When is a finfluencer giving regulated financial advice in Singapore?

What counts as financial advice under Singapore law?

Under the Financial Advisers Act 2001, a "financial advisory service" is any service in the Act's Second Schedule: advising others about any investment product, directly or through publications or writings in any form (print, electronic or other); issuing or promulgating research analyses or reports on investment products; and arranging life insurance. (Financial Advisers Act 2001, Second Schedule, 19 Oct 2026)

A person must not act as a financial adviser in Singapore unless they hold a financial adviser's licence for that service or are an exempt financial adviser. Doing so is an offence punishable by a fine of up to $75,000, up to 3 years' imprisonment, or both. (Financial Advisers Act 2001, s6, 19 Oct 2026)

A person must not act as, or hold themselves out as, a representative giving a financial advisory service unless they are an appointed or provisional representative for that type of service (or fall within a narrow exemption for representatives of certain exempt financial advisers). (Financial Advisers Act 2001, s22, 19 Oct 2026)

How MAS decides whether a post is advice

MAS applies a two-stage test. First, is it financial advice? Generally yes if it expresses an opinion on the merits of buying, selling or holding a particular investment product or class of products; objective factual information generally is not, unless it is presented to induce a purchase or sale. Second, is the person carrying on a business of giving that advice? MAS looks at whether the advice is given systematically and regularly, and whether the person is paid or benefits from it. (MAS Guidelines on Provision of Financial Advisory Service (FAA-G17), 10 Jul 2019)

A disclaimer such as "for information only" does not, by itself, decide whether something is financial advice. Generic opinions that are not tailored to a person, and that do not tell them to act, are less likely to be advice; answering followers one by one with buy, sell or hold calls based on their personal details is more likely to be. (MAS Guidelines on Provision of Financial Advisory Service (FAA-G17), 10 Jul 2019)

The MAS and ASAS guide for content creators says a licence may be needed when you recommend buying, selling or holding specific investment products, or tailor information to a person's circumstances, and that saying "this is not financial advice" does not remove legal liability. (MAS and ASAS, 7 Must-Knows When Sharing Financial Information Online, 25 Sept 2025)

What has MAS said about finfluencers?

In a reply to a parliamentary question for the sitting of 8 April 2025, MAS set out a short test:

MAS considers an individual to be giving financial advice if they are paid to recommend, or express an opinion on, buying, selling or holding investment products. Even if unpaid, a finfluencer who makes such recommendations regularly is treated as giving financial advice, and must first be appointed as a representative by a licensed financial advisory firm. (MAS oral reply to a parliamentary question, 8 Apr 2025, 8 Apr 2025)

MAS received eight complaints against finfluencers in 2025 (as at its 8 April 2025 reply), up from an average of five a year over the previous five years. (MAS oral reply to a parliamentary question, 8 Apr 2025, 8 Apr 2025)

Even when they are not giving advice, finfluencers must not make false or misleading statements about capital markets products, including on social media, or they may commit an offence under the Securities and Futures Act. They are also subject to the Singapore Code of Advertising Practice. (MAS oral reply to a parliamentary question, 8 Apr 2025, 8 Apr 2025)

On 25 September 2025 MAS said it would issue advisory letters to five content creators who may have provided financial advice without a licence, and that people who continue to do so will face enforcement action. (MAS media release, 25 Sep 2025, 25 Sept 2025)

What changed when MAS's Digital Advertising Guidelines took effect?

MAS issued its Guidelines on Standards of Conduct for Digital Advertising Activities on 25 September 2025. They took effect on 25 March 2026 and apply to all financial institutions and their "digital marketers", a term that expressly includes influencers and finfluencers, affiliate marketers and advertising agencies. (MAS Guidelines on Standards of Conduct for Digital Advertising Activities, 25 Sept 2025)

Content that a finfluencer posts under a tie-up with a financial institution (for example, with a referral code that rewards sign-ups) counts as an advertisement. The institution should oversee its digital marketers, is responsible for the videos they produce and for content it re-posts, and should not disclaim responsibility for parts of a video a finfluencer added. (MAS Guidelines on Standards of Conduct for Digital Advertising Activities, 25 Sept 2025)

Where relevant, ads by external marketers should clearly disclose any sponsorship, payment or commercial relationship, and ads by individual finfluencers should clearly and prominently disclose whether the person is licensed to provide regulated financial services, for example whether they are an appointed representative. (MAS Guidelines on Standards of Conduct for Digital Advertising Activities, 25 Sept 2025)

In practice, this means a post that promotes a bank, insurer, broker or investment platform under a paid tie-up is the institution's advertisement as well as the finfluencer's. If it is misleading, or if the finfluencer adds their own unapproved claims, you can raise it with the institution as well as with the person.

