What is MAS TRM? A guide to Singapore’s risk management guidelines

As one of Asia-Pacific’s financial centers, Singapore pushes technology risk management to protect the stability and resilience of its financial sector. The Monetary Authority of Singapore (MAS) issues the Technology Risk Management (TRM) guidelines, which form the country’s core framework for helping financial institutions manage technology risk.

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MAS TRM continues to evolve as technology risks change, with further updates proposed in 2026. Understanding what these changes mean for areas such as IT asset management and data backups is crucial for organizations doing business in Singapore.

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MAS TRM: Overview and scope

MAS TRM is a core guidance framework for MAS-regulated financial institutions operating in Singapore. Aside from banks and insurers, it covers entities such as:

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• Licensed fund management companies
• Corporate finance advisories
• Real estate investment trust (REIT) management companies
• Trade repositories
• Central securities repositories
• Financial advisers

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MAS first published the TRM guidelines on June 21, 2013, with the current version issued in January 2021. The framework sets out the key technology risk management best practices and principles for governance, cyber resilience, and operational reliability.

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On June 10, 2026, MAS proposed amendments to its legally binding TRM Notices, covering areas such as IT asset management, change management, and data backups. The consultation closed on July 31, 2026, and the proposed amendments will likely take effect 12 months after the finalized Notices are published.

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The proposed changes will address evolving TRM challenges and formalize supervisory expectations.

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“The 2026 consultation papers are less about inventing new controls and more about codifying what MAS has been signaling for years, particularly around third-party concentration risk, AI model governance, and operational resilience. The biggest practical shift for most organizations is scope: the proposed Third-Party Risk Management Guidelines extend supervisory expectations to all third-party arrangements, not just material outsourcing.”

Evan Rowse

GTM GRC SME, Vanta

|

LinkedIn

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{{cta_withimage12="/cta-blocks"}} | Starting compliance ebook

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Does MAS TRM apply to foreign SaaS and technology providers?

Foreign SaaS, technology, and payment providers aren’t automatically covered by MAS TRM simply because they operate in Singapore.

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However, MAS TRM requires financial institutions to ensure their vendors meet strict compliance criteria before engaging them. As a result, any global providers supporting MAS-regulated entities must implement controls that meet the prescribed requirements for vendor due diligence, contractual obligations, and vendor oversight.

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What are the consequences of breaching MAS TRM?

Although MAS TRM is a set of guidelines, MAS can take supervisory action where regulated entities fail to comply. The MAS Enforcement Department, a division established in 2016 to ensure consistency in compliance, can investigate breaches and pursue corrective action.

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The MAS Enforcement Department typically investigates regulated bodies following any cyberattacks, regulatory breaches, and other incidents. In the event of a violation, MAS determines the appropriate corrective action based on criteria like the alleged misconduct and the extent of harm or loss caused.

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Potential consequences include:

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• Removals: MAS directs institutions to dismiss directors or executive officers who neglect their duties. The duration of the dismissal depends on the severity of the failure and its impact on the company and its clients.
• Criminal prosecutions: In particularly serious scenarios, MAS pursues criminal prosecution. 
• Civil penalties: MAS imposes civil penalties for certain regulatory breaches, either instead of or alongside criminal prosecutions. The amount depends on factors such as market impact, prior misconduct, and whether the individual/organization tried to actively conceal the issue.

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5 core areas of MAS TRM

MAS TRM comprises 13 substantive sections (from 3–15) addressing technology risk management.

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• Section 3: Technology Risk Governance and Oversight
• Section 4: Technology Risk Management Framework
• Section 5: IT Project Management and Security-by-Design
• Section 6: Software Application Development and Management
• Section 7: IT Service Management
• Section 8: IT Resilience
• Section 9: Access Control
• Section 10: Cryptography
• Section 11: Data and Infrastructure Security
• Section 12: Cyber Security Operations
• Section 13: Cyber Security Assessment
• Section 14: Online Financial Services
• Section 15: IT Audit

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These sections fundamentally consolidate into five core pillars of technology risk management:

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1. IT governance
2. IT project management framework
3. System security
4. IT resilience
5. Managing third-party services

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Area 1: IT governance

This area focuses on establishing an enterprise wide technology risk governance framework, including board and senior management oversight, risk management structures, and policies.. Robust IT governance leverages clear visibility into in-scope assets, systems, and technologies, which let you manage risk proactively and apply suitable controls to align with MAS TRM.

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Teams can support this governance with a project management platform such as ONES.com, which connects project plans, requirements, documentation, testing, and delivery workflows in one workspace.

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To meet MAS TRM criteria, organizations must create detailed IT plans for each project covering every phase and include:

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• The scope of the project
• Core activities
• Milestones
• Deliverables 
• Roles and responsibilities

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“Effective MAS TRM governance starts with two things: clear ownership of technology risk and a defensible inventory of IT assets and systems in scope. Once you have those foundations in place, the rest of your TRM controls become much easier to implement, manage, and demonstrate.”

Evan Rowse

GTM GRC SME, Vanta

|

LinkedIn

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For each high-impact project, establish an IT steering committee comprising key stakeholders, leadership, and relevant department leads. The committee should oversee, provide direction, and manage risks related to the projects.

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You must also establish a framework for managing the system development life cycle (SDLC) and security-by-design. This means embedding security controls in every stage of the SDLC, including initiation, design, testing, and acceptance.

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Area 2: IT project management framework

This area focuses on managing technology projects to ensure they’re delivered securely, within scope, and on time. It covers the governance, oversight, and project management practices needed to manage risk throughout a project’s lifecycle.

