MAS Technology Risk Management, guidelines and notices explained
See what MAS expects of technology risk governance, resilience and cyber security, and which parts are binding notices.
Official sources
Use these official places to read the Guidelines and find the notice that applies to your type of firm.
Official website
The MAS page for the Technology Risk Management Guidelines, with the document, public feedback response and related notices.
Visit mas.gov.sg/regulation/guidelines ↗Get the document
The Guidelines and the notices are published free by MAS. The MAS cyber security page lists which technology risk and cyber hygiene notice applies to each type of financial institution.
Open the official page ↗Works alongside
NIST CSF and ISO 27001 map closely to the Guidelines. DORA is the nearest European equivalent and PDPA covers personal data in Singapore.
Browse all frameworks →What MAS TRM is
The MAS Technology Risk Management Guidelines set out principles and good practice for running technology safely in a financial institution: board oversight, secure development, resilience, access control, cyber operations, testing and audit. How far you apply them should fit the risk and complexity of your services.
Two binding notices sit beside the Guidelines. The Technology Risk Management Notice covers critical systems, recovery and incident reporting, and the Cyber Hygiene Notice sets six baseline practices. Each type of institution has its own numbered notice.
How MAS TRM got to where it is today
The milestones that changed what organisations have to do.
Guidelines issued
MAS publishes the Technology Risk Management Guidelines on 18 January 2021 to guide technology risk governance, IT resilience and cyber resilience.
Notices re-issued
Technology risk and cyber hygiene notices are re-issued under the Financial Services and Markets Act 2022 with new FSM-N numbers, effective 10 May 2024. The earlier notices are cancelled from that date.
Experts panel formed
MAS forms the Cyber and Technology Resilience Experts Panel to advise on emerging technology risks and threats facing the financial sector.
Incident reporting circular
On 16 December 2025 MAS issues a circular explaining how financial institutions should report incidents under the various acts, notices, circulars and guidelines.
Operational risk consultation
On 6 March 2026 MAS opens a consultation on updated Guidelines on Operational Risk Management, a closely related area. It closed on 20 April 2026.
Dates are for orientation. The official website holds the authoritative record.
Do you need it?
If any of these sound familiar, probably yes.
You are a bank, insurer, payments firm, fund manager or other firm regulated by MAS.
You supply technology or cloud services to Singapore financial institutions that pass these expectations on to you.
You are preparing for a MAS inspection or a customer's third-party risk review.
You run online or mobile financial services in Singapore.
What it asks of you
The guidance falls into six areas. The requirements-in-depth page walks through each chapter of the Guidelines and the two binding notices.
Governance and risk
Board and senior management ownership, policies, suppliers, people and a risk framework.
Build, change and run
Secure projects, software and API development, change, patching and incident handling.
Resilience and recovery
Availability, recovery targets, disaster recovery tests, backups and data centre protection.
Access, cryptography and data
Least privilege, strong authentication, key management, data loss prevention and network security.
Cyber operations and testing
Threat intelligence, monitoring, incident response, vulnerability assessment and penetration testing.
Customers, audit and notices
Online service security, fraud monitoring, IT audit and the binding notices.
The 7 groups, 18 areas and 115 expectations
Open any group to see each area of the Guidelines, what MAS expects, and the records worth keeping. The last group covers the two binding notices, shown in their bank versions.
18 areas · 115 expectations
g1Governance and risk (chapters 3 and 4)Who is accountable and how risk is managed.3 areas · 21 expectations
Board and senior management (3.1)The board and senior management own technology risk and cyber risk.6 expectations
- 3.1.2
Make sure the board and senior management include people who understand technology risk, including cyber threats.
What you do
- Record the technology skills of directors and executives
- Brief the board with an outside expert if skills are thin
- 3.1.3
Appoint a CIO, CTO or Head of IT and a CISO or Head of Information Security with the right expertise, with appointments at least approved by the CEO.
What you do
- Document the roles, reporting lines and CEO approval
- In a small firm, name who holds each role even if combined
- 3.1.4
Establish and implement a technology risk management strategy.
What you do
- Write a short strategy linked to business goals
- Review it at least yearly
- 3.1.5
Make key IT decisions in line with the firm's risk appetite.
What you do
- Add a risk appetite check to the IT investment approval template
- Record when a decision falls outside appetite and who accepted it
- 3.1.7
The board or a delegated committee ensures a sound risk framework, an independent technology risk function, a risk appetite and tolerance statement, regular strategy review, assessment of management competence and an independent audit function.
