MAS responds to feedback on proposed enhancements to Product Highlights Sheet requirements and complex products framework

4 June 2026

On 15 May 2026, the Monetary Authority of Singapore (“MAS”) published its response to the feedback received on its consultation paper published on 1 July 2025 (“Response”) on proposed enhancements to the Product Highlights Sheet (“PHS”) requirements and the complex products framework.

MAS’ objective for the proposed changes is to strengthen the effectiveness of a disclosure-based regime for investors to make informed choices on their own, while requiring an appropriate level of intervention for consumers who need more assistance. To read more about the consultation paper, please refer to our article titled “MAS consults on proposed enhancements to Product Highlights Sheet requirements and the complex products framework”.

MAS will consult on legislative amendments to implement the changes to the complex products framework at a later date.

This article provides highlights from the Response.

Enhancements to PHS

Set out below are highlights from the Response in relation to the design and content enhancements to PHS templates. The revised PHS templates can be found in Annex D to the Response.

  • Changes to current presentation of yellow rectangular strip on each page of a PHS: MAS will require the colour, width, and length of the heading band to be standardised for all PHSes. Following feedback, MAS will shrink the width of the heading band to provide for a placeholder for the company logo.
  • Introducing a red-coloured indicator in PHSes of complex products: MAS will proceed with the use of a red-coloured heading band across the top of the first page of the PHS with the words “PRODUCT HIGHLIGHTS SHEET” for PHSes of specified investment products (“complex products”). A lighter shade of red will be used to avoid causing excessive alarm. MAS will also add the words “This is a COMPLEX product” just below the heading band.
  • Use of diagrams to illustrate investment strategy and fees payable for CIS/ILP sub-funds: MAS proposed the disclosure of the investment strategy and fees payable in the form of diagrams for the PHSes of collective investment schemes (“CIS”) (excluding REITs) and sub-funds of investment-linked policies (“ILP”) (“CIS/ILP sub-funds”). Following feedback, MAS will not mandate the diagrams/disclosures on fund size, top 10 holdings, and percentage asset allocations. Instead, issuers are encouraged to include in the PHS a hyperlink or QR code to where investors may access the latest fund information. MAS will proceed to mandate the use of diagrams to illustrate the amount invested into the fund after accounting for initial and recurring charges. The use of diagrams and illustrations will be optional for other sections of the CIS/ILP sub-funds PHS, with the exception of a diagram to illustrate the key parties involved in the structure of the CIS/ILP sub-funds.
  • Introductory statements: MAS will proceed with the proposed introductory statements, which include the phrasing of “you should not purchase… if you do not understand…” to caution prospective investors against investing if they do not understand or are not comfortable with the product/risks.
  • Complexity disclosure statement: MAS will proceed with the proposed wording for the complexity disclosure statement to be included for all redesigned PHSes. Samples of the disclosure statement for complex and non-complex products were provided in the consultation paper.
  • Financial ratios: MAS will proceed to require disclosure of financial ratios of the issuer and guarantors for the PHS of equity securities, hybrid instruments, debt securities, post-seasoning bonds, and exempt bonds. Issuers may choose to disclose the financial ratios of only the guarantor, instead of both the issuer and guarantor, where this would be more meaningful for investors. MAS will set out general principles to guide issuers in their choice of financial ratios. Issuers should consider industry convention in determining the formula for calculating the financial ratios chosen and explain how the ratio is used in assessing the issuer’s financial health.
  • Issuer’s (and guarantor’s) asset and revenue profile: MAS will proceed with its proposal to require disclosure of the asset and revenue profile of the issuer and guarantors for the PHS of equity securities, hybrid instruments, and debt securities, where such offers are made in or accompanied by a prospectus only, and to the extent that such information can be found in the issuer’s financial statements. Where an issuer has chosen not to disclose segment and geographical assets in its financial statements, issuers can indicate the disclosure of such information is not applicable in the PHS.
  • Business strategies and future plans of issuer: MAS will proceed with its proposal to remove the requirement to disclose business strategies and future plans for the PHS of hybrid instruments. 

New PHS requirements for ILPs and classification of ILPs as complex products

PHS requirements for ILPs

MAS will proceed with the introduction of the ILP-PHS as it is useful in helping consumers understand an ILP by providing a concise overview of the key risks and features of the ILP. The main objective of the ILP-PHS is to enhance disclosure of ILP fees and charges, which are not fully captured in the existing ILP sub-fund PHS. To enhance readability and consumer understanding, MAS will amend the ILP-PHS template instructions to require financial institutions (“FIs”) to include cross references in the ILP-PHS directing consumers to the relevant sections in the product summary which set out additional disclosures.

Classification of ILPs as complex products

MAS will proceed to classify ILPs as complex products as there is merit in standardising the complexity labelling of ILPs to reflect their inherent structural complexity regardless of the underlying sub-funds. Following feedback, MAS will include disclosure on why an ILP is complex and how this can be different from the ILP sub-fund.

