MAS to Propose Legislative Changes to Effect Enhancements to Product Highlights Sheets and Complex Products Framework

On 15 May 2026, the Monetary Authority of Singapore (“MAS“) published its Response to feedback on proposals to enhance Product Highlights Sheet (“PHS“) requirements and streamline the complex products distribution framework. The proposed key changes include:

1. enhanced PHS disclosures with clearer labelling and visual cues for complex products;
2. new PHS requirements for Investment-Linked Policies (“ILPs“) and classification of ILPs as complex products;
3. removal of mandatory financial advice for complex products (except for Selected Clients);
4. introduction of pre-transaction alerts; and
5. combination of the Customer Knowledge Assessment (“CKA“) and Customer Account Review (“CAR“) into a single CKA.

MAS consulted on these proposed changes in its 1 July 2025 Consultation Paper. For a summary of these changes, please refer to our July 2025 Legal Update titled “MAS Seeks Feedback on Enhancements to Product Highlights Sheet Requirements and Complex Products Framework“.

Respondents to the earlier Consultation Paper were broadly supportive of the proposals. They welcomed the shift towards a more disclosure-based regime, and the streamlining of the customer journey for self-directed investors. MAS stated that legislative amendments to implement the changes will be consulted on later.

The new PHS requirements for investment products and ILPs will take effect alongside the revised distribution safeguards and product classifications under the complex products framework. MAS will consult on the appropriate transition period when consulting on the legislative amendments.

Part I: Enhanced PHS Requirements

Design Enhancements

To maintain a consistent look for all PHSes, MAS will require the colour, width and length of the heading band to be standardised. MAS will also make changes to create visual distinction and draw attention to product complexity.

Enhancements to Prescribed Content

Key content enhancements include: (i) simplified and standardised introductory statements across all PHS; (ii) new complexity disclosure statements explaining why a product is classified as complex; (iii) mandatory use of diagrams to illustrate investment strategies and fees payable for collective investment scheme (CIS) and ILP sub-funds; and (iv) alignment of PHS requirements across various products through amendments to the Securities and Futures Act 2001 and subsidiary legislation.

Part II: ILP Requirements and Classification

New ILP-PHS

MAS will introduce a new PHS specifically for ILPs (“ILP-PHS“), separate from the ILP sub-fund PHS. The ILP-PHS will enhance disclosure of ILP fees and charges, which are not fully captured in the existing sub-fund PHS. To improve readability, the ILP-PHS must include cross-references to relevant sections in the product summary.

Classification of ILPs as Complex Products

ILPs will be classified as complex products regardless of the complexity classification of the underlying sub-funds. This reflects ILPs’ inherent structural complexity as hybrid products combining insurance and investment features, with returns subject to sub-fund performance and ongoing charges. The ILP-PHS will include a statement explaining that ILPs are complex because they combine insurance and investment features with different layers of fees and charges.

Part III: Review of Complex Products Framework

Nomenclature Changes

MAS will replace the terms “Excluded Investment Products” (EIP) and “Specified Investment Products” (SIP) with “non-complex” and “complex” products, respectively. The CKA and CAR will be combined into a single CKA applicable to all complex products. Transactions in any complex product (listed or unlisted) will count towards the trading experience criterion.

Knowledge and Experience Assessment

Among other changes, MAS will remove the CKA requirement for advised transactions (including digital advisory platforms), and allow a pass outcome in the CKA to be valid perpetually rather than expiring in relation to the investor’s account with the financial institution.

MAS will not proceed with the proposed Product Knowledge Assessment (PKA) due to implementation concerns.

Removal of Mandatory Advice

MAS will remove the mandatory financial advice requirement for investors who do not pass the CKA on execution-only platforms.

Pre-Transaction Alerts

MAS will streamline the complexity disclaimer and suitability warning alerts: (i) a one-off suitability warning at the point of CKA; and (ii) a pre-transaction complexity disclaimer.

Safeguards for Selected Clients

Selected Clients (those meeting at least two of these criteria: aged 62 or above, not proficient in English, below GCE O/N level education) will remain subject to enhanced safeguards including: (i) mandatory identification as part of KYC; and (ii) requirement for full financial advisory service before transacting in complex products. However, Selected Clients who pass the CKA may opt out from seeking financial advice.