What you do
- Hold a documented annual board review of each listed item
- Keep the independent risk function separate from IT delivery
- 3.1.8
Senior management sets up the framework and strategy, keeps policies and standards sound and implemented, defines staff roles clearly and tells the board promptly about major adverse developments.
What you do
- Use a RACI chart for technology risk roles
- Define what triggers an escalation to the board
Evidence to keep
- Board and committee terms of reference
- Technology risk strategy and risk appetite statement
- CIO and CISO appointment and approval records
Policies, assets, suppliers and people (3.2 to 3.6)Policies, a complete asset inventory, supplier oversight, competent staff and yearly awareness training.8 expectations
- 3.2.1
Set policies, standards and procedures for technology risk, using industry standards where suitable, and review them regularly against the changing threat landscape.
What you do
- Align policies to a recognised standard such as ISO 27001 or NIST CSF
- Review each policy yearly
- 3.2.2
Review and assess the risk of any deviation from standards, have senior management approve it and review approved deviations periodically.
What you do
- Keep a deviation register with approver and expiry date
- Review open deviations every quarter
- 3.3.2
Keep an inventory of all information assets, including data, hardware and software held for customers or third parties or used by service providers, and review it when things change.
What you do
- Include cloud services and supplier-held assets in the inventory
- Assign an owner to every asset
- 3.4.2
Before contracting with a third party, assess the technology risks to the confidentiality, integrity and availability of your systems and data at that party.
What you do
- Run a security assessment during procurement
- Record the findings in the contract decision paper
- 3.4.3
Keep making sure the third party takes a high standard of care in protecting data confidentiality and integrity and keeping systems resilient.
What you do
- Review supplier assurance reports every year
- Include audit and incident notice rights in contracts
- 3.5.2
Run background checks on personnel with access to your data and systems to reduce insider threat.
What you do
- Define the checks proportionate to the role
- Extend the checks to contractors and service provider staff
- 3.6.2
Run the security awareness training programme at least annually for all staff, contractors and service providers who have access to your information assets.
What you do
- Run a yearly course with a short test
- Track completion for contractors as well
- 3.6.3
Train the board on the risks of technology use and on technology risk management practices.
What you do
- Add a yearly cyber briefing to a board meeting
- Record attendance
Evidence to keep
- Policy set with review dates
- Information asset inventory
- Third-party risk assessments
- Training records for staff and board
Technology risk management framework (4)A repeatable cycle of identifying, assessing, treating and monitoring technology risk.7 expectations
- 4.1.1
Set up a risk management framework for technology risks with clear governance, roles and reporting lines.
What you do
- Document the framework in one page of process steps
- Name a risk owner function for technology risk
- 4.1.3
Identify a risk owner who is accountable for each technology risk being treated and has the authority to manage it.
What you do
- Add an owner column to the risk register
- Confirm owners accept the role in writing
- 4.2.1
Identify threats and vulnerabilities that apply to your IT environment, including assets maintained by third-party providers.
What you do
- Run a yearly threat workshop
- Include supplier-managed systems in scope
- 4.3.2
Set criteria to measure likelihood and impact so technology risks can be prioritised.
What you do
- Define a 5 by 5 scale with examples
- Apply the same scale across all teams
- 4.4.2
Check whether residual risk is acceptable after treatment, and define criteria and approving authorities for risk acceptance that fit your risk tolerance.
What you do
- Set approval levels by risk score
- Log each accepted risk with an expiry date
- 4.5.2
Keep a risk register to monitor and report technology risks, with significant risks reported to the board and senior management at a frequency that fits the risk.
What you do
- Review the register monthly in IT leadership
- Send the top risks to the board quarterly
- 4.5.3
Develop technology risk metrics that highlight the information assets with the highest exposure, considering risk events, audit findings and regulatory requirements.
What you do
- Track a small set of metrics such as open critical vulnerabilities and incident counts
- Report the metrics in the board pack
Evidence to keep
- Risk management framework
- Risk register with owners and treatment
- Risk criteria and metrics
- Board risk reports
g2Build, change and run (chapters 5 to 7)Projects, software and day-to-day IT operations.3 areas · 28 expectations
IT projects and security by design (5)Control projects from vendor choice to testing, with security built into every phase.7 expectations
- 5.3.1
Set standards and procedures for evaluating and selecting vendors, with due diligence that fits how critical the project deliverables are.
What you do
- Use a vendor scoring template
- Scale the depth of due diligence to criticality
- 5.3.2
Assess the vendor's software development and quality assurance practices, require strong security for any sensitive data it can reach, and control and monitor vendor access to your systems.
