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The Monetary Authority of Singapore (MAS) has announced significant updates to its Guidelines on Fair Dealing, meaning more compliance requirements for payments licensees operating in the jurisdiction.
The revised guidelines, released on May 30, now extend to encompass all financial institutions — including payment and crypto firms — and the entire spectrum of products and services they offer to customers.
“This update to the Fair Dealing Guidelines reflects MAS’ expectation for all financial institutions to treat all customers fairly. This must be a foundational value championed by boards and senior management,” said Ho Hern Shin, deputy managing director for financial supervision at MAS.
“Fair dealing should be demonstrated across all activities that impact the customer, from product design to post-sales service,” she said. “We look forward to financial institutions implementing these guidelines robustly.”
The updated Guidelines include various changes to compliance, such as financial institutions needing to provide products that are well-suited to the needs of their target market segments.
Customers should also expect accurate product recommendations and transparent information, with special consideration for vulnerable individuals, according to MAS.
Additionally, clear and comprehensive explanations of product terms and conditions will need to be provided by firms, ensuring transparency, while independent and prompt handling of customer feedback will be ensured through responsive mechanisms.
“The release of the fair dealing guidelines reflects a broader trend of legislative reform in Singapore that has focused on both bringing the current legislative framework up to speed with modern times and enhancing customer protection,” said Prasad Thandapani, an analyst at Vixio.
Thandapani added that this trend has increased the regulatory burden for Singapore's 475 payments firms, including international companies like Mastercard, Visa, Flywire and Coinbase.
Payment institutions already have to implement new cybersecurity measures due to the second stage of the FSMA Act and new outsourcing guidelines. They may also need to navigate a new shared responsibility framework to combat fraud.
“The expansion of the fair dealing guidelines to include payment service providers also reflects the increasingly blurred lines between payment methods, both traditional and crypto-based, and financial institutions in the region,” he said.
According to Thandapani, “this is especially true of the numerous "superapps" that provide a variety of lending and investment services in addition to functioning as the default payment method for millions of consumers”.
Singapore is not alone in pursuing payments reforms, with neighbouring Malaysia having released similar guidelines in March 2024.
Firms are now required to integrate fundamental principles of fair dealing at every stage of a product's life cycle and in the provision of services, echoing work done in the UK, where the Financial Conduct Authority has introduced the Consumer Duty.
Singapore’s original Guidelines were introduced in 2009 under the Financial Advisers Act, and primarily focused on the selection, marketing and distribution of investment products, as well as related advisory and post-sales services.
Over the years, MAS says that financial institutions have largely adhered to these principles beyond just advisory services and investment products.
The expanded scope of the guidelines formalises this practice while retaining the core objectives of fair dealing and prioritising positive customer outcomes.
