MAS issues Digital Advertising Guidelines: what fund managers must do before March 2026
On 25 September 2025, the Monetary Authority of Singapore (MAS) published the Guidelines on Standards of Conduct for Digital Advertising Activities (Guidelines). This is a new, cross-industry standard for how financial institutions (FIs), including CMS licence holders / fund managers, advertise via digital media. The Guidelines take effect on 25 March 2026 and are paired with a Guide on Responsible Financial Content Creation for online creators. MAS also said it has issued advisory letters to five content creators who may have provided financial advice without a licence.
What’s new?
Five safeguards now frame what “good” looks like for digital advertising by FIs. FIs should:
- Assess the suitability of each digital platform (e.g., whether you can modify or remove ads; platform policies/reputational risk).
- Address format limitations (e.g., character caps) so disclosures are prominent, and each advertisement is not misleading on its own.
- Vet and brief digital marketers/creators (qualifications, conflicts, training, contracts).
- Monitor all digital campaigns (including external partners) with tools like social listening, web crawlers, and mystery shopping.
- Take disciplinary action where needed. Boards and senior management remain accountable for implementation. The Guidelines apply to all FIs and persons acting on their behalf (e.g., influencers, affiliates, agencies).
Alongside this, MAS and Advertising Standards Authority of Singapore released a creator-facing guide (the 7 must-knows), covering when a licence may be required for financial advice/dealing, checks against the FI Directory and Investor Alert List, and sponsored-content disclosures.
Connection with other MAS consultation
Earlier in the year, the MAS proposed to remove advertising exclusions that historically let some AI/II-targeted materials sit outside the SF(LCB)R advertisement rules. That consultation closed in July 2025 but is not yet finalised.
The direction of travel is clear: apply advertising standards more consistently, regardless of audience or channel. The Guidelines sit alongside the pending SF(LCB)R amendments. Treat them cumulatively: tighten digital conduct now and prepare for broader scope once MAS finalises the exclusions removal.
What should fund managers do now?
- Update your Marketing & Communications Policy to include any specifics for digital marketing,
- Strengthen approvals & record-keeping,
- Check and reinforce Board and SM oversight,
- If relevant, build an “influencer/affiliate” control framework, and
- Plan for the likely removal of AI/II “exclusions”.
Do/don’t for common FMC use-cases
LinkedIn carousel on a strategy theme:
- Do: include clear, legible risk statements within the carousel; link to full disclosures; and avoid performance cherry-picks.
- Don’t: place all risks on a separate landing page or in fine-print alternative text.
Creator collaboration for a webinar
- Do: contractually require licence/disclosure checks; pre-clear scripts; and require the creator to disable comments promoting stock tips.
- Don’t: allow unvetted “DM me for access to this fund” call-to-actions.
Bottom line
Treat digital advertising as a board-level conduct risk. Build the five safeguards into policy, people, and platforms now; lock in creator controls; and prepare for broader scope once MAS finalises the exclusions removal. Doing so will put you ahead of the 25 March 2026 go-live and reduce the risk that routine brand posts, factsheets, or webinars become regulatory problems.
How Ocorian can help
We regularly support firms in the following areas:
- Reviewing regulatory filings and assessing capital adequacy
- Evaluating governance structures to ensure ongoing compliance
- Advising on MAS correspondence and remediation plans
- Enhancing policies and procedures to strengthen regulatory hygiene
If you’re looking to be licensed and need to change your license, or seek permission for a new controlling shareholder, we can help.
Related Items
View all