What you do
- Give vendors time-limited, logged access
- Ask for evidence of the vendor's secure development process
- 5.4.2
Apply a security-by-design approach: build security into every phase of the system development life cycle, with security specifications in design and continuous security evaluation.
What you do
- Add a security checkpoint to each phase gate
- Involve the security team in design reviews
- 5.4.3
Set security requirements that at least cover access control, authentication, authorisation, data integrity and confidentiality, system activity logging, security event tracking and exception handling.
What you do
- Use a standard security requirements checklist for new systems
- Confirm each item in the design review
- 5.7.1
Establish a system testing methodology and an approved test plan whose scope covers business logic, system functions, security controls and performance under load and stress.
What you do
- Include security tests in every release test plan
- Get the plan approved before testing starts
- 5.7.3
Keep separate physical or logical environments for unit, integration and user acceptance testing, with need-to-know access to each.
What you do
- Split test and production accounts and networks
- Review who has access to test environments
- 5.7.5
Track issues found in testing, report major ones to the project steering committee and resolve them before deployment to production.
What you do
- Use an issue tracker with severity
- Block release if a major defect is open
Evidence to keep
- Vendor evaluation records
- SDLC framework and standards
- Security requirements and design reviews
- Signed test reports
Software development and APIs (6)Secure coding, third-party and open-source code control, DevSecOps and API safeguards.10 expectations
- 6.1.2
Adopt secure coding and source code review standards covering secure programming, input validation, output encoding, access control, authentication, cryptography and error handling.
What you do
- Adopt a standard such as OWASP guidance
- Require peer review of code before merge
- 6.1.3
Have a policy for third-party and open-source code so it is reviewed and tested before it goes into your software.
What you do
- Approve open-source libraries before use
- Scan dependencies in the build pipeline
- 6.1.4
Track updates and reported vulnerabilities for third-party and open-source code in your software so you can remediate quickly.
What you do
- Keep a software bill of materials
- Subscribe to advisories for key components
- 6.1.6
Have a comprehensive strategy to validate and test application security, which may mix static, dynamic and interactive testing, and keep the testing rules current.
What you do
- Run static and dynamic scans on every major release
- Review testing rules yearly
- 6.1.7
Track all issues found in code review and application security testing and remediate major ones before production deployment.
What you do
- Set severity-based fix deadlines
- Report open issues to release managers
- 6.3.2
In DevSecOps, apply adequate security measures and enforce segregation of duties across development, testing and release.
What you do
- Require a different person to approve production deployments
- Protect pipeline credentials
- 6.4.2-6.4.3
Vet third parties before they connect through APIs and run a risk assessment so each API is as strong as the sensitivity and criticality of the data it carries.
What you do
- Use an onboarding checklist for API partners
- Classify the data each API exposes
- 6.4.4-6.4.5
Set API security standards that protect API keys and access tokens, enforce token expiry and use strong encryption and key management for sensitive data in transit.
What you do
- Rotate API keys on a schedule
- Use short-lived tokens
- 6.4.6-6.4.7
Test API security before go-live, log third-party sessions (who, when, what data), monitor in real time and be able to revoke keys or tokens quickly after a breach.
What you do
- Log every API call with caller identity
- Test the key revocation procedure
- 6.5.2-6.5.3
Control and monitor shadow IT and end-user developed or acquired applications: assess their risk, approve them before use and test them before deployment.
What you do
- Keep an approved application list
- Review spreadsheets and macros used for critical processes
Evidence to keep
- Secure coding standard
- Application security test reports
- Open-source component inventory
- API security standard and access logs
IT service management (7)Disciplined configuration, patching, change, release, incident and problem processes.11 expectations
- 7.2.1-7.2.2
Keep accurate configuration information on hardware and software and verify it regularly.
What you do
- Use a configuration database or asset tool
- Reconcile it with live systems every quarter
- 7.3.1-7.3.2
Avoid outdated or unsupported hardware and software, watch end-of-support dates, and have a technology refresh plan and a risk assessment for items nearing end of support.
What you do
- Track vendor support end dates in the asset register
- Schedule replacement before end of support
- 7.3.3
Obtain management dispensation, with a validity period matching the risk, for continued use of unsupported technology and review it periodically.
What you do
- Record dispensations with compensating controls
- Expire dispensations automatically unless renewed
- 7.4.1-7.4.2
Have a patch management process that applies patches within a timeframe that fits their criticality and tests patches before production.
