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Trestec
Marina Bay, Singapore

Singapore (MAS)

MAS outsourcing, technology risk and business continuity frameworks.

Overview

MAS outsourcing and technology risk expectations should be considered alongside business continuity. The relevant frameworks include the MAS Guidelines on Outsourcing, the MAS Technology Risk Management Guidelines (2021) and the MAS Business Continuity Management Guidelines.

MAS issued its Guidelines on Outsourcing on 27 July 2016 (last revised 5 October 2018). From 11 December 2024 they were replaced by the Guidelines on Outsourcing (Banks) and the Guidelines on Outsourcing (Financial Institutions other than Banks), both issued on 11 December 2023. They apply a risk-based approach, with fuller expectations for material outsourcing arrangements: in summary, those which, if disrupted, could significantly affect the institution’s business operations, reputation or profitability, or its ability to manage risk and comply with laws and regulations, or which involve customer information where unauthorised access or disclosure would materially affect the institution or its customers.

MAS Notice 658 (banks) and Notice 1121 (merchant banks), Management of Outsourced Relevant Services, issued 11 December 2023 and in force since 11 December 2024, set legally binding requirements alongside the guidelines.

MAS does not generally require prior notification of material outsourcing; it removed that expectation in 2016. Banks must keep an outsourcing register and submit it to MAS twice a year and on request, and Notices 658 and 1121 require notification in specific cases, such as subcontracting of material services and certain terminations. MAS consulted in March 2026 on Guidelines on Third-Party Risk Management, which would replace the outsourcing guidelines once finalised.

Applies to

  • Banks and merchant banks, under Notices 658 and 1121 and the Guidelines on Outsourcing (Banks)
  • Other MAS-regulated financial institutions, under the Guidelines on Outsourcing (Financial Institutions other than Banks)
  • Material outsourcing arrangements, which attract the fullest expectations
  • Cloud arrangements, which MAS treats as a form of outsourcing

Relevant jurisdictions

Scope and applicability

Confirm the requirements that apply to your entity, the service and the arrangement before selecting the depth of review. How the rules apply depends on your entity.

Key dates

27 July 2016

MAS Guidelines on Outsourcing issued (last revised 5 October 2018)

18 January 2021

MAS Technology Risk Management Guidelines

6 June 2022

MAS Business Continuity Management Guidelines issued

June 2023

Business Continuity Management Guidelines: institutions expected to meet them and have a BCM audit plan; first BCM audit due by June 2024

11 December 2024

Notices 658 and 1121 and the split Guidelines on Outsourcing (Banks / FIs other than Banks) in force

March 2026

MAS consults on Guidelines on Third-Party Risk Management

Inside the regulation

MAS Guidelines on Outsourcing

The guidelines cover topics including MAS’s expectations for the risk management of outsourcing arrangements, the responsibilities of the board and senior management, evaluation of risks, assessment of service providers, the outsourcing agreement, confidentiality and security, business continuity, monitoring and control, audit and inspection, outsourcing outside Singapore and outsourcing within a group.

Annexes give examples of arrangements that are and are not outsourcing, and MAS publishes a template for the outsourcing register.

MAS Technology Risk Management Guidelines (2021)

The 2021 guidelines cover technology risk governance and oversight, the technology risk management framework, IT project management and security-by-design, software application development and management, IT service management, IT resilience, access control, cryptography, data and infrastructure security, cyber security operations, cyber security assessment, online financial services and IT audit. Third party management sits within governance (section 3.4).

MAS Business Continuity Management Guidelines

The guidelines move from a focus on individual systems to critical business services, expecting institutions to identify them, set service recovery time objectives, map their dependencies, including on third parties, and test the end-to-end recovery of each service, with independent BCM audits at least every three years.

Detailed requirements

01

Outsourcing governance

Review the arrangement against the MAS Guidelines on Outsourcing. The board and senior management are responsible for the outsourcing framework, policies and oversight.

02

Notifications to MAS

MAS does not generally require prior notification of material outsourcing. For banks, Notices 658 and 1121 require notification in specific cases, such as subcontracting of material services and certain terminations.

