Raymond Cheung
Chartered Actuary · CRO · Board Adviser · Singapore
SGX RegCo's April 2026 consultation on remuneration KPI, dividend policy, and investor relations disclosures is a quiet rule change with a 2027 start date — which is exactly why most boards haven't started preparing for it. The gap it exposes isn't disclosure capability. It's whether the board can explain a policy it never actually debated.
SGX RegCo's April 2026 consultation paper proposing new disclosure requirements — remuneration KPIs, a published dividend policy, an investor relations policy — closed for comment back in May, with implementation phased in from 2027 and the first annual-report disclosures due in 2028. That timeline is long enough that most boards have filed it under 'not yet,' which is my reaction to it: the boards that wait until 2027 to think about this will spend that year writing down policies that were never actually board decisions, just management defaults nobody challenged.
The disclosure isn't the hard part
None of the three requirements is technically difficult. Explaining the KPIs behind executive remuneration, describing a dividend policy, publishing an investor relations policy — a competent company secretary can draft all three in an afternoon. The requirement that actually bites is subtler: SGX RegCo isn't just asking companies to disclose a policy, it's asking them to explain material changes in remuneration KPIs year over year, and to describe investor engagement activity, not just claim it exists. That converts a disclosure exercise into an audit trail. If the board never debated why the remuneration KPI mix shifted, or never actually reviewed what 'investor engagement' consists of beyond an annual roadshow, 2027 is when that absence becomes visible in print.
“SGX RegCo isn't asking for a policy document. It's asking for proof the board actually owns the policy it's about to publish.”
What I'd put in front of a board now
I'd rather a board spend an hour on this in 2026 than scramble in 2027. Three questions worth asking at the next remuneration or nominating committee meeting: Does the board currently have a documented view on why executive KPIs are weighted the way they are, or has that always been management's call to present and the board's to approve without much debate? Does the company have an actual dividend policy, or an informal payout pattern nobody has written down because writing it down felt like a constraint? And can the board point to specific investor engagement — not just the existence of an IR function, but decisions the board made in response to what shareholders raised?
None of this requires new committees or new advisers. It requires the board to treat 2026 as the year it starts owning three decisions it may have been quietly delegating. SGX RegCo has given the market eighteen months of runway specifically so boards don't have to write these policies under deadline pressure. Boards that use that runway to actually debate the substance will find 2027 straightforward. Boards that wait will find themselves disclosing, for the first time in public, that nobody was really deciding.
Common Questions
What does SGX RegCo's proposed disclosure rule actually require?
The April 2026 consultation proposes three new annual-report disclosures for Mainboard and Catalist issuers: the KPIs used to determine executive remuneration and an explanation of material year-on-year changes, a documented dividend policy, and a published investor relations policy with a description of investor engagement activities. Implementation is proposed to start from 2027, with disclosures appearing in annual reports from 2028.
Does the dividend policy disclosure require companies to pay a dividend?
No. SGX RegCo has been explicit that the proposal does not prescribe a payout ratio, quantified target, or a requirement to pay a dividend at all — only that the company document and describe whatever policy it does follow.
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.