What you do
- Set patch deadlines by severity
- Test patches on a staging system
- 7.5.1-7.5.3
Assess, test, review and approve changes before implementation, with a risk and impact analysis, tests in a test environment and signed-off results.
What you do
- Use a change request template with risk fields
- Require test evidence before approval
- 7.5.4-7.5.5
Use a change advisory board to approve and prioritise changes, take a backup before the change and have a rollback plan.
What you do
- Hold a weekly change meeting
- Record the backup and rollback step in every change
- 7.5.6
Define procedures and approvers for urgent or emergency changes, such as a high priority security patch.
What you do
- Write an emergency change procedure
- Review all emergency changes afterwards
- 7.6.1-7.6.2
Segregate duties in software release so no one person can develop, compile and move code between environments, and keep traceability and integrity of code that moves.
What you do
- Use pipeline approvals
- Sign build artefacts
- 7.7.1-7.7.3
Set up an incident management framework to restore service to a secure and stable state quickly, covering handling of IT and cyber incidents, protection of evidence and clear roles for recording, escalation, decisions and resolution.
What you do
- Write an incident procedure with severity levels
- Keep an on-call roster and forensic readiness plan
- 7.7.5-7.7.7
Keep senior management informed during major incidents, keep a communications plan for customers and the media, and give customers timely updates and advice where appropriate.
What you do
- Draft holding statements in advance
- Name spokespeople and channels
- 7.8.1-7.8.3
Run problem management to find root causes, keep a record of past incidents with lessons learnt and analyse trends to decide on further corrective action.
What you do
- Hold a post-incident review for every major incident
- Review incident trends every quarter
Evidence to keep
- Configuration records
- Patch and end-of-support tracker
- Change records with approvals and rollback plans
- Incident and problem records with lessons learnt
g3Resilience (chapter 8)Keeping systems available and recoverable.2 areas · 12 expectations
Availability, recovery and backup (8.1 to 8.4)Systems that stay up, recover to agreed targets and can be restored from protected backups.8 expectations
- 8.1.2
Use redundancy or fault-tolerant design for systems needing high availability, review architecture and dependencies for single points of failure, and test resilience regularly.
What you do
- Map internal and external dependencies of critical systems
- Test failover at least yearly
- 8.1.3-8.1.4
Monitor system resource use against thresholds and have procedures for when thresholds are breached.
What you do
- Set alerts on capacity thresholds
- Document the response steps
- 8.2.1
Set recovery time and recovery point objectives for systems aligned to business priorities.
What you do
- Agree objectives with business owners
- Record them in the asset register
- 8.2.2
Keep a disaster recovery plan covering various disaster scenarios and responsibilities, reviewed at least annually and when material changes occur.
What you do
- Review the plan each year and after major change
- Keep a printed copy off-site
- 8.3.1-8.3.3
Test the disaster recovery plan regularly with business and IT participants, using plausible scenarios including full and partial loss of the primary site and dependencies on third parties.
What you do
- Run a yearly recovery exercise against the objectives
- Record issues and fix them
- 8.3.4
Assess the disaster recovery capability of service providers that manage your assets and test the recovery steps that need coordinated action.
What you do
- Request the provider's recovery test results
- Run a joint test with critical providers
- 8.4.1-8.4.3
Have a backup strategy and plan, a policy for the backup data life cycle (frequency, retention, storage, destruction) and periodically test restoration.
What you do
- Follow a 3-2-1 backup approach
- Restore a sample from backup each quarter
- 8.4.4
Protect confidential backup data, for example by encryption, and store backup media offline or offsite.
What you do
- Encrypt backups
- Keep an offline or immutable copy
Evidence to keep
- Architecture and dependency maps
- RTO and RPO register
- Disaster recovery plan and test reports
- Backup policy and restore test results
Data centre resilience (8.5)Protect the facilities that host your systems from physical and environmental threats.4 expectations
- 8.5.1
Run a threat and vulnerability risk assessment for your data centres, covering physical and environmental threats and the country's political and economic climate, and review it after significant change.
What you do
- Include hosted and colocation sites
- Re-run after a material change
- 8.5.2-8.5.3
Provide redundancy for power, network and cooling to remove single points of failure, and fit fire detection and suppression.
What you do
- Confirm provider redundancy by contract and audit report
- Review fire protection certificates
- 8.5.4
Place the secondary or disaster recovery data centre in a different geographic location from the primary so one disruption cannot hit both.
What you do
- Check the separation distance and shared infrastructure
- Document the reasoning
- 8.5.5-8.5.6
Monitor physical and environmental controls round the clock and control physical access with need-based access, visitor approval and escort, secured access points and restricted equipment racks.
