MAS consults on proposed enhancements to Product Highlights Sheet requirements and the complex products framework

30 July 2025

On 1 July 2025, the Monetary Authority of Singapore (“MAS”) published its consultation paper on “Enhancements to Product Highlights Sheet (PHS) Requirements and the Complex Products Framework”. The consultation closes on 1 September 2025.

On 3 November 2023, MAS responded to the consultation on Proposed Changes to Complex Products Regime and indicated it would conduct a broader review of the framework and of product disclosure enhancements.

This consultation paper presents MAS’ proposals, with respect to the broader review, in two parts:

  • Part A: Enhancements to the Product Highlights Sheet (“PHS”)
  • Part B: Review of the Complex Products Framework

Set out below is an outline of the changes proposed by MAS.

Outline of proposed changes

A.      Enhancements to PHS

1.      Design and content enhancements to PHS templates

a.      Design enhancements to PHS

  • Changes to current presentation of yellow rectangular strip on every page of a PHS
  • Introducing red-coloured indicator for specified investment products (to be renamed as “complex products”)
  • Use of diagrams to illustrate investment strategy and fees payable for collective investment schemes (excluding real estate investment trusts) and sub-funds of investment-linked policies (“ILPs”)

b.      Enhancements to prescribed content in the PHS

  • Introductory statements
  • Complexity disclosure statement
  • Financial ratios
  • Asset and revenue profile of issuer and guarantor
  • Business strategies and future plans of issuer

c.       Proposed PHS templates

2.      Alignment of PHS-related legislation

3.      New PHS requirements for ILPs 

4.      Transition period for implementation 

B.      Review of the complex products framework

1.      Enhanced disclosures and simplified nomenclature

a.      More intuitive nomenclature for classifying capital markets products

b.      Distributors to clearly disclose that a product is complex

2.      Streamlined distribution safeguards for complex products

a.      Combining Customer Knowledge Assessment (“CKA”) / Customer Account Review (“CAR”) into single set of criteria termed as CKA

b.      Product knowledge assessment (“PKA”) as an alternative assessment to CKA

c.       Knowledge and experience assessment (“KEA”) not required for advised transactions

d.      Investors may proceed to invest without undergoing mandatory advisory process

e.      Mandatory advice required for Selected Clients transacting in complex products

f.        No expiry date for pass outcome in KEA

g.      Grandfathering of prior knowledge assessments (current CKA or CAR)

h.      Removal of requirement to undergo learning modules

3.      Response to feedback relating to product classifications for specific products

4.      Transition period for implementation


This article provides a summary of the changes proposed by MAS.

To read the article, please click here.

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