On 30 December 2025, the Monetary Authority of Singapore (MAS) issued revised Notices on Reporting of Misconduct of Representatives (the "Misconduct Notices") under the Securities and Futures Act ("SFA"), Financial Advisers Act ("FAA") and Insurance Act ("IA"). The MAS also issued a circular to all Chief Executive Officers on the same day in relation to the revised regime.

The revised regime follows various rounds of consultation by the MAS in as early as July 2018, which the MAS released its feedback in May 2021 to responses received. A further consultation paper was released by the MAS in April 2022, which the MAS released its feedback in December 2025 while concurrently issuing the revised Notices.

We have been closely monitoring the consultation process and proposals by the MAS over the years, alongside developments on the topic in other jurisdictions. We set out below a summary of the key changes which are important for financial institutions ("FIs") to note, in preparing to comply with the revised Misconduct Notices when they come into effect on 1 January 2027.

Key changes to the misconduct reporting regime

(1) Revisions to the categories of reportable misconduct

The key changes include:

• Clarification that the reportable categories involving fraud or dishonesty specifically include acts of illegal monetary gains, bribery, money laundering and tax evasion.
• Removal of reportable categories in relation to: (i) failure to satisfy the MAS Guidelines on Fit and Proper Criteria; and (ii) misconduct which results in non-compliance of regulatory requirements or where there is a serious breach of the FI's internal policy or code of conduct.

In relation to the removal of the reportable categories above, MAS has stated in its response to feedback received in the consultation that:

• As mentioned in the MAS Fit and Proper Guidelines, the inability of an individual to meet a specific criterion does not automatically render him not fit and proper. FIs should not adopt a check-box approach and automatically file a misconduct report for every representative who is not able to meet any single factor mentioned in the Fit and Proper Guidelines. Instead, FIs will need to holistically consider the facts and circumstances of the act committed by the representative, and determine if it constitutes a misconduct that falls within one of the reportable categories.
• It is MAS’ intention for acts, which have elements of dishonesty, as well as harm to clients and to the financial  industry, to be reportable. For all other misconduct, FIs are expected to assess accordingly and put in place proper monitoring mechanisms and additional controls where applicable. (For example, inappropriate workplace behaviour, if carried out in the representative's personal capacity and did not result in any client detriment, is not reportable in the absence of aggravating factors.)

This means that non-financial misconduct are generally unlikely to be reportable under the new regime. Notably, the approach contrasts with that taken by the UK FCA, where non-financial misconduct may lead to enforcement action by the FCA (see our latest Clifford Chance briefing at: Non-financial misconduct in financial services regulation –where do we stand?). Given the evolving approaches amongst different jurisdictions, FIs should be conscious that the requirements may be different across jurisdictions and take a strategically calibrated approach where the misconduct and representative involved has multi-jurisdictional implications.

(2) Revisions in timeframe

The current Misconduct Notices require FIs to submit a misconduct report to the MAS within 14 days 'upon discovery' of the reportable misconduct. The timeline is extended to 21 days under the revised Notices when the FI has 'reasonable grounds to believe' that there is reportable misconduct.

FIs will be required to submit an updated report no later than 21 days after the date of occurrence of any significant development, which includes any notification received by the FI of the outcome of any police or criminal investigations. Under the current Notices, there is no specific timeline applicable in relation to the submission of updated reports, or to update the MAS of the outcome of police or criminal investigations into the misconduct.

(3) Providing representatives with a copy of the misconduct report

FIs will be required to provide representatives with a copy of the misconduct report within 21 days after submission to the MAS. The objective is to allow representatives to be aware of such misconduct reports, in order to enable them to make full and accurate disclosures when applying to join a new FI.

However, the requirement does not apply if disclosure to the representative would prejudice its internal investigations or regulatory and criminal investigations.

Next steps

FIs should review their current misconduct reporting policies and procedures to align with the new Notices, when they come into operation on 1 January 2027. In particular, FIs should be conscious of potential divergent approaches on reporting of non-financial misconduct across jurisdictions.