What you do
- Review data centre access lists every quarter
- Keep visitor logs
Evidence to keep
- Threat and vulnerability risk assessment of each data centre
- Redundancy design records
- Physical access logs and reviews
g4Security controls (chapters 9 to 11)Access, cryptography, data and infrastructure.4 areas · 22 expectations
Access control (9)Least privilege, strong authentication and tight control of privileged and remote access.7 expectations
- 9.1.1-9.1.2
Apply never alone, segregation of duties and least privilege, and run an access management process to provision, change and revoke rights with approval from the information asset owner.
What you do
- Use role-based access with owner approval
- Have a second person approve sensitive changes
- 9.1.3
Log user access and user management activities with unique identification for audit and investigation.
What you do
- Give every user a unique ID
- Keep logs of access changes
- 9.1.4-9.1.5
Enforce a password policy with strong controls and use multi-factor authentication for users with access to sensitive system functions.
What you do
- Enable MFA for admins and finance systems
- Block weak passwords
- 9.1.6-9.1.7
Review user access periodically to find dormant, redundant and inappropriate rights, and revoke access promptly when roles change or people leave.
What you do
- Run access reviews by system owner
- Trigger removal from HR leaver events
- 9.1.8
Subject service providers with access to your assets to the same monitoring and restrictions as your own staff.
What you do
- Give providers named accounts with logging
- Review provider access every quarter
- 9.2.1-9.2.2
Grant privileged access on a need-to-use basis, log and review its activity, and manage and monitor system and service accounts.
What you do
- Use a privileged access vault
- Review service account usage
- 9.3.1-9.3.2
Encrypt remote connections, use strong authentication such as MFA for remote access and allow it only from devices secured to your standards.
What you do
- Require VPN or zero trust access with MFA
- Check device compliance before connecting
Evidence to keep
- Access management procedure
- Access review records
- Privileged account inventory and logs
- Remote access and MFA configuration
Cryptography (10)Sound algorithms and careful key management.4 expectations
- 10.1.2-10.1.5
Use algorithms from well-established international standards with suitable key lengths, vetted and tested, and monitor developments in cryptanalysis to update algorithms when needed.
What you do
- Publish an approved algorithms list
- Review it yearly
- 10.2.1-10.2.3
Have a key management policy covering the key life cycle, protect keys from disclosure and set a lifespan for each key based on risk.
What you do
- Maintain a key inventory with owners and expiry
- Rotate keys before expiry
- 10.2.4-10.2.6
Store sensitive keys in hardened tamper-resistant systems such as a hardware security module, distribute them by secure means and use each key for a single purpose.
What you do
- Use a managed HSM or cloud key service
- Separate encryption and signing keys
- 10.2.7-10.2.10
Revoke and replace compromised keys and related keys, destroy expired or revoked keys securely and keep protected backups of keys.
What you do
- Write a key compromise runbook
- Test key recovery
Evidence to keep
- Cryptography standard
- Cryptographic key inventory
- Key management procedures
Data protection (11.1)Prevent leakage and loss of confidential data in motion, at rest and in use.4 expectations
- 11.1.1-11.1.2
Develop data loss prevention policies and measures that detect and prevent unauthorised access, change, copying or transfer of confidential data in motion, at rest and in use, with service providers held to the same standard.
What you do
- Deploy DLP on email and endpoints
- Include cloud storage in scope
- 11.1.3-11.1.5
Encrypt and strongly control confidential data on systems and endpoints, allow only authorised media and devices to store or send it, and prevent and detect use of unauthorised internet services.
What you do
- Enforce full-disk encryption
- Block unsanctioned file sharing sites
- 11.1.6
Restrict sensitive production data in non-production environments, require senior management approval for exceptions and mask the data where possible.
What you do
- Use masked test data
- Log any approved exceptions
- 11.1.7
Irrevocably delete confidential data from media, systems and endpoints before disposal or redeployment.
What you do
- Use certified wipe tools
- Keep a disposal certificate
Evidence to keep
- Data loss prevention policy and tooling
- Encryption configuration
- Non-production data controls
- Disposal records
Network, system, virtualisation and IoT security (11.2 to 11.5)Segment and harden networks and systems, and control virtual and connected devices.7 expectations
- 11.2.1-11.2.4
Install firewalls at internet and third-party connections, segment assets by criticality, deploy network intrusion prevention and use network access controls to block unauthorised devices.