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To align, organizations should apply management methodologies across IT initiatives and embed access controls at each stage of the lifecycle so that only approved stakeholders can process deliverables or approve changes. Independent quality assurance adds an additional layer of oversight to validate whether your projects meet predefined outcomes before finalization.

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Another expectation is to clarify roles and responsibilities at the onset of each new IT initiative. This enables the steering committee to track stakeholder accountability and reduces ambiguity around delivery, oversight, and risk management.

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Ongoing risk assessments are also core for this area. The threats each initiative introduces can change between lifecycle phases, and continuous oversight helps detect and respond to each as they emerge. Teams with existing ISO 27001 risk assessment processes will already have a baseline for identifying threats, but they should still layer on specific MAS TRM governance requirements to comply.

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{{cta_withimage2="/cta-blocks"}} | ISO 27001 checklist

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Area 3: System security

System security focuses on protecting systems and sensitive information from unauthorized access and misuse.

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To align with the expectations for this area, implement layered security controls across relevant systems. Define a structured framework for periodic reviews to determine if:

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• Your implementations continue to be effective and relevant
• They’re applied consistently

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As part of compliance, create policies and standards for access management that apply the principles of never alone, least privilege, and segregation of duties. These measures are typically supported by strong authentication mechanisms, such as MFA or adaptive authentication, and by encryption for sensitive data, both in transit and at rest.

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Another expectation is to have regular security tests to identify and patch vulnerabilities before they escalate. MAS expects financial institutions to conduct independent vulnerability assessments and penetration testing at least annually and following major system changes. For critical systems, you should also consider red-team or adversarial testing to assess resilience against attacks. MAS-regulated financial institutions typically engage independent third- party testers to conduct these assessments.

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Security controls should also account for the entire system lifecycle, from design to deployment and ongoing maintenance.

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Area 4: IT resilience

IT resilience focuses on controls and procedures needed to keep critical systems operational during disruptions, minimizing downtime and maintaining customer trust.

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IT resilience starts with identifying critical systems and conducting business impact analyses (BIAs) for each to determine how disruptions would affect operations. The findings determine recovery time and recovery point objectives that correspond with a system’s criticality.

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Actionable business continuity, incident response, and disaster recovery plans are foundational for strong IT resilience. Each defines the processes, roles, and recovery procedures that drive response to incidents and restore critical services with minimal operational disruptions.

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Resilience plans require continuous updates to remain effective. Organizations should conduct regular stress tests and tabletop exercises to identify and fix gaps in response procedures and maintain operational readiness.

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Area 5: Managing third-party services

Relying on third-party services introduces new operational, technological, and compliance risks that should be addressed under MAS TRM. To do so, MAS requires organizations to build an effective vendor risk management framework that supports the entire vendor lifecycle.

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Vendor onboarding should include due diligence checks to verify potential vendors meet MAS TPRM criteria. Your third-party risk assessments should cover:

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• Security controls
• Governance practices
• Operational resilience
• Regulatory alignment

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A common mistake organizations make is creating robust onboarding processes for new vendors, and then underestimating the level of ongoing monitoring necessary under MAS TRM compliance. Oversight should be ongoing and extend to subcontractors (Nth-party) visibility, exit and stressed exit planning, and the right to audit and evidence collection.

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How MAS TRM maps to other frameworks

For organizations operating across borders, it’s important to balance MAS requirements with overlapping regulatory obligations in other jurisdictions to minimize duplicated work. Existing frameworks and standards may have controls and evidence you can reuse when aligning with MAS TRM.

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One of the most important is the MAS Cyber Hygiene notice, which outlines a legally binding minimum set of cybersecurity controls that organizations must implement, regardless of whether they’re also pursuing MAS TRM. MAS TRM builds on these controls by introducing broader expectations for technology risk management.

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Another important Singaporean framework is the Outsourced Service Provider Audit Report (OSPAR), published by the Association of Banks in Singapore (ABS). OSPAR helps verify that outsourced service providers meet security expectations required by financial institutions, which supports many of the third-party risk management principles of MAS TRM.

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You can also leverage ISO 27001 and SOC 2 to accelerate MAS TRM compliance. While neither guarantees full alignment with MAS TRM, both cover many of the same security, risk management, and governance controls.

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For ISO 27001 in particular, technological controls cover the bulk of what multiple MAS TRM areas cover, especially for:

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• Access management policies
• Privileged access controls
• Authentication requirements, including MFA
• Encryption algorithm and key management standards
• Secure coding and vulnerability management practices

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Aside from these, ISO 27001’s TPRM controls provide the foundation for MAS TRM’s outsourcing guidelines with controls for supplier relationships, due diligence, and ongoing vendor oversight.

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A leading enterprise compliance management solution like Vanta plays a central role in helping teams align with multiple frameworks with less duplication and better visibility. Vanta’s automation, cross-mapping, and ongoing oversight capabilities streamline control maintenance and help you build a foundation for global compliance.

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Support your MAS TRM compliance with Vanta

Vanta is the #1 agentic trust management platform for organizations scaling their compliance programs. The platform supports alignment with 35+ compliance frameworks, including ISO 27001, SOC 2, and NIST CSF, that address many core control areas of MAS TRM. You can then use Vanta’s custom framework capabilities to map existing controls to corresponding requirements.

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If you’re just starting out in your compliance journey, you can also try Vanta’s dedicated ISO 27001 and vendor risk management software to align with many MAS TRM and other compliance expectations in Singapore. The platform can support teams with:

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• 1,400+ automated tests powered by 400+ integrations
• AI-powered control mapping that helps you stay audit-ready
• Automated risk management workflows
• Access review management
• Automated evidence collection and gap remediation
• Centralized dashboards for issue tracking

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Schedule a custom demo to explore tailored compliance solutions with a Vanta expert.

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