MAS Misconduct Reporting Updates for FAs and Insurance Brokers

This update is targeted at Licensed / Exempt Financial Advisers and Insurance Brokers.

MAS has introduced updated misconduct reporting requirements that firms should start preparing for ahead of the implementation date of 1 January 2027. The changes affect how firms identify reportable misconduct, when reports must be filed, when follow-up updates are required, and what records must be maintained internally.

Updated MAS Notices

These updated notices formalise a more structured reporting framework around:

• submission of a Misconduct Report,

• submission of an Investigation Report in certain cases,

• submission of Update Reports following key developments,

• provision of certain reports to the individual concerned, and

• maintenance of proper supporting records.

Who This Affects

The updated requirements apply to:

• Licensed Financial Advisers

• Exempt Financial Advisers

• Insurance Brokers

• relevant accident and health insurance intermediaries

In practical terms, firms should review whether their current compliance, HR and investigation workflows are ready to support these new reporting obligations.

Scope of “Misconduct”

Under the updated notices, misconduct is broader than fraud or dishonesty alone. It can include acts or omissions such as:

• fraud

• dishonesty

• conduct involving illegal monetary gain

• gross negligence

• inappropriate advice

• inappropriate recommendations

• misrepresentation

• inadequate disclosure of information to clients

The key issue is whether the conduct materially adversely affects the client or calls into question the individual’s fitness and propriety.

Misconduct Report

Where a firm has reasonable grounds to believe that misconduct has occurred, it must generally submit a Misconduct Report to MAS within 21 calendar days, unless MAS has allowed a longer period in writing.

This means firms should not wait until every issue is fully concluded before determining whether reporting is triggered. A clear internal escalation process is therefore important, particularly where the matter first arises through complaints, supervisory reviews, monitoring findings, or internal investigations.

Investigation Report

In some cases, a firm must also submit an Investigation Report.

This becomes especially important where the alleged misconduct involves fraud, dishonesty, illegal monetary gain or similar matters. Firms are expected to assess whether a police report should be lodged. If a police report has been made, the relevant details should be included as part of the reporting.

Even where the matter does not involve fraud or dishonesty, an Investigation Report may still be required where the firm’s reasonable grounds are based on or supported by internal investigation findings.

Update Reports

The new framework does not stop at the initial report. Firms must also submit Update Reports within 21 calendar days of any significant development.

Examples may include:

• a police report being lodged,

• a decision not to lodge a police report after earlier consideration,

• changes to investigation findings,

• disciplinary or corrective action taken, or

• material updates relating to investigations or proceedings.

This means firms will need a proper mechanism to track post-reporting developments instead of treating the initial submission as the end of the matter.

Disclosure to the Individual Concerned

The updated notices also place emphasis on procedural handling after a report is submitted.

Subject to certain exceptions, firms must provide the individual concerned with a copy of the Misconduct Report and certain related Update Reports within the prescribed period after submission to MAS.

At the same time, not every document needs to be shared. Certain reports and materials, particularly where disclosure may prejudice investigations or where the person cannot reasonably be contacted, may be treated differently.

Firms should therefore ensure that their internal SOPs clearly set out:

• what must be shared,

• what may be withheld,

• who approves that decision, and

• how the rationale is documented.

Record-Keeping

Record-keeping is a key part of the updated framework.

Firms should maintain proper records of:

• the underlying facts of the case,

• affected clients and transactions,

• investigation steps and evidence reviewed,

• internal assessments and conclusions,

• disciplinary or corrective actions taken,

• whether reports were provided to the individual concerned, and

• the basis for any decision not to provide certain materials.

This is important not only for compliance with the reporting notices, but also for demonstrating that the firm has handled the matter in a structured and defensible manner.

Transitional Provisions

The updated notices take effect from 1 January 2027.

Firms should also be aware that transitional treatment may apply depending on when the misconduct arose and whether reporting obligations had already been triggered under the previous notice. In short, firms should not assume that older cases can simply be ignored if they remain unresolved by the time the new framework comes into force.

This makes early process review even more important, especially for firms that may already have legacy cases, unresolved complaints, or internal investigations in progress.

What Firms Should Do Now

Before 1 January 2027, firms should consider reviewing whether they have:

• a clear trigger for identifying when there are reasonable grounds to report,

• an internal owner for investigations and reporting,

• a documented process for assessing whether a police report should be made,

• a mechanism to monitor deadlines for Update Reports,

• an SOP for disclosure to the individual concerned, and

• adequate investigation and record-retention procedures.

How Alder Can Help

Keeping up with MAS regulatory changes is not just about knowing that a new notice has been issued. The real challenge is translating those changes into workable internal processes that your business can actually follow.

Alder supports Licensed / Exempt FAs and Insurance Brokers by helping to track regulatory developments, assess the operational impact of new MAS requirements, and update internal compliance frameworks accordingly. This can include reviewing your existing escalation and investigation process, identifying reporting gaps, enhancing SOPs, and helping your team put in place a practical workflow for compliance with the updated misconduct reporting regime.

As MAS requirements continue to evolve, having a partner that keeps track of these developments can help firms respond more confidently and avoid last-minute remediation before implementation deadlines.