What you do
- Segment production, corporate and guest networks
- Enable intrusion prevention on perimeter devices
- 11.2.5-11.2.8
Review network access rules regularly, remove obsolete rules and insecure protocols, consider isolating web browsing, deploy effective DoS protection and review the network architecture periodically.
What you do
- Review firewall rules every six months
- Use a DoS mitigation service for internet-facing systems
- 11.3.1-11.3.2
Set security configuration standards for hardware and software, review them periodically and check systems conform, addressing deviations in time.
What you do
- Use hardening baselines such as CIS Benchmarks
- Scan for configuration drift
- 11.3.3-11.3.6
Use endpoint protection, keep anti-malware current, scan for indicators of compromise, monitor for anomalies and use controls such as application allow-listing.
What you do
- Deploy EDR on all endpoints and servers
- Allow-list software on critical servers
- 11.3.7
Before allowing BYOD, run a comprehensive risk assessment and apply suitable measures to secure personal devices.
What you do
- Use mobile device or application management
- Separate work and personal data on devices
- 11.4.1-11.4.3
Set security standards for all virtualisation components, restrict administrative access to hypervisors and host systems and govern virtual images and snapshots.
What you do
- Harden hypervisors
- Control who can create and copy images
- 11.5.1-11.5.5
Keep an inventory of IoT devices, assess and mitigate their risks, host them in a separate network segment, prevent unauthorised access and monitor for anomalies.
What you do
- Put cameras and printers on their own VLAN
- Change default credentials on all devices
Evidence to keep
- Network diagrams and firewall rule reviews
- Security configuration baselines
- Endpoint protection coverage report
- IoT device inventory
g5Cyber operations and testing (chapters 12 and 13)Detect, respond and test.2 areas · 11 expectations
Cyber security operations (12)Know the threats, watch your systems and respond to cyber incidents.5 expectations
- 12.1.1-12.1.2
Collect and analyse cyber-related information on threats and vulnerabilities, procure cyber intelligence monitoring and take part in trusted threat information sharing.
What you do
- Subscribe to a sector sharing group
- Triage intelligence weekly
- 12.2.1
Set up a security operations centre or buy managed security services, with defined processes, roles and responsibilities.
What you do
- Use a managed detection and response provider if you lack a team
- Define escalation contacts
- 12.2.2-12.2.3
Collect, review and retain system logs and protect them from unauthorised access, and baseline routine activity so anomalies can be found.
What you do
- Send logs to a central protected store
- Review baselines each year
- 12.2.5-12.2.6
Correlate events across logs to spot suspicious patterns and escalate suspicious activity to the right stakeholders in good time.
What you do
- Create correlation rules for common attack patterns
- Define escalation timings by severity
- 12.3.1-12.3.3
Maintain a cyber incident response and management plan to isolate and neutralise threats and resume services securely, investigate the control failures that allowed the breach and feed lessons into controls and the plan.
What you do
- Rehearse the plan with a scenario each year
- Track post-incident improvements to closure
Evidence to keep
- Threat intelligence feeds and sharing arrangements
- SOC or managed security service contract
- Log collection and retention settings
- Cyber incident response plan
Cyber security assessment (13)Test your defences and fix what you find.6 expectations
- 13.1.1-13.1.2
Run regular vulnerability assessments at a frequency that fits system criticality and exposure, covering vulnerability discovery, weak configurations, open ports and application vulnerabilities.
What you do
- Scan internet-facing systems at least monthly
- Include web application checks
- 13.2.1-13.2.3
Carry out penetration testing, using blackbox and greybox testing for online financial services, and test the production environment with proper safeguards.
What you do
- Hire an accredited testing firm
- Agree rules of engagement before testing
- 13.2.4
Set penetration test frequency by criticality and exposure, and test internet-facing systems at least once a year or after major changes.
What you do
- Add a post-change test trigger
- Keep the previous test report to show improvement
- 13.3.1-13.3.2
Run regular scenario-based cyber exercises, such as table-top, social engineering or cyber range exercises, involving senior management, business, communications and service providers.
What you do
- Hold a yearly table-top exercise
- Include a key supplier
- 13.4.1-13.4.2
Run adversarial attack simulation exercises with defined objectives, scope and rules of engagement, supervised so they do not disrupt production.
What you do
- Use an intelligence-led red team for critical services
- Brief the control group before the exercise
- 13.6.1
Have a remediation process that classifies the severity of issues from assessments and exercises, sets timeframes by severity and handles deviations through risk assessment and mitigation.
