MAS responds to feedback on proposed capital treatment for structured products and infrastructure investments for insurers

27 November 2025

On 28 October 2025, the Monetary Authority of Singapore (“MAS”) published its response to feedback received on its consultation paper, published on 18 October 2024, on the proposed capital treatment for structured products and infrastructure investments for insurers (“Response”). MAS also announced that it will revise MAS Notice 133 on Valuation and Capital Framework for Insurers (“Notice 133”), with the finalised capital treatment for structured products and infrastructure investments expected to take effect from 31 March 2026.

In its consultation paper, MAS proposed to finetune the enhanced risk-based capital framework for insurers in Singapore by:

  • introducing a differentiated capital treatment for infrastructure investments; and
  • revising the capital treatment of structured products, including those which are infrastructure in nature.

For more on the consultation, please read our article “MAS issues consultation paper on capital treatment for structured products and infrastructure investments for insurers”.

Structured products

In the Response, MAS said that it will proceed with its proposal to:

  • remove the option to apply a 50% risk charge on the entire market value of the investment;
  • recognise the credit rating assigned by recognised external credit assessment institutions to the tranche of the securitised assets;
  • maintain a 50% loading for rated debt-based securitised assets, and for rated non-debt based securitised assets, a loading of 300% for investment grade (“IG”) securities and 500% for non-IG securities; and
  • classify certain structured products as non-standard instruments.

Infrastructure investments

Definition and criteria

Following feedback, MAS will adopt the definition aligned with the Insurance Capital Standard (“ICS”) by replacing “Regulated assets” with the categories “Water utilities”, “Waste management utilities”, and “Energy (including electricity and gas utilities)” under the examples on what qualifies as infrastructure. There are also other changes to the examples on definitions to better address feedback and ensure closer alignment with ICS’ definitions.

MAS will proceed with the proposed qualifying criteria for infrastructure assets to be eligible for differentiated capital treatment, with some amendments following feedback. In addition, MAS acknowledges that not all the qualifying criteria can be met fully for some infrastructure projects. In this regard, MAS has been collaborating with relevant stakeholders on a pilot program aimed at facilitating insurers’ investments into sustainable infrastructure projects, subject to a risk-appropriate level of capital charges, and necessary safeguards such as investment caps. This pilot aims to serve as a testbed to build up insurers’ knowledge and experience in investing in sustainable infrastructure assets. Details on this pilot project will be shared with the industry shortly.

MAS will extend the differentiated capital treatment applied to infrastructure projects to infrastructure corporates. To provide clarity on the definition of infrastructure corporates, MAS will include guidance in Notice 133 that a substantial majority is taken to mean at least a 75% level. This would include companies that invest exclusively or nearly exclusively in infrastructure projects across one or multiple sectors.

Proposed capital treatment

MAS will proceed with its proposal to:

  • introduce correlation factors for equity sub-asset classes to recognise diversification benefits between infrastructure equities and other equities; and
  • allow look-through for infrastructure investment in a fund structure, similar to collective investment schemes as specified in Appendix 4B of Notice 133.

MAS will reduce the minimum period for unrated infrastructure debt investments from five years to three years.

Reference materials

The following materials are available on the MAS website www.mas.gov.sg: