ID 01/26 MAS Notice 126 - Lapses in Own Risk and Solvency Assessment (ORSA) Report Submissions
AI Analysis
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.
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).
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
Related regulations
References
AI-generated analysis. May contain errors or omissions — verify with the original MAS source before acting. Full disclaimer.
What the MAS said
Inform and remind insurers of MAS Notice 126 requirements and expectations on ORSA report submissions.
Published by MAS . Read the full notice at the source for the authoritative text.