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Singapore: MAS consults on proposed revisions to remove exemptions under the financial advertisement regulations

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In brief

On 3 May 2025, the Monetary Authority of Singapore (MAS) issued a consultation paper proposing to remove the current exclusions under the Financial Advisers Regulations (FAR) and the Securities and Futures (Licensing and Conduct of Business) Regulations (SF(LCB)R) that exempt certain financial institutions from complying with advertising regulations (“2025 Consultation“).

This proposal is part of MAS’s broader initiative to enhance market conduct standards, following its 2023 Consultation Paper on Enhancing Safeguards for Proper Conduct of Digital Prospecting and Marketing Activities (“2023 Consultation“). In the 2023 Consultation, MAS proposed that advertising regulations similar to those currently applicable to product advertisements be applied to non-product advertisements as well.

The proposed amendments in the 2025 Consultation are intended to take effect concurrently with the legislative changes outlined in the 2023 Consultation.

Key takeaways

MAS is proposing to level the playing field by removing the existing exclusions from product advertisement regulations, which are based on certain types of investors and/or certain activities. The same approach will be taken with respect to non-product advertisements.

The proposed changes reflect MAS’s emphasis on reinforcing fair dealing and information transparency across all types of investors and improving regulatory consistency.

MAS is seeking feedback on the 2025 Consultation until 11:59 pm on 5 June 2025. If you have any feedback or questions, please let us know. 

Existing exclusions

Currently, FAR Regulations 22(7)(a) and (c) and SF(LCB)R Regulations 46(7)(b) and (d) provide various exclusions from the product advertisement regulations, including product advertisements provided to certain types of investors or in connection with certain types of activities, such as dissemination or publication of information in connection with the following:

  • Advising institutional investors or related corporations on investment products.
  • Advising accredited or expert investors on bonds.
  • Advising on spot foreign exchange contracts other than for the purposes of leveraged foreign exchange trading.
  • Offering securities or units in collective investment schemes to accredited investors and institutional investors or in reliance on certain other prospectus exemptions.

Removal of advertising exclusions

MAS proposes to do the following:

  • Remove the exclusions in FAR Regulations 22(7)(a) and (c) and SF(LCB)R Regulations 46(7)(b) and (d), such that all product advertisements must comply with the applicable requirements.
  • Apply similar uniform standards to non-product advertisements.

MAS takes the following view: 

  • The principles of fair dealing and transparency should apply universally to all investors, and all investors should be given reliable and accessible information to enable them to make informed decisions. 
  • All financial advertising should convey information that is accurate, balanced and legible, irrespective of the type of product or the target audience.
  • Consistency between product and non-product advertisements is essential to prevent information asymmetry and risks of misinformation. 

The above is not intended to be exhaustive or to constitute legal advice.

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Stephanie Magnus co-heads the Asia Pacific Financial Institutions Group and heads up the Financial Services Regulatory Practice Group in Singapore. Stephanie is ranked Band 1 for FinTech in Singapore by Chambers FinTech 2020. She is also ranked as a Leading Individual for Financial Services Regulatory: Local Firms in Singapore by Legal 500 Asia Pacific 2020. She is recognised as a leading lawyer for Banking & Finance: Regulatory in Singapore by Chambers Asia Pacific and Chambers Global 2020. Stephanie was quoted in Chambers Asia Pacific for her "timely, practical and business-oriented" advice, with a "deep understanding of the regulatory regime." She is also recognised as "very business-savvy and brilliant every time," and is admired for her "very strong grasp of the legal issues from both a technical and practical perspective."

Author

Eunice is a principal in the Financial Services Regulatory practice group of Baker McKenzie's Singapore office and a member of the Firm's Global Financial Services Regulatory Steering Committee. Eunice has extensive experience in regulatory, legal and compliance matters in the financial services and fintech sectors. Her clients include banks, investment managers, broker-dealers, payments companies and other financial institutions.
Eunice is consistently recognised as the Next Generation Partner for Financial Services Regulatory in Legal 500 Asia Pacific. Clients have described her as: “an exceptional lawyer with deep knowledge of financial services; "commercial and solutions-oriented and has an excellent relationship with the regulator which is of benefit to her clients"; "singled out for being smart and having the ability to navigate the Singapore regulatory landscape"; "is responsive, pleasant and willing to explore different parameters" and "is outstanding in that she always carefully and clearly explains the situation and background of the issue so that we can fully understand it, she always has a quick response and she has a deep understanding of the financial industry and our company."
Eunice is a frequent speaker at legal and financial industry seminars and forums. She also regularly assists clients in coordinating industry responses and participate in consultation with the Monetary Authority of Singapore on policy and legislative changes.

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