Reed Smith Client Alerts

Key takeaways

  • The outsourcing requirements for banks and other financial institutions will change in December 2024.
  • Banks will face more additional obligations than non-bank financial institutions.
  • Non-bank financial institutions should review their current outsourcing arrangements and practices.


In 2016, the Monetary Authority of Singapore (MAS) issued revised Guidelines on Outsourcing (Outsourcing Guidelines 2016) to financial institutions.

The Outsourcing Guidelines 2016 applied to all financial institutions under the Monetary Authority of Singapore Act, including retail and merchant banks, insurers, trust companies and payment services providers.

Two new sets of guidelines

In 2023, the MAS issued two new sets of guidelines: Guidelines on Outsourcing (Banks) (the New Bank Guidelines) and Guidelines on Outsourcing (Financial Institutions other than Banks) (the New FI Guidelines). These set out MAS’ expectations for both banks and financial institutions (FIs) that are not banks with regard to their outsourced services. While the New Bank Guidelines apply to retail and merchant banks, the New FI Guidelines apply to any financial institution as defined in Section 2 of the Financial Services and Markets Act 2022 other than a retail and merchant bank. In other words, financial institutions other than banks (FIOBs) include finance companies, insurers, insurance intermediaries, financial advisers, payment services providers, trust companies, financial holding companies and credit card issuers.