Monetary Authority Of Singapore Rolls Out New Guidelines For Digital Advertising: Key Compliance For Financial Institutions

On 25^th September 2025, the Monetary Authority of Singapore (MAS) rolled out guidelines on Standards of Conduct for Digital Advertising Activities (" Guidelines") slated to gain effect from 25^th March 2026. The Guidelines reflect MAS's commitment to protecting consumer interest in the age of social media and "finfluencers". In today's era of digital hyper-connection, digital media has emerged as the dominant channel for engaging with consumers. Financial institutions are increasingly using social media, influencer marketing and targeted advertising to connect with clients and prospects. However, MAS has noticed cases of misleading or unauthorised promotions that present considerable risks to consumers and the overall integrity of the financial sector.

The Guidelines apply to financial institutions that are licensed or regulated by MAS and to all forms of digital advertising, including promotions via websites, social media, e-mail, blogs or video-sharing platforms. It also applies to internal and external digital marketers such as employees, representatives, influencers, affiliate marketers and advertising agencies acting on behalf of financial institutions.

LEADERSHIP AND GOVERNANCE

MAS has made it clear that the Board and the Senior Management must be held accountable for ensuring that all digital advertising conducted under the institution's name, including the ones produced by foreign headquarters or external marketers comply with the Guidelines. Therefore, the Board and Senior Management must set the "tone from the top" for ethical advertising, integrating digital conduct safeguards into policies and procedures and exercising active oversight and instituting corrective actions when risks to customers arise. This will require financial institutions to also focus on governance.

MAS expects financial institutions to have in place effective governance frameworks covering:

1. approval of digital media platforms used
2. policies on selection, onboarding and monitoring of digital marketers
3. systems to detect and remove unauthorised content or fake accounts
4. regular review of policies to align with evolving digital trends.

NAVIGATING THE GUIDELINES: FIVE SAFEGUARDS

To guide financial institutions, MAS has set out five safeguards for digital advertising, with examples to illustrate compliance steps.

1. Ensuring Appropriate Digital Media Use in Financial Advertising

Before advertising, financial institutions must carefully assess whether a digital platform is appropriate. This means ensuring the following:

1. Considering the platform's reputation and track record.
2. The platform's advertising policies on financial products.
3. Ensure that the financial institutions can effectively control, update or remove ads to manage market conduct and reputational risks.

Compliance tip: Use social media platforms that are compatible with contractual clauses that expressly reflect the requirements set out in the Guidelines.

2. Promotion of Clear and Balanced Advertising

Digital media, especially social media formats, can limit space and distort messages. Financial institutions must therefore ensure the following:

1. Key disclosures (e.g., risks, fees, conditions) are visible and clear.
2. Benefits should not be overstated while omitting material caveats.
3. Each advertisement should stand on its own and is not required to be connected/ explained by another post or link.
4. Disclosures of sponsorships or paid partnerships with influencers are prominently and visibly made

Compliance tip: Financial institutions can consider consumer testing of short-form disclosure templates optimised for social media to ensure that consumers understand disclaimers.

3. Due Diligence on Digital Marketers

Financial institutions must select only qualified and ethical marketers. Formal agreements should clearly define obligations, conflicts of interest controls, and disciplinary procedures, based on a few conditions such as:

1. Professional competence and clear understanding of financial products.
2. Prior conduct and compliance track record.
3. Contractual undertakings to adhere to every MAS requirement.

Compliance tip: Require influencers to complete mandatory compliance training based on all MAS requirements before campaign launch. Mandate pre-clearance of videos and posts.

4. Continuous Monitoring and Surveillance

Financial institutions should maintain a central register of all digital campaigns, influencer engagements, and social media accounts used for advertising. They must deploy technology-enabled surveillance, which can detect misleading content, unauthorised promotions and use unapproved platforms.

Compliance tip: Financial institutions should have social listening tools to track their product advertisements in real time. They must set up protocols in place to flag such incidents of misleading content etc. which includes takedown steps, reporting to MAS timelines and incident alert notices to consumers.

