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In brief

In a joint response to a public forum letter, the Monetary Authority of Singapore (MAS) and the Cyber Security Agency of Singapore (CSA) announced that they are considering requiring vendors to obtain national cybersecurity certifications, namely the Cyber Essentials or Cyber Trust mark, before they can be licensed or bid for government contracts involving access to sensitive data or systems.

This move follows a recent data breach involving a third-party vendor and underscores the growing regulatory focus on third-party cybersecurity risks.


In more detail

The joint statement by the MAS and CSA, published on 21 April 2025, was issued in response to a forum letter in The Straits Times that raised concerns about third-party cybersecurity vulnerabilities.

In their response, the MAS and CSA acknowledged the importance of extending cybersecurity standards beyond an organization’s internal systems to include its third-party service providers. They reiterated that financial institutions are already expected to implement stringent controls over vendors handling customer data and to regularly assess the adequacy of these controls.

More significantly, the agencies revealed that they are assessing the possibility of making the CSA’s Cyber Essentials or Cyber Trust mark a mandatory requirement for vendors seeking to be licensed or to participate in government procurement processes involving sensitive data or systems.

These marks are part of Singapore’s national cybersecurity certification framework:

  • Cyber Essentials Mark: Designed primarily for small and medium enterprises (SMEs), this certification outlines baseline cybersecurity measures that organizations should implement to protect against common threats and enhance digital resilience, in the key areas of cloud security, operational technology security and AI security.
  • Cyber Trust Mark: Aimed at organizations with more extensive digitalized business operations that are likely to have higher risk levels, this certification involves a more comprehensive assessment of cybersecurity practices, governance and risk management.

Attaining the Cyber Essentials or Cyber Trust mark demonstrates an organization’s commitment to robust cybersecurity practices, enhancing its reputation and trust among customers.

The agencies also highlighted support schemes to help organizations meet these standards. For instance, CSA’s Chief Information Security Officer-as-a-Service program offers up to 70% co-funding for eligible SMEs to implement cybersecurity measures aligned with the Cyber Essentials Mark.

The agencies emphasized that all organizations, including vendors, must take a proactive approach to cybersecurity, especially when entrusted with sensitive data or access to critical systems.

Key takeaways

This initiative is part of a broader effort by the CSA and sectoral regulators like the MAS to raise cybersecurity standards across the ecosystem.

If the MAS and CSA eventually require vendors to obtain the Cyber Essentials or Cyber Trust mark as a condition for licensing or bidding for government contracts involving sensitive data, this would represent a significant shift from voluntary to mandatory certification.

While there have not been any further announcements regarding implementation, interested businesses should begin assessing their readiness to obtain the relevant certifications.

Overall, this announcement is consistent with Singapore’s broader strategy to strengthen digital trust and resilience. It also shows that supply chain cybersecurity is “top of mind” for regulators, and demonstrates their increasing focus on the cybersecurity posture of vendors and service providers.

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For further information and to discuss what this development might mean for you, please get in touch with your usual Baker McKenzie contact.

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Author

Andy Leck is a distinguished senior legal practitioner in Intellectual Property and Technology, Media and Telecommunications (TMT) matters. He is the head of the Intellectual Property and Technology (IPTech) Practice Group in Singapore, and serves as the Asia Pacific head of Baker McKenzie's TMT Industry Group. Andy is widely recognized by reputable global industry and legal publications as a leader in his field. He was named on "The A-List: Singapore's Top 100 lawyers" by Asia Business Law Journal since 2018. Chambers Asia Pacific notes that Andy as "a well-known IP practitioner who is highlighted for his record of handling major trade mark litigation, as well as commercial exploitation of IP rights in the media and technology sectors. He's been in the industry for a long time and has always been held in high regard. He is known to be very fair and is someone you would like to be in the trenches with you during negotiations." Furthermore, Asian Legal Business acknowledges Andy as a leading practitioner in his field and notes that he “always gives good, quick advice, [is] client-focused and has strong technical knowledge for his areas of practice.” Under his leadership, the TMT team in Singapore is highly regarded for its expertise in “outsourcing, cloud computing and TMT IP-related mandates” and “data privacy, compliance, technology and telecoms regulations.” Andy was appointed by the Intellectual Property Office of Singapore (IPOS) as an IP Adjudicator to hear IP disputes between 2021 and 2023. He has been an appointed member of the Singapore Copyright Tribunal since May 2010 and a mediator with the WIPO Arbitration and Mediation Center, as well as the Singapore Mediation Centre.

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Ren Jun Lim is a principal with Baker McKenzie Wong & Leow. He represents local and international clients in both contentious and non-contentious intellectual property matters. He also advises on a full range of healthcare, as well as consumer goods-related legal and regulatory issues. Ren Jun co-leads Baker McKenzie Wong & Leow's Healthcare as well as Consumer Goods & Retail industry groups. He sits on the Law Society of Singapore IP Committee and on the Executive Committee of the Association of Information Security Professionals. He is also a member of the Vaccines Working Group, Singapore Association of Pharmaceutical Industries, a member of the International Trademark Association, as well as a member of the Regulatory Affairs Professionals Association. Ren Jun is ranked in the Silver tier for Individuals: Enforcement and Litigation and Individuals: Prosecution and Strategy, and a recommended lawyer for Individuals: Transactions by WTR 1000, 2020. He is also listed in Asia IP's Best 50 IP Expert, 2020, recognised as a Rising Star by Managing IP: IP Stars, 2019 and one of Singapore's 70 most influential lawyers aged 40 and under by Singapore Business Review, 2016. Ren Jun was acknowledged by WTR 1000 as a "trademark connoisseur who boasts supplementary knowledge of regulatory issues in the consumer products industry." He was also commended by clients for being "very responsive to enquiries and with a keen eye for detail, he is extremely hands-on. His meticulous and in-depth approach to strategising is key to the excellent outcomes we enjoy."

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Ken Chia is a member of the Firm’s IP Tech, International Commercial & Trade and Competition Practice Groups. He is regularly ranked as a leading TMT and competition lawyer by top legal directories, including Chambers Asia Pacific and Legal 500 Asia Pacific. Ken is an IAPP Certified International Privacy Professional (FIP, CIPP(A), CIPT, CIPM) and a fellow of the Chartered Institute of Arbitrators and the Singapore Institute of Arbitrators.

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Sanil is a local principal in the Intellectual Property & Technology Practice Group in Baker McKenzie Wong & Leow. Sanil is qualified in both Singapore and Australia, and is a Certified Information Privacy Professional (CIPP/A) by the International Association of Privacy Professionals. Sanil is recognized as a Rising Star by both Legal 500 Asia Pacific in the Intellectual Property: Local Firms category as well as by IP Stars for his advisory work in the IP space. Sanil is also recommended by World Trademark Review 1000 for IP enforcement, litigation, prosecution and strategy.

Author

Daryl Seetoh is a local principal in the Intellectual Property & Technology (IPTech) Practice Group in Singapore. He is a qualified lawyer in Singapore, and is a fellow and certified member of the International Association of Privacy Professionals (FIP, CIPP(A), CIPP/E, CIPM). Daryl has been recognised by Chambers Asia Pacific, Singapore as an "Associate to Watch" for Technology, Media, Telecoms (TMT): International work in 2025. Clients commended that "Daryl is an excellent attorney," and he is "very knowledgeable about data privacy laws throughout the Asia Pacific region, and is able to provide very good, consolidated advice." Daryl has previously worked at Baker McKenzie’s San Francisco office and has also been seconded to financial institution and technology multinational clients.