Raymond Cheung
Chartered Actuary · CRO · Board Adviser · Singapore
SGX has reportedly started pushing back on issuers that disclosed director pay in bands rather than exact amounts, and a 2026 NUS study shows the transparency gap has moved to key management and family-linked pay. Here is what Singapore boards should take from it before the next annual report.
My first reaction to the news that SGX has been querying issuers over how they reported director pay was not surprise. It was recognition. Years ago, in a remuneration discussion I sat through, the room spent forty minutes on the CEO's bonus and about forty seconds on the table that would actually be printed in the annual report. That table is where the regulator now looks first.
The facts, as reported: the rule requiring exact pay for each director and the CEO applies to annual reports for financial years ending on or after 31 December 2024. At least one issuer is reported to have shown director pay in bands in its FY2025 report, and SGX asked for a granular breakdown covering fixed salary, bonuses, fees and other components. That is the regulator telling the market that the rule is no longer new, and that a late FY2025 report is not a grace period.
The gap has moved
What interests me more is where the weakness now sits. A 2026 NUS study covering 469 companies and 41 trusts found better transparency on director and CEO pay, but continued opacity on key management personnel and on employees who are related to substantial shareholders, directors or the CEO. Those relationships are exactly where minority shareholders worry about unearned or excessive pay. Compliance on the headline number has improved. The harder disclosures have not.
“A board that discloses the CEO's pay precisely and treats a director's cousin on the payroll as a footnote has complied with the rule and missed its purpose.”
What I would do before the next report
- Have the remuneration committee review the actual draft table, not a summary of it, and confirm every director and the CEO is shown at exact amounts with the full component breakdown.
- Ask the company secretary for a list of every employee related to a director, the CEO or a substantial shareholder, with their pay. If the answer takes a week to produce, the process is the problem.
- Minute why key management pay is disclosed the way it is. A documented decision reads very differently from a default.
Boards that treat remuneration disclosure as the company secretary's job will keep getting queries. The ones that treat it as a board decision will not. I know which committee I would rather sit on.
Common Questions
Does SGX require exact pay for each director and the CEO?
Yes. For financial years ending on or after 31 December 2024, listed issuers must disclose the exact amount and breakdown of remuneration for each director and the CEO. Banded disclosure is no longer acceptable for those individuals.
Is key management personnel pay also disclosed exactly?
Not at present. Key management personnel other than directors and the CEO are still disclosed in bands, which is why research now points to that area as the remaining transparency gap.
What should a Singapore board do if its last annual report used pay bands for directors?
Move to exact amounts with the full component breakdown in the next report, and have the remuneration committee confirm this before the draft goes to the auditors. Do not wait for an SGX query to prompt the change.
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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.