Singapore: Representatives Must Receive Copies of Misconduct Reports From 1 January 2027

From now on, a misconduct report will no longer go only to the regulator; it must also reach the representative being reported. The Monetary Authority of Singapore (MAS) has revised its rules on reporting misconduct by representatives, and they take effect on 1 January 2027.

From that date, firms such as financial advisers, Capital Markets Services (CMS) licence holders and insurance brokers must not only report misconduct by representatives and former representatives, but also give the representative concerned a copy of the report, keep records, conduct internal investigations and take corrective action. The existing reporting system will be discontinued on the same day.

Three notices issued together, replacing the old regime

On 30 December 2025, MAS issued three revised notices, divided by sector:

• FAA-N27: issued under the Financial Advisers Act 2001 and applicable to all licensed and exempt financial advisers.
• Notice 508: applicable to insurance brokers and to accident and health insurance intermediaries.
• SFA 04-N24: issued under the Securities and Futures Act 2001 and applicable to CMS licence holders and exempt persons. The MAS webpage also lists banks, merchant banks, finance companies and insurers conducting regulated activities under that Act.

According to a commentary by the law firm Allen & Gledhill, the old FAA-N14, Notice 504 and SFA 04-N11 will be cancelled from 1 January 2027.

Beyond reporting: investigating and informing the representative

According to the MAS webpage, FAA-N27 and SFA 04-N24 cover the same ground: reporting misconduct by representatives and former representatives, providing the representative with a copy of the report and later updates, record keeping, internal investigations and corrective action.

Allen & Gledhill notes that a firm that has begun an internal investigation into alleged misconduct must submit the investigation report together with the misconduct report, and must also submit a copy of any police report. Firms must also give the representative a copy of the report and subsequent updates within the prescribed timelines.

The consultancy Ocorian offers further detail, but its analysis is a third-party interpretation that this article has not been able to check against the full text of the notices. According to Ocorian, misconduct under SFA 04-N24 is narrowed to market conduct breaches (for example, insider trading) and conduct involving fraud, dishonesty or illicit financial gain (for example, bribery and money laundering). A firm must report once it has reasonable grounds to believe that misconduct has occurred, without first establishing liability.

Ocorian adds that the reporting deadline is 21 days, replacing the previous 14 days, and that material developments such as a police report or a change in investigation findings must also be updated within 21 days. A copy must likewise be provided to the representative within 21 days, except where disclosure would impede the investigation or the person cannot be contacted. The guidance accompanying the notices also covers fair appeal procedures and proportionate corrective action such as suspension, dismissal, clawback of remuneration, retraining and closer supervision.

From the 2018 consultation to 2027

1. 6 July 2018: MAS issued a consultation paper.
2. 14 May 2021: MAS published its response to the feedback.
3. 19 April 2022: MAS held a further consultation on the related legal amendments.
4. 30 December 2025: MAS published the revised notices and its response to the 2022 consultation.
5. 24 August 2026: MAS issued a circular announcing that the existing reporting system will be discontinued from 1 January 2027, and published FAQs.
6. 30 September 2026: MAS published a misconduct report template and an investigation report template (Word documents), addressed to financial advisers, CMS entities, insurance brokers and licensed direct insurers.
7. 1 January 2027: the new notices take effect and the existing system is discontinued.

Analysis: what it means for recruitment teams

The following is editorial analysis. MAS materials do not directly regulate background checks in hiring, so what follows is inference.

The new regime covers former representatives, and firms must take corrective action after an investigation. For recruitment teams in Singapore, background checks on people who have worked at other firms may need to be more careful, for example by finding out whether a candidate is involved in an ongoing investigation at a previous employer.

Exit processes also merit a fresh look. A representative's departure does not end the firm's reporting obligations. If a former representative needs to be contacted later, the contact details and records kept at the time of departure become critical.

The templates have been published and the effective date is not far off. A practical approach is to use the two templates now to review internal investigation, record keeping and exit procedures, rather than wait for the first case to arise.

Compiled by the F50 Editorial Team from public sources, for general reference only and not professional advice. Details are correct as of the publication date and may change.