The MAS corporate governance consultation is relevant to Singapore’s insurers. In its consultation release, the regulator states: “The Monetary Authority of Singapore (MAS) is seeking feedback on targeted updates to the Corporate Governance Regulations.” On the deadline, the same release says: “Comments may be submitted via the FormSG link by 9 December 2026.”
Consultation Targets Specific Rules for Banks, Insurers and Holding Companies
This is a consultation, so everything reported below is a proposal put to the industry rather than a settled rule. For insurers, the instruments named in the release include the Insurance (Corporate Governance) Regulations 2013 and the Financial Holding Companies (Corporate Governance of Designated Financial Holding Companies with Licensed Insurer Subsidiary) Regulations 2022. The same list also names the Banking Regulations, alongside the insurance instruments.
According to MAS, the consultation paper proposes targeted refinements in four main areas. The areas are director independence, board composition, key appointments and streamlining for lower-impact institutions, and each is taken in turn below.
MAS frames the package in its own words. It says the proposed changes build on an established and well-functioning corporate governance framework, strengthening safeguards in specific areas where risks and practices have evolved, while streamlining requirements for financial institutions (FIs) with less impact on customers and the financial system. The release also says the proposed updates build on revisions made in November 2021 to MAS’ Guidelines on Corporate Governance for banks, insurers and their designated financial holding companies.
The release sets out the regulator’s starting point. MAS states that corporate governance remains fundamental to well-run and resilient FIs. It adds: “Banks and insurers play particularly critical roles in safeguarding depositor and policyholder interests.”
The release also addresses proportionality. MAS notes that it applies corporate governance requirements proportionately, taking into account the size, risk profile and impact of each FI. The release continues that FIs that are more systemically important or have greater retail reach can have a larger impact on customers and the financial system, and are therefore subject to more stringent corporate governance requirements.
Proposals on Director Independence and Board Composition
The first area concerns independence. On the MAS proposal, MAS proposes to refine the criteria for determining whether directors are independent from management, business relationships and substantial shareholders. The release offers an example: directors employed by, or have dealings with related corporations or affiliates, will be deemed non-independent from management and business relationships.
MAS explains the purpose of clearer criteria in one sentence: “Clear independence criteria support objective judgement and effective challenge.” The example and the stated purpose sit together in the same part of the release, and both concern the independence criteria.
The second area is the make-up of the board itself. Here, MAS proposes to increase the minimum board size and require a majority of independent directors for domestic systemically important banks and insurers as well as full banks. The proposal on board size and independent directors is reported here after the independence proposal.
The release gives its reasoning for the board changes. It states that these refinements are intended to ensure that boards continue to have the breadth of perspectives and expertise and independent oversight needed as institutions grow in scale and complexity. Readers following governance supervision in other markets may also look at InsuraBeat’s pieces on APRA’s governance reset for insurers and on Japan’s governance code and insurer cross-shareholdings.
Proposed Changes to Prior Approvals for Key Appointments
The third area deals with senior roles. The consultation release says that MAS proposes to require prior approval for additional key appointments, such as Chairperson of Nominating Committee of locally incorporated banks and insurers, and Chief Information Officer of domestic systematically important banks. MAS ties the proposal to its stated reasoning: the proposals reflect the increasing importance of succession planning, technology and information risk management at the board and senior management levels.
The fourth area concerns lower-impact FIs. The release says that MAS also proposes to remove the requirement for prior approval of certain board and senior management appointments for FIs assessed to have less retail reach or lower systemic importance. MAS describes the purpose of that change as follows: it ensures that regulatory requirements remain risk-proportionate and do not impose unnecessary regulatory burden where additional approvals are not needed.
Holding companies are addressed in the same release. It states: “Designated financial holding companies with a bank or insurer subsidiary would generally be subject to the same corporate governance standards as their subsidiaries, reflecting the way governance and risks are managed across financial groups.” The release addresses holding companies with an insurer subsidiary in the same passage as those with a bank subsidiary.
MAS also gives an overall statement of intent: “Overall, the proposals are intended to keep corporate governance standards strong and up to date, while ensuring requirements remain proportionate and fit for purpose across the financial sector.” Singapore is also the subject of other InsuraBeat coverage, including a piece on MAS plans for a protected cell company framework and one on an MAS official telling engineering insurers about risk capacity. InsuraBeat has also covered ICICI Lombard’s penalty over outsourcing governance gaps.
Insurers that want to respond should return to the MAS release and its consultation paper for the full detail. The release states: “Comments may be submitted via the FormSG link by 9 December 2026.”
