MAS Compliance Guide 2026: Key Regulatory Requirements for Fund Managers in Singapore
As Singapore’s fund management industry moves into 2026, compliance expectations are becoming more structured, more data-driven, and more closely supervised. For Licensed Fund Management Companies (LFMCs), the focus is no longer limited to filing forms on time. MAS is looking at how well firms embed governance, risk management, and operational discipline into their day-to-day operations.
This guide provides the key regulatory requirements, supervisory priorities, and practical preparation steps fund managers need to be aware of, all in one place.
Key MAS Filings Due Early 2026
Filing Requirement | Purpose | Deadline |
Declaration of NIL misconduct | Confirms the conduct oversight of representatives | 14 January 2026 |
Form 1 – Statement of Assets & Liabilities | Financial position disclosure | 14 January 2026 |
Form 2 – Financial Resources & Indebtedness | Capital adequacy and risk posture | 14 January 2026 |
Quarterly Income & Expenditure | Reviews financial sustainability | 15 January 2026 |
Basic Quarterly Fund Data Collection (QDC) | Regular reporting of AUM, investor counts, and exposures | 28 February 2026 |
MAS treats late or inaccurate submissions as a sign of weak internal risk controls. Firms that plan well ahead and align finance with compliance generally fare better under scrutiny.
Quarterly Fund Data Collection (QDC): now a standing obligation
Quarterly Fund Data Collection (QDC) represents a shift in how MAS supervises fund managers. Rather than relying primarily on annual snapshots, MAS is moving toward regular, structured submissions that provide ongoing visibility into assets under management, investor composition, and investment exposures.
| Component | Explanation |
|---|---|
| Basic QDC | All LFMCs report high-level data such as AUM and number of investors. |
| Full QDC | Larger funds (e.g., mandates above certain thresholds) provide deeper breakdowns of investments. |
The phased rollout started in late 2025, with full reporting expected from early 2026.
Manual spreadsheets and last-minute reconciliation increase the risk of errors. MAS expects firms to put repeatable processes in place.
Liquidity risk: stronger structure, clearer oversight
Liquidity risk management remains a key supervisory focus. MAS expects fund managers to clearly understand and document how liquid their funds are, how redemption risks are managed, and what tools are available during stress periods.
| Topic | Focus Area |
|---|---|
| Fund categorisation | Classify funds by liquidity characteristics |
| Liquidity tools | Access to tools like swing pricing, gates and levies |
| Governance | Clear oversight of how and when tools are used |
Importantly, MAS is not only interested in whether policies exist, but whether decision-making responsibilities are clearly defined and documented.
AML/CFT: expanded scope and tighter timelines
MAS has strengthened AML/CFT expectations, particularly in three areas.
| Area | MAS Expectation |
|---|---|
| Enterprise risk assessment | Include PF and other emerging risks |
| Enhanced due diligence | Stronger checks for high-risk customers and complex structures |
| STR reporting | Standard cases: file within 5 business days; PF/sanctions cases: within 1 business day |
Together, these changes require more than policy updates. They demand operational readiness and staff awareness.
Governance and conduct: Demonstrable Responsibility
MAS continues to emphasise the Individual Accountability and Conduct (IAC) framework. For fund managers, this means:
| Governance Area | MAS Focus |
|---|---|
| Senior management accountability | Clear assignment of roles and responsibilities |
| Conflict of interest management | Policies and real-world decisions documented |
| Oversight records | Board/internal committee minutes showing active supervision |
MAS places importance on evidence of implementation, through documentation, decision records, and oversight mechanisms — rather than inferred from job titles.
Technology, cybersecurity, and AI risk management
MAS’s supervisory priorities for 2026 include technology and model risk, particularly as fund managers adopt more automation and AI tools.
Key Expectations
| Risk Category | MAS Emphasis |
|---|---|
| Cybersecurity | Strong controls, incident response readiness |
| AI governance | Model validation, explainability, and oversight |
| Operational resilience | Test scenarios and board awareness |
Regulators expect governance proportional to the business impact of technology systems, including explainability and validation for AI-driven processes.
What MAS is really signalling for 2026
Taken together, these requirements point to a clear direction. MAS is moving beyond checklist compliance and focusing on how well compliance is embedded into the organisation.
Fund managers that perform well typically:
- Integrate compliance into business planning
- Use technology to reduce manual errors
- Regularly test their controls and escalation processes
- Treat regulatory change as an ongoing programme, not a year-end task
Practical readiness snapshot for 2026
By the end of 2025, LFMCs should be able to demonstrate the following, using this concise checklist to benchmark their readiness:
| Area | What to Prepare |
|---|---|
| Regulatory filings | Calendar with responsible owners and contingency dates |
| QDC | Automated processes, governance, and reconciliation routines |
| AML/CFT | Updated frameworks including PF, due diligence, and STR procedures |
| Governance | Accountability maps and evidence of oversight |
| Liquidity risk | Fund categorisation and tool governance documentation |
| Technology risk | Cyber and AI risk assessments, validation protocols |
If any of these areas rely heavily on informal processes or individual knowledge, they are likely to attract regulatory attention.
How Pecuniya Can Help
Firms that plan ahead are better placed to meet MAS expectations with confidence and consistency. Early alignment on governance, reporting, and control frameworks reduces regulatory risk and supports stronger engagement with investors and stakeholders.
Pecuniya works alongside fund managers to provide practical regulatory guidance and implementation support across key compliance areas.
If you would like to review your readiness for 2026 or strengthen your compliance arrangements, please reach out to us at 📩 Compliance@Pecuniya.com