03

Register of arrangements

Maintain a register of outsourcing arrangements. Banks and merchant banks must submit it to MAS twice a year and on request (Notices 658 and 1121). Other institutions should check the MAS Guidelines on Outsourcing.

04

Evaluation of risks

Assess the risks of each arrangement before entering it and periodically, including concentration risk and the institution’s ability to bring the service back in house or move it.

05

Provider due diligence

Assess the provider and its evidence in context, including its financial strength, capability, controls and reliance on subcontractors, as the applicable guidelines expect.

06

Outsourcing agreement

A written agreement covering scope, performance standards, confidentiality and security, subcontracting, business continuity, audit and inspection rights for the institution and MAS, and termination.

07

Confidentiality and security

Protect customer information held by providers, consistent with obligations under the Banking Act and the Personal Data Protection Act, where applicable.

08

Overseas and intragroup outsourcing

Consider additional risks where the service is provided outside Singapore or by a group entity, including MAS’s ability to access information.

09

Technology risk

Consider the MAS Technology Risk Management Guidelines (18 January 2021) when reviewing technology dependencies. They cover third parties in section 3.4, Management of Third Party Services, which applies even where a service is not outsourcing and expects risk assessment before contracting and ongoing oversight.

10

Business continuity

Review continuity arrangements against the MAS Business Continuity Management Guidelines, which focus on critical business services, recovery time objectives and dependencies on third parties, with independent BCM audits at least every three years.

11

Contracts and exit

Review terms and transition arrangements with legal and compliance teams against the applicable notices and guidelines.

How Trestec supports it

Requirement

Scope and service inventory

How Trestec supports it

Record suppliers, services and accountable owners

Requirement

Proportionate risk assessment

How Trestec supports it

Document the rating, rationale and approval

Requirement

Board and management oversight

How Trestec supports it

Prepare an evidence-linked oversight summary

Requirement

Planning an arrangement

How Trestec supports it

Connect the proposed service to its dependencies

Requirement

Provider due diligence

How Trestec supports it

Review questionnaires and supporting documents

Requirement

Contract negotiation

How Trestec supports it

Review obligations alongside the source clauses

Requirement

Security assurance

How Trestec supports it

Keep supplier policies and certifications together

Requirement

Incident notification

How Trestec supports it

Identify supplier notification clauses for review

Requirement

Ongoing monitoring

How Trestec supports it

Track reviews, evidence gaps and outstanding actions

Requirement

Subcontractor dependencies

How Trestec supports it

Map providers behind the direct supplier

Requirement

Outsourcing register

How Trestec supports it

Maintain connected supplier and arrangement records

Requirement

Materiality and notifications

How Trestec supports it

Record materiality reviews and supporting notification evidence

Requirement

Critical business services

How Trestec supports it

Link suppliers to the business services they support

Illustrative mapping, not a compliance determination.

Supervisory review: gaps to examine

Illustrative review questions, not findings from a supervisor.

Incomplete provider inventory

Arrangements held across several teams may be missing from the central record.

Review depth not explained

Document why an arrangement receives its level of oversight.

Contracts disconnected from assurance

Review clauses alongside current evidence rather than in isolation.

Unowned follow-up actions

Record who will resolve a gap and when it will be reviewed.

Materiality not documented

No record of why an arrangement is, or is not, a material outsourcing arrangement.

MAS access not secured

Agreements do not give MAS access to information and premises.

Cloud register gaps

Cloud services adopted by business units are missing from the outsourcing register.

Dependencies not mapped to critical business services

Third parties supporting critical business services are not identified for continuity planning.

Evidence you can produce

  • Supplier and service inventory
  • Risk assessments and approval records
  • Provider due diligence and source documents
  • Contract review and notification terms
  • Monitoring records and remediation actions
  • Continuity and exit evidence
  • Board and management reporting
  • Record of which regime applies to each entity
  • Materiality assessments for outsourcing arrangements
  • Mapping of third parties to critical business services

Common questions

See Trestec on your own supplier list.