MAS Introduces Initiatives to Promote Responsible Online Financial Content and Issues Advisory Letters to Content Creators

Summary

On 25 September 2025, the Monetary Authority of Singapore (“MAS”) announced a series of initiatives aimed at fostering responsible digital financial content and advertising. These include:

1. the publication of new Guidelines on Standards of Conduct for Digital Advertising Activities (Guideline No. FSG-03) (the "MAS Guidelines"), effective 25 March 2026; and
2. a collaborative guide with the Advertising Standards Authority of Singapore (“ASAS”) titled 7 Must-Knows When Sharing Financial Information Online (the "ASAS Guide"). 

Additionally, MAS has issued advisory letters to five online content creators for potentially providing unlicensed financial advice, signalling heightened enforcement scrutiny.

These developments underscore the MAS' focus on mitigating risks arising from the use of digital platforms—particularly social media platforms—such as misleading promotions, deceptive practices, and unauthorized content dissemination. 

This bulletin analyses the key learning points from the MAS Guidelines and ASAS Guide and highlights practical next steps which financial institutions (“FIs”), their representatives, and third-party digital marketers (including influencers) should prioritize to ensure compliance. 

1. Guidelines on Standards of Conduct for Digital Advertising Activities

The MAS Guidelines respond to several risks identified by MAS which derive from the nature of using digital media platforms to engage in advertising. For instance, formatting constraints on digital media (e.g., character limits) may result in the omission of critical details on product features, risks, or terms, leading to an imbalanced or misleading view of these product offerings. Further, there have been instances of deceptive tactics (e.g., "catfishing" to solicit leads) which have harassed or misled users, and instances of non-compliant advertisements being disseminated without FI oversight or pre-approval. 

To counter the abovementioned risks, the MAS Guidelines establish principles-based expectations for FIs and their digital marketers to advertise financial products and services via digital media in a "responsible and professional manner." The MAS Guidelines apply to all Singapore-licensed FIs and their appointed third parties, including external collaborators like influencers and affiliate marketers. Content disseminated through tie-ups (e.g., referral codes for investment sign-ups) is explicitly treated as advertising. Non-compliance may impact assessments of an FI's fitness and propriety under the Financial Advisers Act (“FAA”) and Securities and Futures Act (“SFA”).

A. Key Safeguards

The MAS Guidelines emphasise that the board and senior management of FIs remain responsible for the FI’s digital advertising activities, even if conducted or produced by foreign head offices or central teams. As such, the following core safeguards listed in the MAS Guidelines should be incorporated into the FI’s internal policies and systems (and measures beyond the listed safeguards should be implemented if appropriate): 

• Selecting low-risk digital media (e.g., based on customary use and track record of the digital medium, ease of control over advertisements disseminated on such mediums) and managing format limitations (e.g., using expandable posts or links to full disclosures, considering risk of misinformation due to truncated messages).
• Ensuring clear, prominent risk warnings (e.g., appropriate disclosures that returns are not guaranteed, that historical returns are not indicative of future investment performance, and disclosures of licensing) and balanced messaging (e.g., disclosing both benefits and risks in an advertisement instead of only mentioning risks in a separate webpage).
• Ensuring appropriate selection criteria for digital marketers (e.g., based on qualifications, communication styles, track records in advertising for the financial sector) and ensuring that the digital marketers are apprised of relevant advertising rules and regulations (e.g., through trainings and/or entering into formal agreements with external digital marketers)
• Monitoring for unauthorized content and enabling swift remediation (e.g., ensuring processes are in place to request for the removal of unauthorised social media accounts or advertisements, to track and preserve evidence of unauthorised content, filing police reports).
• Taking appropriate and proportionate disciplinary action against errant digital marketers based on risk and severity of misconduct (e.g., more stringent monitoring, issuance of warnings or imposing other corrective actions or penalties)

2. ASAS Guide: 7 Must-Knows When Sharing Financial Information Online

In parallel, MAS and ASAS released the ASAS Guide, which is a one-page checklist containing practical guidance for content creators (e.g., social media influencers). Key "must-knows" include: 

3. Advisory Letters to Content Creators

In conjunction with the release of the MAS Guidelines and ASAS Guide, the MAS has also sent advisory letters to five content creators suspected of unlicensed financial advice.

Implications 

The recent initiatives above evidence the MAS’ increasing scrutiny on and efforts to regulate digital media advertising of financial services and products, and the following impacts should be noted:

• Financial Institutions: Expect intensified MAS supervision of digital campaigns. FIs partnering with third parties (e.g., influencers) must extend oversight, including contractual clauses for compliance and audit rights. Risks include reputational damage from rogue ads and liability for third-party misconduct.
• Content Creators and Influencers: High-risk activities like product-specific recommendations or order facilitation now demands licensing checks. Even "educational" content can cross into regulated territory if tailored or promotional.
• Broader Ecosystem: Digital platforms are encouraged to play a more prominent role in improving financial literacy, but the potential for the amplification of harmful content (e.g., via algorithms) heightens collective responsibility. The alignment and collaboration between the ASAS and MAS also buffers and strengthens the enforcement capabilities in relation to advertising standards.

Recommendations and Next Steps

To stay ahead of the game and mitigate any potential enforcement, FIs, content creators / influencers and affected players in general should:

1. Conduct a Digital Advertising Audit: Review current campaigns against the Guidelines; map risks by platform and implement archiving/monitoring tools by Q1 2026 (when the MAS Guidelines take effect).
2. Update Policies and Training: Embed the safeguards listed in the Guidelines into fair dealing frameworks; implement appropriate trainings for the boards, senior management, staff, and marketing partners on licensing triggers and disclosure rules.
3. For Content Creators: Refer to the checklist in the ASAS Guide before posting any material; Consider consulting legal advice for potentially infringing campaigns or content; and verify FI partners via MAS directories.
4. Monitor Developments: The MAS Guidelines are issued following public consultations and the MAS may provide further clarifications on compliance in future updates. Engage with ASAS for advertising best practices.

Assistance we can provide

We provide comprehensive assistance to clients navigating MAS’ new initiatives on responsible online financial content and digital advertising, including the Guidelines on Standards of Conduct for Digital Advertising Activities and the collaborative guide with ASAS. This includes:

1. advising financial institutions, content creators, and digital marketers on implementing the required safeguards—such as assessing digital media and online content appropriateness, ensuring clear disclosures, managing conflicts of interest;
2.  establishing monitoring and disciplinary frameworks; 
3. conducting gap analyses of existing policies and procedures; 
4. drafting or reviewing contracts with third-party influencers or affiliates to align with regulatory requirements under the Financial Advisers Act and Securities and Futures Act; and
5. delivering tailored training for boards, senior management, and staff to foster accountability; and representing clients in MAS interactions, such as responding to advisory letters, investigations, or enforcement actions to mitigate risks of non-compliance and promote fair dealing outcomes.

Do reach out to us should you require assistance. 

This article is produced by our Singapore office, Bird & Bird ATMD LLP. It does not constitute legal advice and is intended to provide general information only. Information in this article is accurate as of 26 September 2025.