MAS FSG-03 Digital Advertising Guidelines: Compliance Checklist for Insurers and Financial Advisers

The MAS digital advertising guidelines for insurance apply to every Singapore-licensed insurer and financial adviser that promotes products online, and they have applied since 25 March 2026. The Guidelines on Standards of Conduct for Digital Advertising Activities, referred to here as FSG-03, were issued by MAS on 25 September 2025 with a six-month lead time. They do not create a new product approval process. They set out what MAS expects of the institution's own governance over how, where and through whom financial products are advertised digitally. This article translates those expectations into a checklist that compliance, marketing and distribution teams can work through, and it should be read alongside the guidelines themselves, which remain the authoritative text.

Who FSG-03 covers

The Guidelines apply to financial institutions and to their digital marketers. In the guidance published by MAS and summarised by several law firms, digital marketers include more than the institution's own staff: employees, representatives, influencers, affiliate marketers and advertising agencies can all fall within scope when they promote the institution's products on its behalf or with its endorsement.

For insurers this matters because distribution is rarely in-house alone. A direct insurer may rely on tied agents, financial adviser partners, bancassurance partners and a digital agency running paid social campaigns. Each of those channels can produce digital advertising that the insurer is expected to oversee.

MAS considered, in its response to consultation feedback, whether lower-risk products such as general insurance should be carved out. It did not exclude them. Financial institutions are expected to apply the Guidelines to digital advertising for all financial products and services, even where the conduct risk of a particular product is lower. An insurer should therefore not assume that a simple general insurance or term product places it outside the framework.

The five safeguards

FSG-03 is built around five areas of control. The labels below follow public summaries of the Guidelines; confirm the exact wording against the MAS text before finalising internal policy.

First, the institution should ensure that the digital media it uses are suitable for advertising financial products and services to its target customers. Second, it should assess the limitations of each medium, for example space or format constraints that make it hard to present risks and exclusions fairly, which can leave customers with a misleading or unbalanced picture. Third, it should assess and select appropriate digital marketers. Fourth, it should monitor the digital advertising activities carried out by those marketers. Fifth, it should take disciplinary action against digital marketers whose conduct falls short.

MAS has also stated that boards and senior management are accountable for ensuring digital advertising is conducted in line with the Guidelines. That accountability is the reason many institutions are routing FSG-03 through their regulatory licensing and compliance governance forums rather than leaving it with marketing.

Checklist for platform selection and channel limits

Start with a documented platform assessment. For each channel the insurer uses or intends to use, the record should show why the channel is suitable for the product and the audience, what the reputational and market conduct risks are, and what limits the format imposes.

Practical points to cover include:

1. A channel register listing every platform, page, account and campaign in use, with a named owner.
2. A product-to-channel mapping that records which products may be advertised where. Short-form video and character-limited posts may be unsuitable for products with complex exclusions, surrender charges or investment-linked features.
3. A rule on how mandatory disclosures, risk warnings and links to full product documents are presented when the format is constrained.
4. Criteria for paid targeting, so that audiences are not selected in a way that exploits vulnerability or encourages unsuitable purchases.
5. A review trigger when a platform changes its features or policies.

The assessment should be refreshed when a new product, channel or campaign type is introduced, not only annually.

Checklist for selecting and contracting digital marketers

Many of the highest-risk placements sit with third parties. The selection step should be a proper due diligence exercise, proportionate to the marketer's reach and the products promoted.

Consider the following:

1. Pre-engagement checks covering the marketer's track record, prior regulatory or platform sanctions, understanding of financial advertising rules and ability to follow a content approval process.
2. Written agreements that require adherence to the institution's advertising standards, set out an approval workflow, give the institution the right to require removal of content, and provide for termination for breach.
3. Training or a briefing pack for influencers and affiliates on what they may and may not say, including a prohibition on guarantees, unbalanced return claims and statements that a disclaimer is intended to cure.
4. Clear identification of commercial relationships so that promoted content is recognisable as advertising.
5. A defined list of staff and representatives who are authorised to post about products on personal accounts, and rules for those who are not.

The Singapore Code of Advertising Practice, including its appendix on financial products and services, continues to apply to the content itself, and it sits alongside the Guidelines rather than being replaced by them.

Checklist for monitoring and disciplinary action

FSG-03 expects active oversight, not reliance on the marketer's own assurances. Public commentary from law firms points to monitoring tools that institutions are adopting, including web crawling, social media listening, mystery shopping and a maintained register of campaigns and accounts.

A workable monitoring programme usually contains:

1. Pre-publication review of material that makes product claims, with a recorded approver.
2. Post-publication sampling of live content by compliance, at a frequency that reflects the risk rating of each marketer.
3. A process for third-party complaints and platform reports to reach compliance quickly.
4. An escalation path covering takedown timelines, root cause analysis and notification to senior management.
5. A disciplinary ladder that runs from retraining and content correction to suspension and termination of the relationship, applied consistently and documented.
6. Management information to the board risk committee, including numbers of campaigns, exceptions found, takedowns and sanctions applied.

Record keeping deserves attention. If MAS asks how the institution satisfied itself that a given campaign was suitable, the answer should be retrievable from the approval trail without reconstruction.

Interaction with the broader conduct framework

FSG-03 does not sit alone. Insurers and financial advisers remain subject to the Financial Advisers Act and its regulations on advertisements, to the Guidelines on Provision of Financial Advisory Service, and to fair dealing expectations in the MAS conduct framework. Our analysis of the MAS market conduct framework for insurers explains how those pieces fit together. Pending and recent amendments to the advertisement regulations and related notices were discussed by MAS in its response to consultation feedback; check the MAS website for the current instrument text and effective dates, since this article does not restate them.

Two interactions are worth flagging for the compliance plan. The first is with digital distribution conduct regulation, where online sales journeys, disclosures and suitability processes already carry their own requirements. The second is with technology and data controls: campaign tooling, tracking and audience targeting involve customer data, so privacy and technology risk teams should be part of the review.

A practical sequence for the next 90 days

For institutions that implemented only the minimum by 25 March 2026, a structured follow-up avoids a gap emerging at the next supervisory conversation.

1. Build or update the channel and marketer register, and confirm each entry has an owner.
2. Gap assess current practice against the five safeguards and rate each as met, partly met or not met.
3. Remediate contracts with agencies, influencers and distribution partners that lack approval, takedown and termination rights.
4. Stand up a monitoring routine and run a first sample review, recording the findings.
5. Report to the board or its risk committee on the programme, the exceptions found and the actions under way, so that accountability is evidenced.
6. Schedule an independent review after two reporting cycles to test whether the controls operate as designed.

Next steps

Alpha Consultant works with insurers and financial advisers on regulatory gap assessments, conduct frameworks and compliance governance. If your team needs a structured review of its digital advertising controls against FSG-03, or support designing the governance and monitoring programme, speak to our team through the regulatory licensing practice page.