MAS responds to feedback on proposed amendments to advertisement regulations and introducer notice to enhance safeguards for digital advertising activities

17 June 2026

On 22 May 2026, the Monetary Authority of Singapore (“MAS”) issued a second Response to feedback received from its consultation paper published on 25 April 2023 on “Enhancing Safeguards for Proper Conduct of Digital Prospecting and Marketing Activities” (“Consultation Paper”).

In the Consultation Paper, MAS sought feedback on its proposal to issue Guidelines on Standards of Conduct for Digital Prospecting and Marketing Activities (“Guidelines”) setting out MAS’ expectations on financial institutions (“FIs”) to conduct digital advertising activities in a responsible and professional manner.

MAS also proposed amendments to the Financial Advisers Regulations and the Securities and Futures (Licensing and Conduct of Business) Regulations (collectively, “Advertisement Regulations”) to extend the application of the regulatory requirement for FIs’ approval of product advertisements to non-product advertisements and require FIs and their representatives to state their identities in advertisements. MAS further proposed to refine the requirements in Notice FAA-N02 on Appointment and Use of Introducers (“Notice FAA-N02”) to strengthen FIs’ oversight and control of activities conducted by lead generation firms and enhance safeguards for proper handling of customers’ data.

On 25 September 2025, MAS issued its Response to feedback received on the Guidelines and published the Guidelines on Standards of Conduct for Digital Advertising Activities. In the Response issued on 22 May 2026, MAS sets out its response to feedback received on the proposed amendments to the Advertisement Regulations and Notice FAA-N02.

For more on the Consultation Paper, please refer to our article “MAS proposes enhanced safeguards for prospecting and marketing of financial products”. For more on the Guidelines on Standards of Conduct for Digital Advertising Activities, please refer to our article “MAS publishes Guidelines on Standards of Conduct for Digital Advertising Activities to promote responsible online financial content sharing and advertising”.

This article provides key highlights from the Response issued by MAS on 22 May 2026.

Amendments to Advertisement Regulations

Non-product advertisements

MAS has clarified that product and non-product advertisements include those disseminated in respect of an FI’s products or services, such as those posted by the FI’s representatives. The guidance in the Frequently Asked Questions on Fair and Balanced Advertising and Other Advertising Restrictions on whether certain types of publications or communications are considered “advertisements” will continue to apply.

FI’s approval of non-product product advertisements

MAS will proceed with the proposal to extend the existing requirements for FIs’ approval of product advertisements to non-product advertisements. MAS clarified that senior management of FIs is not expected to personally review every non-product advertisement and may delegate their responsibilities for approving non-product advertisements to other competent personnel or committees. However, senior management remains accountable for ensuring that their FIs’ advertisements comply with the Advertisement Regulations.

While FIs may adopt a risk-proportionate approach to designing and implementing approval processes for non-product advertisements, the FIs’ senior management should exercise appropriate oversight to ensure the frameworks are robust and delegated responsibilities are effectively carried out.

MAS clarified that the Advertisement Regulations apply to all advertisements disseminated by or on behalf of the FIs, regardless of where the content is produced or coordinated from. Therefore, senior management of the FIs remains responsible for ensuring that advertisements disseminated by or on behalf of the FI comply with the Advertisement Regulations.

Disclosure of identities of FIs and/or representatives in advertisement

MAS will proceed with the proposed requirement for FIs to state their names as listed in the Financial Institutions Directory (“FID”) at least once when disclosing their identities in advertisements. This will help consumers verify the licensing status of FIs and guard against dealing with unregulated entities. FIs may use shortened or alternative names provided the official FID-listed name appears at least once in the same advertisement.

Following feedback, MAS agrees that it may not be necessary for representatives to disclose both their names and representative numbers in advertisements, as the representative number suffices as a unique identifier for each representative. Hence, MAS will remove the proposed requirement for representatives to disclose their names as set out in the Financial Institutions Representatives Register.

The identity disclosure requirement applies to all forms of advertisement. Representatives of an FI reposting or sharing that FI’s advertisements on social media are considered as disseminating advertisements on the FI’s behalf and must therefore disclose their identity.

MAS will not prescribe the specific methods for identity disclosures. FIs may adopt disclosure practices that are appropriate, provided disclosures are clear and prominent. In the Response, MAS provides examples of appropriate disclosure in the context of social media platforms and other third-party platforms.

Pre-existing advertisements

Given the operational challenges in amending pre-existing advertisements, MAS will not proceed with requiring advertisements published before the effective date of the updated Advertisement Regulations to comply with the new requirements. However, FIs are strongly encouraged to review and update pre-existing advertisements which continue to be actively disseminated, to ensure alignment with the updated requirements.

Enhancements to Notice FAA-N02 on appointment and use of introducers

MAS proposed amendments to Notice FAA-N02 to require FIs to monitor the activities and conduct of lead generation firms, and to ensure that the manner in which lead generation firms collect, use, or disclose consumer data is in line with the FI’s own data management policies and applicable laws.

Handling of consumer data and written agreements with introducers

MAS will not proceed with the proposal requiring data collected by introducers to be handled in accordance with FIs’ data management policies. MAS notes that introducers collect a limited set of consumer information (such as names, dates of birth, and contact numbers), and it is not necessary for such data to be subject to the FI’s full data management framework. Instead, FIs should ensure that their written agreements with introducers clearly specify how introducers should collect, disclose, and dispose of consumer data.

FIs should assess whether their current written agreements with introducers comply with the new requirements and must sign new agreements if deficiencies are identified. MAS will not prescribe the details to be included in the written agreements. FIs should adopt a risk-based approach to ensure that the level of oversight and controls is commensurate with the materiality and scope of the introducing activities performed.

Approval of introducers’ advertisements

MAS states in its Response that product or non-product advertisements disseminated by introducers on behalf of FIs fall within the scope of the Advertisement Regulations. Accordingly, these advertisements are required to be approved by the FI’s senior management or their delegates.

Application of Notice FAA-N02 to long term accident and health policies

MAS explains that while Notice FAA-N02 does not apply to long-term accident and health policies, FIs are strongly encouraged to apply the same requirements when they engage introducers to generate leads for such policies.

Implementation timeline

MAS will provide a nine-month transition period from the date of issuance of the updated Advertisement Regulations and Notice FAA-N02. On 6 May 2025, MAS issued a consultation paper proposing to remove product advertisement exclusions under the Advertisement Regulations (“Exclusions Removal Consultation”). MAS will issue the response to the Exclusions Removal Consultation and the updated Advertisement Regulations incorporating changes from this consultation and the Exclusions Removal Consultation, at the same time. The nine-month transition period will commence from the date of issuance of the updated Advertisement Regulations and Notice FAA-N02.

For more on the Exclusions Removal Consultation, please refer to our article “MAS consults on proposed revisions to financial advertisement regulations to remove existing exclusions”.

Reference materials

The Response to Amendments to Advertisement Regulations and Introducer Notice is available on this webpage of the MAS website www.mas.gov.sg.