under the Financial Advisers Act
• Exempt financial advisers under the Financial Advisers Act
• Holders of a capital markets services licence under the Securities and Futures Act
• Persons exempt from holding a capital markets services licence under section 99(1)(a), (b), (c) or (d) of the Securities and Futures Act
• Registered insurance brokers and exempt insurance brokers under the Insurance Act
• Licensed direct insurers, including life and composite insurers, with accident and health insurance intermediaries
• Current and former representatives and relevant broking staff whose misconduct is reportable

Related regulations

• Financial Advisers Act 2001
• Insurance Act 1966
• Securities and Futures Act 2001
• MAS Notice FAA-N27 Reporting of Misconduct of Representatives by Financial Advisers
• MAS Notice 508 Reporting of Misconduct of Broking Staff by Insurance Brokers and of Representatives by Accident and Health Insurance Intermediaries
• MAS Notice SFA 04-N24 Reporting of Misconduct of Representatives by Holders of Capital Markets Services Licence and Exempt Persons
• MAS Notice FAA-N14 Reporting of Misconduct of Representatives by Financial Advisers
• MAS Notice 504 Reporting of Misconduct of Broking Staff by Insurance Brokers
• MAS Notice SFA 04-N11 Reporting of Misconduct of Representatives by Holders of Capital Markets Services Licence and Exempt Financial Institutions