Applicability to portfolio bonds

Following requests for clarity, MAS will review the applicability of the ILP-PHS template for portfolio bonds and consult the industry subsequently.

Review of complex products framework

Changes to nomenclature

MAS will proceed to revise the terms “Excluded Investment Product” (“EIP”) and “Specified Investment Product” (“SIP”) to “non-complex product” and “complex product” respectively. MAS will also combine the current Customer Knowledge Assessment and Customer Account Review (“CAR”) into a single set of criteria termed the Customer Knowledge Assessment (“CKA”) which will be applicable to both listed and unlisted complex products.

Knowledge and experience assessment for complex products

  • Separate knowledge and experience assessment not required for advised transactions: MAS will proceed to remove the CKA requirement for advised transactions (including digital advisory platforms). However, financial advisers continue to be responsible for ensuring investors understand the key risks and features of the product, taking into account their product knowledge and experience when assessing the complex product’s suitability. For execution-only transactions in complex products, the CKA requirement will remain in place.
  • PKA as alternative assessment to CKA: MAS will not proceed with the introduction of the Product Knowledge Assessment (“PKA”) as an alternative way to evaluate an investor’s knowledge of complex products given the implementation concerns raised, including cost concerns and operational complexities in administering the PKA, in addition to a CKA. MAS will retain the existing SIP learning modules as an optional resource for investors. Investors can choose not to undergo the learning modules, but those that pass any of the existing SIP learning modules will be considered as having passed the CKA.
  • Non-expiry of CKA pass outcome: MAS will proceed to allow a pass outcome in the CKA to be valid perpetually and not expire in relation to the investor’s account with the FI.
  • Removal of mandatory advice for investors who did not pass CKA: MAS will proceed to remove mandatory advice for investors who do not pass the CKA on execution-only platforms. This will give investors greater autonomy in deciding whether to seek financial advice before transacting in complex products, notwithstanding their lack of knowledge and experience. To help investors make an informed choice, FIs will be required to alert investors prior to execution that an investment product is complex.

Alerts

MAS consulted on FIs providing a complexity disclaimer alert to all investors prior to any transaction of a complex product, and for FIs to issue a suitability warning for investors who are assessed as lacking in knowledge and experience in complex products, prior to any transaction of a complex product.

Following feedback about the efficacy of such alerts, particularly where multiple transactions are carried out within a short period of time, MAS will streamline the complexity disclaimer and suitability warning alerts:

  • One-off suitability warning at point of CKA: Where the investor does not meet the CKA criteria, FIs must (i) inform the investor of the CKA outcome; (ii) warn the investor that complex products may not be suitable for him; and (iii) encourage the investor to review the optional learning module.
  • Pre-transaction complexity disclaimer: FIs must provide a complexity disclaimer which all investors must acknowledge prior to every transaction in complex products. The complexity disclaimer will be simplified and must include the following prompts:

(i)  This is a complex product.

(ii)  Please review the product documents.

(iii)  If you do not understand its features, you are encouraged to review the [name or link to the learning modules] or seek advice.

For advised transactions, financial advisers only need to convey (i) and (ii) of the disclaimer.

Safeguards for certain clients

MAS will proceed to require identification of Selected Clients and full financial advice for all Selected Clients who wish to transact in complex products on execution-only platforms.

However, MAS will allow Selected Clients who pass the CKA (including those who passed one of the existing SIP learning modules) to opt out from seeking financial advice and proceed to transact in complex products. FIs will be required to document the Selected Client’s opt-out decision. After opting out, the Selected Client may proceed to invest without advice for all future complex product transactions. Selected Clients who have previously fulfilled the CKA/CAR criteria can be considered as having passed the new CKA.

A “Selected Client” is a client who meets any two of the following criteria: (i) is 62 years of age or older; (ii) is not proficient in spoken or written English; (iii) has below GCE “O” or “N” level certifications, or equivalent academic qualifications; other than a client who meets any two of the criteria and has been assessed by the FI to possess adequate investment experience and knowledge to transact in the investment product recommended.

Transition period

The new PHS requirements for investment products and ILPs will take effect alongside the revised distribution safeguards and revised product classifications under the complex products framework. MAS will consult on the legislative changes to implement the complex products framework requirements and will seek feedback on the appropriate transition period from the time the legislative instruments are issued in that forthcoming consultation paper. MAS acknowledged the feedback that at least 12 months was required to implement the changes.

MAS clarified that managers of CIS (excluding REITs) do not need to update all PHSes of existing funds to the revised templates on the effective date. Instead, the PHSes of existing CIS (excluding REITs) will need to incorporate the revised templates when the accompanying updated prospectus is lodged on or after the effective date.

Reference materials

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