Singapore: MAS issues revised misconduct reporting requirements for financial institutions

MAS issued the following revised Notices on misconduct reporting requirements (collectively, the “Revised Notices”) on 30 December 2025, following a multi-year consultation process that began in 2018:

• Notice FAA-N27 on Reporting of Misconduct of Representatives by Financial Advisers (replacing Notice FAA-N14);

• Notice 508 on Reporting of Misconduct of Broking Staff by Insurance Brokers and of Representatives by Accident and Health Insurance Intermediaries (replacing Notice MAS 504); and

• Notice SFA 04-N24 on Reporting of Misconduct of Representatives by Holders of Capital Markets Services Licence and Exempt Persons (replacing Notice SFA 04-N11). 

In July 2018, MAS consulted on proposed changes to misconduct reporting requirements in order to enhance the quality of how financial institutions (FIs) detect, investigate and address representative misconduct. MAS published its responses in May 2021, and later MAS consulted on the specific legislative amendments needed to implement these changes under the Financial Advisers Act 2001 (FAA), Insurance Act 1966 (IA) and Securities and Futures Act 2001 (SFA) in April 2022. In December 2025, MAS published its Response to Feedback Received on Revised Notices on Misconduct Reporting Requirements, finalising the misconduct reporting framework.

The Revised Notices will come into effect on 1 January 2027, providing FIs with a one-year period to prepare for compliance with the revised requirements. To support this, MAS will publish FAQs providing further clarity on key concepts such as reportable misconduct.

Key updates

1. Revision to reportable misconduct categories

MAS has narrowed the scope of reportable misconduct by removing two categories entirely: (i) misconduct relating to failure to satisfy the Guidelines on Fit and Proper Criteria, and (ii) the broad "catch-all" category covering other misconduct resulting in non-compliance with regulatory requirements or serious breaches of internal policy.

For misconduct involving inappropriate advice or misrepresentation under the FA and IA, MAS has added gross negligence and inappropriate recommendation as reportable categories and requires the acts to have a materially adverse impact on client interests or to impinge on the representative's fitness and propriety. This aligns with the existing regulatory requirement under Notice FAA-N20 to assess whether representatives’ infractions reach such materiality thresholds.

For misconduct involving fraud and dishonesty across all three Acts, MAS is expanding the scope to explicitly include illegal monetary gains and additional offences such as bribery, money laundering and tax evasion.  

2. New investigation and reporting requirements

While the requirement to submit an investigation report is not new to the Revised Notices, MAS now requires FIs to submit investigation reports using prescribed formats, and FIs are required to adopt the investigation report template for submission of details of investigations relating to representatives' reportable misconduct. The reporting timeline has been extended from 14 to 21 calendar days, and the trigger changed from "discovery" to when FIs have "reasonable grounds to believe" that misconduct was committed. In most cases, reasonable grounds are established at the conclusion of an investigation. In limited circumstances where reasonable grounds exist before an investigation is concluded, FIs are required to submit the misconduct report first and the investigation report subsequently.

3. Providing representatives with a copy of the misconduct report 

Another change is the requirement for FIs to provide representatives with copies of misconduct reports submitted to MAS within 21 calendar days after submission to MAS. This change was implemented to avoid previous situations where representatives were unaware that they were being investigated or that their principal companies have submitted misconduct reports on them, resulting in them being unable to make full or accurate disclosures on their compliance history when applying to join a new principal company. To guard against such disclosure compromising the quality of the investigation, this requirement does not apply if providing the copy would prejudice investigations, if a public authority has requested non-disclosure, or if the FI cannot contact former representatives using their last known contact details.

MAS expects FIs to exercise care and implement appropriate safeguards to ensure that copies of misconduct reports are provided to the correct individuals, including verifying identities and encrypting reports sent electronically.

4. Amended Police Reporting Requirements 

Under the previous Notices, FIs were expected to lodge a police report for acts involving fraud, dishonesty or other offences of a similar nature, and where they had not done so, to notify MAS of the reasons for their decision. To enable MAS to conduct timely assessment on whether to take regulatory or supervisory action on the representative upon conclusion of the police investigation, the Revised Notices have added an extra requirement for FIs to update MAS of the outcome of the police investigations no later than 21 days after they become aware of the outcome.

5. Other clarifications

MAS has provided the following additional clarifications in its Response to Feedback:

• Application of the revised Notice SFA 04-N11 to Registered Fund Management Companies (“RFMCs”): The RFMC regime has been repealed with effect from 1 August 2024, so the revised SFA Notice is no longer applicable to RFMCs;

• Submission of misconduct reports and updates on misconduct reports and investigation reports (“Update Reports”): The misconduct reporting requirements apply only to applicable representatives and broking staff as defined in the Revised Notices. Where misconduct involves both a designated investment product and a long-term accident and health policy, FIs should report under both the FAA and the IA. FIs must submit an Update Report within 21 calendar days from when they become aware of police investigation outcomes or criminal proceedings. The provision of misconduct reports to representatives or the mere continuation of internal investigations are not significant developments requiring submission of an Update Report;

• Withdrawal of misconduct reports: FIs may withdraw misconduct reports submitted to MAS, though this should be infrequent. Where misconduct is found to be unsubstantiated and withdrawn, FIs need not disclose the fact that the misconduct report was filed and withdrawn in reference check responses; 

• Corrective actions: The Revised Notices require FIs to establish robust disciplinary action frameworks with expanded corrective action types including clawback, retraining, and enhanced supervision and monitoring, and to identify root causes of misconduct to implement remedial measures. FIs must submit Update Reports only when taking new corrective actions or actions materially different from those previously specified; and

• Record keeping requirement: FIs must keep records for not less than five years in physical or electronic form, provided that electronic records are readily accessible and retrievable in a readable format. 

Next steps

With the one-year transition period before the Revised Notices take effect on 1 January 2027, FIs should review and update internal policies and procedures for misconduct investigations and reporting in order to be compliant with the Revised Notices.