MAS amends SFA 04-N21 to permit alternative due-diligence steps for Global Listing Board issue managers
Issue managers on SGX-Nasdaq Global Listing Board listings may now use alternative due-diligence steps in place of the prescribed paragraph 23 procedures.
Change
On 26 June 2026 the Monetary Authority of Singapore (MAS) issued SFA 04-N21 (Amendment) 2026, permitting issue managers to adopt alternative due-diligence steps in place of paragraph 23 of the Notice on Business Conduct Requirements for Corporate Finance Advisers where appropriate for a Global Listing Board (GLB) listing, while the paragraph 19 reasonable-care obligation continues to apply.
Why it matters
The amendment opens a defined flexibility rather than a new restriction: for Global Listing Board (GLB) listings on the SGX-Nasdaq dual-listing route, issue managers may substitute alternative due-diligence steps for the procedures prescribed in paragraph 23 of the CF Notice, provided they assess those alternatives appropriately address the listing's material issues and risks. The change recognises that GLB prospectuses are prepared to US disclosure standards, making it reasonable for issue managers to apply US due-diligence practices. The baseline obligation in paragraph 19 to conduct due diligence with reasonable care, skill and diligence is unchanged, and the CF Notice's conflicts, governance, supervision, record-keeping and disclosure requirements continue to bind. The operative decision for affected firms is whether a given GLB engagement will rely on the paragraph 23 procedures or on documented, defensible alternative steps.
Implications
- — Issue managers on Global Listing Board (GLB) listings may now substitute alternative due-diligence steps for the paragraph 23 procedures, but must be able to evidence why the chosen alternatives appropriately address the listing's material issues and risks; the paragraph 19 reasonable-care obligation still applies and is the floor any alternative must clear.
- — Corporate finance advisory firms running GLB engagements should decide and document, per engagement, whether due diligence follows the prescribed paragraph 23 steps or US-practice alternatives, as the discretion now sits with the issue manager and the basis for that choice is what MAS would examine.
- — Issue managers conducting standard SGX-ST IPOs and reverse takeovers outside the GLB route see no change: paragraph 23 continues to apply in full, and the alternative-steps flexibility is confined to GLB listings.
Who is affected
- — Issue managers on SGX-Nasdaq Global Listing Board (GLB) listings
- — Corporate finance advisory firms running GLB engagements
- — Compliance teams maintaining due-diligence procedures for SGX-ST IPOs and reverse takeovers