ID 01/26 MAS Notice 126 - Lapses in Own Risk and Solvency Assessment (ORSA) Report Submissions
Executive Summary
This MAS circular ID 01/26, published on 02 January 2026, addresses observed lapses in ORSA report submissions under MAS Notice 126, specifically reminding insurers not to fully rely on group-level ORSA reports to meet local requirements. It matters because non-compliance risks regulatory scrutiny, enforcement actions, and weakened enterprise risk management (ERM) frameworks essential for solvency and risk oversight in Singapore's insurance sector. #
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). #
What You Need To Do
- Review current ORSA processes to confirm entity-specific reports are produced, not mere group report adoptions
- Conduct gap analysis against Notice 126
- 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
Key Dates
Compliance Impact
Urgency: High – Immediate attention required as the circular flags "several insurers" with lapses, signaling MAS active monitoring and potential targeted inspections or penalties. Matters for solvency regime integrity; non-compliance undermines ORSA's role in capital adequacy and could trigger supervisory interventions amid evolving risks like liquidity and macro stresses.
Who is Affected
Summary
Inform and remind insurers of MAS Notice 126 requirements and expectations on ORSA report submissions.