What you do
- Track findings in one register with deadlines
- Escalate overdue critical findings
Evidence to keep
- Vulnerability assessment reports
- Penetration test reports
- Exercise records
- Remediation tracker
g6Customers and audit (chapters 14 and 15)Online services, fraud and independent assurance.2 areas · 9 expectations
Online financial services (14)Protect online and mobile services, customer authentication and transactions.6 expectations
- 14.1.1-14.1.3
Apply security measures that fit the risk of online services, secure communication channels with encryption and signatures, and reduce exposure to common attacks such as injection, scripting, man-in-the-middle, DNS hijacking, DDoS and spoofing.
What you do
- Run web application firewall and TLS on customer channels
- Test against common web attack lists
- 14.1.4-14.1.7
Address mobile application risks, distribute apps only through official stores or secure channels, monitor and act on phishing against you and your customers, and block rooted or jailbroken devices from financial transactions unless the app is protected.
What you do
- Use app attestation and jailbreak detection
- Run a takedown process for phishing sites
- 14.2.1-14.2.3
Use multi-factor authentication at customer login, protect passwords with end-to-end encryption, and use transaction signing for high-risk activities such as changes to sensitive data, new payees, high-value transfers and limit changes.
What you do
- Require a second factor for new payees
- Sign high-risk transactions
- 14.2.5-14.2.11
Make one-time passwords short-lived, encrypt biometric and credential data, calibrate biometric accuracy to risk, control soft token provisioning, keep sessions intact and end them after inactivity, assess corporate customer controls and store credentials in a form resistant to reverse engineering.
What you do
- Set session timeouts
- Bind soft tokens to registered devices
- 14.3.1-14.3.3
Run real-time fraud monitoring, investigate suspicious transactions and notify customers of suspicious activity or transfers above a threshold.
What you do
- Send instant alerts for large transfers
- Review fraud rules after each incident
- 14.4.1-14.4.3
Educate customers on security best practices, alert them to new cyber threats and tell them how to detect and report unauthorised transactions.
What you do
- Publish short security tips in the app
- Send alerts during active scam campaigns
Evidence to keep
- Online channel security design
- Customer authentication configuration
- Fraud monitoring rules
- Customer communications
IT audit (15)Independent assurance on technology risk.3 expectations
- 15.1.1
Make sure IT audit gives the board and senior management an independent, objective opinion on the adequacy and effectiveness of technology risk management, governance and controls.
What you do
- Report IT audit results directly to the audit committee
- Keep audit independent of IT delivery
- 15.1.2-15.1.3
Identify a comprehensive set of auditable areas covering all IT operations, functions and processes, and set audit frequency by criticality and risk.
What you do
- Build an IT audit universe and risk-rank it
- Audit critical systems more often
- 15.1.4
Make sure IT auditors have the skills to assess IT policies, procedures, processes and controls.
What you do
- Fund certifications for IT auditors
- Use specialists for complex areas
Evidence to keep
- IT audit plan and universe
- Audit reports and findings
- Auditor competence records
g7Binding notices (banks)The two notices MAS makes binding, with equivalents for other firm types.2 areas · 12 expectations
Cyber Hygiene Notice (bank version FSM-N06)Six binding cyber hygiene practices for banks. Other firm types have equivalent notices.6 expectations
- FSM-N06 4.1
Secure every administrative account on operating systems, databases, applications, security appliances and network devices to prevent unauthorised access or use.
What you do
- Inventory all admin accounts and vault their credentials
- Use separate named admin accounts
- FSM-N06 4.2
Apply security patches to every system within a timeframe that fits the risk of each vulnerability, and where no patch exists put controls in place to reduce the risk.
What you do
- Set patch deadlines by severity
- Apply virtual patching or isolation where a patch is not available
- FSM-N06 4.3
Have a written set of security standards for every system and make each system conform, with controls to reduce risk where a system cannot conform.
What you do
- Publish a baseline per platform
- Record approved exceptions with compensating controls
- FSM-N06 4.4
Put controls at the network perimeter to restrict all unauthorised network traffic.
What you do
- Default-deny inbound rules
- Review perimeter rules regularly
- FSM-N06 4.5
Implement one or more malware protection measures on every system, where such measures are available and can be implemented.
What you do
- Install endpoint protection on all supported systems
- Document systems where it is not possible
- FSM-N06 4.6
Use multi-factor authentication for all administrative accounts on critical systems and for all accounts on any system used to access customer information through the internet.