5. Disciplinary Measures

Financial institutions should impose graduated sanctions on non-compliant marketers, including written warnings and mandatory retraining, suspension or termination of digital marketing privileges and reporting of cases to MAS or any law enforcement authorities. Prohibiting repeat offenders from digital marketing activities can also serve as a deterrent.

Compliance tip: Implement a risk and disciplinary matrix linking violations to penalties. It is also important for legal and compliance teams to ensure that clauses in contracts with external service providers contain terms that allow them to impose the requirements mentioned in the MAS Guidelines.

PENALTIES FINANCIAL INSTITUTIONS MAY FACE FOR NON-COMPLIANCE

Non-compliance with the Guidelines may affect MAS's fit-and-proper assessment. However, it is important to note that since the Guidelines operate alongside binding laws that govern fair-dealing and advertising, like the Financial Advisers Regulations ("FAR") and the Securities and Futures (Licensing and Conduct of Business) Regulations ("SF(LCB)R). Therefore, the failure to comply can lead to regulatory sanctions, disqualification of directors, senior management or representatives (under the Financial Advisers Act 2001 and Securities and Futures Act 2001) and even civil or criminal liability for misleading statements. Institutions should also align with the Advertising Standards Authority of Singapore ("ASAS"), including the Singapore Code of Advertising Practice (SCAP) and Guidelines on Interactive Marketing Communication and social media, which provide broader principles on truthful, non-deceptive advertising in digital spaces and complement MAS's requirements for ethical promotions.

Compliance Roadmap

With the Guidelines gaining force from March 2026, for compliance teams and legal teams, this means preparing and integrating digital advertising into compliance monitoring frameworks and embedding accountability across business lines.

Key steps to consider include:

1. Conduct gap analysis and benchmarking practices against the Guidelines and all other existing MAS requirements for digital advertising mentioned in the Guidelines.

2. Update policies to align digital advertising practices with the Guidelines and build platform approval frameworks so that the teams know which platforms are permitted.

3. Board and Senior Management engagement to sensitise, educate, inform and escalate as required for accountability and oversight.

4. Review and amend existing contracts and ensure that all new contracts with finfluencers, media agencies etc. expressly incorporate all MAS compliance obligations including the sanctions that can be imposed. A due diligence checklist for onboarding external advertisers will provide clarity to teams within the financial institutions.

5. Train teams that are responsible for digital marketing and external digital media advertisers.

6. Design a sanctions matrix to map misconduct and align internal and external disciplinary actions with the Guidelines.

7. Conduct ongoing reviews to ensure compliance with the Guidelines as well as the regulations and standards it references.

8. Align compliance processes and policies to the strictest standard in place and track all regulations and standards referenced in the Guidelines.

9. Invest in compliance tools that can help with horizon scanning, monitoring, tracking and reporting of both internal and regulatory compliance.

CONCLUSION

The digital marketplace offers creativity but not at the expense of consumer protection. The Guidelines provide a forward-looking regulatory approach which balances innovation with consumer protection. For financial institutions and their marketing partners, the message must be unequivocal: digital conduct is an extension of corporate conduct. The roadmap is clear: financial institutions must review, update and strengthen internal policies and contracts with external advertisers well ahead of the March 2026 deadline. By acting early, in-house legal and compliance teams will not only meet the MAS requirements but also reinforce consumer trust in their institution.

Other key regulations and standards referenced in the MAS Guidelines include:

1. Financial Advisers Regulations (FAR)
2. Securities and Futures (Licensing and Conduct of Business) Regulations (SF(LCB)R)
3. Financial Advisers Act 2001
4. Securities and Futures Act 2001
5. Advertising Standards Authority of Singapore (ASAS), Singapore Code of Advertising Practice (SCAP)
6. ASAS Guidelines on Interactive Marketing Communication and Social Media

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.