Will social media platforms block financial ads from unlicensed advertisers?

Under the Online Criminal Harms Act 2023, the Singapore Police Force's Code of Practice for Social Media Services (in operation from 17 August 2026) requires designated social media services to refuse ads offering financial products or services to Singapore users unless the advertiser is licensed by MAS or another Singapore authority, or is authorised by a licensed entity. "Advertiser" expressly includes content creators, influencers and affiliate marketers. Platforms have six months from the date set in their notice to put the measures in place. (Singapore Police Force, Code of Practice for Social Media Services (OCHA), 17 Aug 2026)

The code defines "advertisements" as content the platform carries as part of a service it provides for payment, so it targets paid ads, not ordinary unpaid posts. So for an ordinary post, the checks below still matter. (Singapore Police Force, Code of Practice for Social Media Services (OCHA), 17 Aug 2026)

How do I check a finfluencer before acting on their post?

Check the person, then the firm, then the alert list, using MAS's own registers. If you deal with unregulated persons, including those based overseas, you give up the protection of MAS's regulations. MoneySense points to three checks: the Financial Institutions Directory for the firm, the Investor Alert List, and the Financial Institution Representatives Register for the person. (MoneySense (Singapore government), 2 Jul 2026)

1. 1. Read the disclosure on the post

   If a financial institution is paying for the post, the person should say so, and should say whether they are licensed to give regulated financial services. No disclosure on a post that is plainly promoting a product is a reason to slow down. (MAS Guidelines on Standards of Conduct for Digital Advertising Activities, 25 Sept 2025)

2. 2. Search the person on the MAS Register of Representatives

   Anyone giving financial advice must be an appointed representative of a licensed or exempt firm. Search their name or representative number. The register shows which firm appointed them and what they may advise on. If they are not listed, they are not an appointed representative. (Financial Advisers Act 2001, s22, 19 Oct 2026)

   Open the Register of Representatives ↗

3. 3. Check the firm on the MAS Financial Institutions Directory

   Check that the firm the person names, or the firm whose product they promote, is regulated by MAS, and what it is allowed to do. Our firm search uses a dated copy of the directory; the MAS site is the authority. (MoneySense (Singapore government), 2 Jul 2026)

   Open the Financial Institutions Directory ↗

   Or search our copy of the directory.

4. 4. Check the MAS Investor Alert List

   Search the person, the firm, the website and any app or channel name they give you. (MAS Investor Alert List, 19 Oct 2026)

   Open the Investor Alert List ↗

5. 5. If it looks like a scam, call ScamShield

   You can check whether something is a scam by calling the ScamShield Helpline on 1799. Don't transfer money or share log-in details while you check. (ScamShield (Singapore government), 19 Oct 2026)

   ScamShield Helpline ↗

Being on a register shows that a firm or person is regulated. It is not an endorsement of a product or of what they say online, and a name missing from the Investor Alert List is not a sign that someone is safe. For a step-by-step screen before you hand over money, see check before you deal, and to check an adviser you have met, see how to check a financial adviser.

What are signs that a post may have crossed into advice?

These signs come from the examples in MAS's guidance; none of them settles the question on its own.

• They tell followers to buy, sell or hold a specific fund, share, policy or token.
• They answer followers one by one, using the follower's age, income or existing investments.
• They post about investment products regularly and earn from it, for example through referral codes, commission or sponsorship tied to sign-ups.
• They rely on "not financial advice" while doing any of the above.

(MAS Guidelines on Provision of Financial Advisory Service (FAA-G17), 10 Jul 2019)

Questions people ask about finfluencers in Singapore