Raymond Cheung
Chartered Actuary · CRO · Board Adviser · Singapore
MAS's 30 September 2026 consultation is being read as deregulation, because it removes prior approval for appointments at lower-impact financial institutions. Read the other half. MAS is adding prior approval for one new seat at every locally incorporated bank and insurer: the chair of the nominating committee. Of all the seats it could have picked, it picked the one that decides who gets onto the board.
Most of the coverage of MAS's 30 September consultation has led with the easing: for financial institutions with less retail reach or lower systemic importance, certain board and senior management appointments will no longer need the regulator's prior approval. That is the deregulatory headline. It is also the less interesting half of the paper. Because in the same consultation, MAS proposes to add prior approval for a seat that does not currently require it, at every locally incorporated bank and insurer: the chairperson of the nominating committee.
Regulators do not add friction at random
In my experience, both as a statutory CRO dealing with MAS and as an adviser sitting on the board side of that relationship, a regulator adds an approval gate in exactly one circumstance: it has seen enough outcomes it did not like to decide that the existing process cannot be relied on. MAS is simultaneously taking approval away from a whole class of institutions and adding it for one specific role. That is not a drafting accident. It is a judgment about where governance in Singapore financial institutions is weakest.
“The nominating committee chair is the person who decides who gets onto the board. MAS has just said it wants a say in who that person is. Boards should sit with what that implies about the last decade of nominating committee work.”
The two proposals that compound
There is a second limb of the consultation that most boards will underestimate, and it interacts badly with the first. MAS proposes to tighten the independence criteria so that directors employed by, or with dealings involving, related corporations or affiliates would be deemed non-independent. At the same time, it proposes larger minimum boards and a majority of independent directors for domestic systemically important banks and insurers, and for full banks. Those two proposals pull in opposite directions on the same board. You need more independent directors as a proportion of a larger board, at the same moment that the definition of independent gets narrower.
For a Singapore insurer sitting inside a regional or global group, this is not theoretical. Directors who have been counted as independent for years because their relationship runs to an affiliate rather than to the licensed entity may simply stop counting. I would expect a meaningful number of boards to discover, when they run the arithmetic, that they are not close to a majority under the revised test and that the shortfall has to be filled from a Singapore independent director pool that is already thin and already under tenure pressure from SGX's nine-year rule.
What to do before 9 December
- Re-run your board independence classification against the proposed criteria, not the current ones, and establish how many directors you would lose. Do this as an arithmetic exercise on paper before it becomes a recruitment problem.
- Ask whether your nominating committee chair would comfortably survive a MAS fit-and-proper assessment on the specific competency the role needs, which is board composition judgment, not general seniority.
- Respond to the consultation. It closes 9 December 2026. Boards that have a genuine practical constraint on independent director supply should say so now, with evidence, rather than discover the transition timetable after it is fixed.
My own view is that MAS has the diagnosis right. Nominating committee work in Singapore has been the quietest and least scrutinised part of board governance for a long time, and a regulator that wants better boards is correct to start with the person who builds them. But diagnosis and transition are different problems. The boards that engage with this in October will be making choices. The ones that wait until the rules are final will be filling vacancies.
Common Questions
What does MAS's September 2026 consultation propose for nominating committee chairs at Singapore banks and insurers?
MAS proposes to add the chairperson of the nominating committee to the list of key appointments requiring MAS's prior approval at locally incorporated banks and insurers. It also proposes prior approval for the Chief Information Officer at domestic systemically important banks. This runs alongside a proposal to remove prior approval for certain appointments at institutions with lower systemic importance, so the net effect differs by institution. The consultation closes 9 December 2026.
How would the proposed independence criteria change board composition for Singapore insurers?
MAS proposes that directors employed by, or with dealings involving, related corporations or affiliates would be deemed non-independent. For an insurer that sits within a wider group, that can reclassify directors who have been treated as independent for years. Because MAS is separately proposing larger boards with a majority of independent directors for domestic systemically important insurers, the two changes compound: a narrower definition applied against a higher threshold on a bigger board.
Should a Singapore insurance board respond to the MAS corporate governance consultation?
Yes, if it has a practical constraint worth putting on the record, particularly on independent director supply or transition timing. Consultation responses are the only point at which a board's operational reality can shape the final rule. Once the amendments to the Insurance (Corporate Governance) Regulations are made, the board's options narrow to compliance planning. Feedback closes 9 December 2026.
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About the author
Raymond Cheung is a Chartered Actuary, C-suite executive and board adviser with more than 20 years of experience across Asia in risk management, insurance, ESG and corporate governance. He is the CEO of CER Consultancy and an accredited trainer at SMU Academy and the Singapore College of Insurance.