What you do
- Enable MFA on admin consoles and customer data portals
- Review coverage every quarter
Evidence to keep
- Administrative account inventory and patch compliance reports
- Written security standards per system
- Firewall rule sets and malware protection coverage
- MFA coverage report
Technology Risk Management Notice (bank version FSM-N05)Binding duties for banks on critical systems, availability, recovery, incident reporting and customer data controls.6 expectations
- FSM-N05 para 4
Put in place a framework and process to identify critical systems.
What you do
- Define criteria for criticality
- Review the list yearly
- FSM-N05 para 5
Make all reasonable effort to keep critical systems highly available, with unscheduled downtime affecting operations or customers not exceeding 4 hours in total in any 12 months.
What you do
- Track downtime per critical system
- Investigate each outage against the 4 hour limit
- FSM-N05 para 6
Set a recovery time objective of not more than 4 hours for each critical system, and validate and document at least every 12 months how recovery testing is done and when the objective is validated.
What you do
- Test recovery of each critical system annually
- Keep the test record and result
- FSM-N05 para 7
Notify MAS as soon as possible, and no later than 1 hour, after discovering a relevant incident (a severe and widespread system malfunction or IT security incident, or one materially affecting customer service).
What you do
- Pre-agree who makes the call and who notifies
- Keep the MAS reporting template ready
- FSM-N05 para 8
Submit a root cause and impact analysis report to MAS within 14 days of discovering the relevant incident, unless MAS allows longer, covering an executive summary, root cause, impact and remedial measures.
What you do
- Use a standard report template
- Start the root cause review as soon as service is stable
- FSM-N05 para 9
Implement IT controls to protect customer information from unauthorised access or disclosure.
What you do
- Map customer data stores and their access controls
- Test controls through regular reviews
Evidence to keep
- Critical systems register
- Downtime and availability records
- Recovery test validation records
- Incident notifications and root cause reports
Nothing matches. Clear the search or pick another chapter group.
Outcomes and implementation examples are from MAS Guidelines on Risk Management Practices - Technology Risk, with Notices FSM-N05 and FSM-N06, published by NIST. Descriptions of what to do and the evidence lists are our own plain-English guidance. Check the official source for the authoritative text.
Your path to getting started
Five steps from first look to evidence you can show MAS. Effort depends on your size and starting point.
- 1
Find your notice
Use the MAS cyber security page to see which technology risk and cyber hygiene notice applies to your firm type.
- 2
Identify critical systems
List the systems whose failure would seriously disrupt operations or customers.
- 3
Assess against the Guidelines
Score each chapter against what you do today and record where you deviate and why.
- 4
Close gaps with evidence
Fix gaps, set recovery tests and keep proof for each expectation.
- 5
Set up incident reporting
Agree who decides, who reports to MAS and how, and rehearse it.
How Optimus GRC helps
Each area maps to a part of the platform, so the work and the evidence sit together.
| What it asks | What you do in Optimus GRC |
|---|---|
| Governance and risk | Roles, risk register and board reporting |
| Build, change and run | Change records, test reports and incident log |
| Resilience and recovery | Recovery objectives, test results and backup records |
| Access, cryptography and data | Access reviews, key inventory and security standards |
| Cyber operations and testing | Monitoring coverage, test reports and exercise outcomes |
| Customers, audit and notices | Fraud controls, audit plans and notice evidence |
Free MAS TRM readiness checklist
A one-page PDF you can print or share with your team. No sign-up needed.
Download the checklist (PDF)- Critical systems register
- Technology risk policy template
- Recovery and incident reporting checklist
- Cyber hygiene evidence tracker
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<a href="/frameworks/mas-trm/">MAS TRM explained in plain English - Optimus CyberX</a>Common questions
Are the MAS Guidelines mandatory?
The Guidelines themselves are guidance. MAS says how far you apply them should fit your risk and complexity, and it considers how closely you follow their spirit when it supervises you. The notices are binding.
Which notice applies to us?
It depends on the type of institution. Banks, for example, follow FSM-N05 (technology risk management) and FSM-N06 (cyber hygiene). The MAS cyber security page has a table of the notice for each type, effective 10 May 2024.
What must banks report after a serious incident?
Under the bank notice, tell MAS as soon as possible and no later than 1 hour after discovering a relevant incident, then submit a root cause and impact report within 14 days unless MAS allows longer.
What if we cannot control a system, such as one run by a supplier?
The cyber hygiene notice excuses a requirement only to the extent you cannot control the system directly, cannot require the provider to comply, and it is not reasonable to switch to a provider you can control. Check the exact notice for your firm type.
Related frameworks
See how ready you are for MAS TRM
Answer questions across every area. We email you a report showing where you comply and where you do not.