Monetary Authority Of Singapore Proposes To Enhance Product Highlights Sheets And Streamline Framework For Complex Products

The Monetary Authority of Singapore (MAS) is seeking feedback on proposals to enhance the requirements for Product Highlights Sheets and to streamline the framework for complex products.  

2 Investors today are increasingly being empowered to engage in self-directed investment, aided by the digitalisation of financial services. Nonetheless, there remain those who are less technologically or financially savvy who would be better off seeking financial advice to understand the features and risks of the products they are investing in. MAS’ objective 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.  

Proposed Product Highlights Sheet (PHS) Enhancements 
3 Financial institutions are required to provide investors with a PHS for certain offers of investment products such as shares, bonds and units in a Collective Investment Scheme.[1] MAS proposes revised PHS templates to help users better understand key product information. For example, the proposed changes will draw investor’s attention to key product features, which are now on the first page. A “question and answer” format is also used to better engage investors on factors to consider. In addition, products that are complex will be clearly indicated with a red label to alert investors of the need to seek advice as appropriate.  Investment-Linked Policies (ILPs) will also now require a PHS under the proposals.
 
Streamlining of the Complex Products Framework
4 The complex products framework was introduced in 2012 to aid retail investors in better understanding the features and risks of a complex product before they invest. The framework classifies capital markets products into “complex” and “non-complex” products and stipulates distribution safeguards for complex products. For complex products, the distributor is required to assess a retail investor’s educational, work and investment experience. Where the investor is assessed not to have sufficient knowledge or experience, he will have to complete a learning module, or receive mandatory financial advice.

5 MAS periodically reviews the complex products framework taking into account market developments and feedback, so that they remain appropriate for the evolving and diverse investment needs of Singapore retail investors. Over the last decade, retail investor access to investment product knowledge has improved. Therefore, alongside the proposed PHS enhancements, there is room to streamline the complex products distribution safeguards to be more disclosure and information-based through the following:  

a) Remove requirement for mandatory financial advice 

With clearer complex product labelling and investor-friendly PHS disclosures, investors will be in a good position to make considered, informed investment decisions. Relevant warnings and risks will be highlighted, and investors encouraged to consider seeking professional financial advice. Given this, MAS proposes to remove the requirement for mandatory financial advice even where the investor does not have the qualifications, experience, or knowledge to invest in the product, except in the case of those who require added protection.   

b) Introduce Product Knowledge Assessment (PKA)

MAS is introducing the PKA as an alternative way to assess an investor’s knowledge in complex products. This is in addition to existing criteria based on educational and professional qualifications. The PKA comprises questions on the key features and risks of a complex product, and serves as a self-assessment and awareness-building tool.

c) Impose targeted safeguards for investors who require added protection

Investors who may need additional protection (“Selected Clients”[2]) will still be required to go through a mandatory financial advisory process before they purchase complex products. This will ensure they continue to have available the safeguards MAS has implemented for Selected Clients - such as having a trusted individual present during the financial advisory process, and a call-back process to confirm the investment decision before proceeding.

6 MAS invites views and suggestions from interested parties on the proposals set out in this consultation paper which is available here  . Comments may be submitted via the FormSG link   by 1 September 2025. 

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[1] As specified under the Securities and Futures Act 2001, Securities and Futures (Offers of Investments) (Exemption for Offers of Straight Debentures) Regulations 2016, Securities and Futures (Offers of Investments) (Exemption for Offers of Post-seasoning Debentures) Regulations 2016, and various MAS Notices and Guidelines depending on the type of product. Please see section 2 of the Consultation Paper for further details.

[2] Selected Clients [as currently defined in FAA-G14 Guidelines on the Remuneration Framework for Representatives and Supervisors (“Balanced Scorecard Framework”), Reference Checks and Pre-Transaction Checks] refer to any customer of financial institutions who meets any two of the following criteria: (a) Is 62 years of age or older; (b) Is not proficient in spoken or written English; (c) Has below GCE “O” or “N” level certifications, or equivalent academic qualifications; other than a customer who meets any two of the criteria and has been assessed by the financial institution to possess adequate investment experience and knowledge to transact in the investment product recommended