Webinar Insights - Preparing for Monetary Authority of Singapore Transition Planning Guidelines for Asset Managers

Context 

MAS issued guidelines on Environmental Risk Management – Transition Planning (“TPG”) on 5 March 2026, upgrading from the 2020 Environmental Risk Management (ERM) guidelines. 

The guidelines supplement the 2020 framework and set out expectations on transition planning for banks, insurers, and asset managers. Our webinar focused on the requirements for asset managers only. 

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Key Webinar Takeaways

A key point of the guidelines is that they move beyond simple risk identification to forward-looking, strategic transition planning. 

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Scope of Action

TPG applies at entity level (firm's overall strategy) and product level (specific fund metrics), ensuring transparency for clients and regulators

• TPG applies to:

1. Asset managers which have discretionary authority over the investment portfolios they are managing
2. Where asset managers delegate investment management to sub-managers or advisors, they still retain overall responsibility for the management of climate-related risks and should thus communicate their expectations on climate-related risk management to the sub-managers or advisors
3. Asset managers that are branches or subsidiaries of global groups may take guidance from their Group’s transition planning as long as the Group’s transition planning approach meets the expectations set out in the TPG

• Proportionality principle – implementation should be calibrated to the asset manager’s size, complexity, and climate-risk exposure

Mandatory Reporting Timelines

The guidelines will apply from September 2027, following an 18-month transition window starting from the release date (5 March 2026).

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Market Context 

While the TPG focus on internal risk management and governance, Singapore’s broader regulatory roadmap for disclosures is explicitly built on the ISSB framework.

MAS has explicitly encouraged financial institutions to reference the ISSB framework and TCFD when finalising transition planning processes. 

Think of TPG as the supervisory action and IFRS S2 as the disclosure mechanism:

• MAS TPG Guidelines: These set the standard for how you manage risks, engage investee companies, and structure your board’s oversight.
• ISSB IFRS S2: This provides the global baseline for what you tell the public and investors about those transition plans.

What is a Transition Plan? 

MAS defines the process of transition planning as the internal risk management processes and strategic planning undertaken by an entity to prepare for climate-related risks and potential changes in business models associated with climate change. 

A "transition plan" refers to a documented output of the transition planning process and can be internal documents or externally disclosed.

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Building a Credible Transition Plan

A credible transition plan for an asset manager is a time-bound strategy that demonstrates how the firm will align its investment activities and business model with a net-zero trajectory, typically targeting 2050 or sooner. 

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MAS Expectations and How to Get Started 

MAS expects asset managers to adapt business models, governance arrangements, and risk management frameworks to address both transition risks (e.g., policy, technology changes) and physical risks (e.g., acute and chronic climate impacts).

Asset managers should engage customers and portfolio companies to understand, and push for progress on, their climate-related risks and management plans, rather than withdrawing investments indiscriminately. 

Asset managers should apply risk-materiality-based data collection, meaning data expectations should scale with the materiality of the counterparty’s climate risk profile, avoiding unnecessary burdens.

Asset managers should keep pace with rapid developments in climate-risk methodologies, analytics, and data sources.

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Asset managers could start the process by conducting a gap assessment against the four MAS TPG pillars presented here: 

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We suggest three key steps in building your transition plan:

A. Structure your report using the 4 Pillars of TCFD.

B. Adopt the specific data requirements of ISSB’s IFRS S2.

C. Refine your sector-specific materiality analysis using the Singapore-Asia Taxonomy (SAT) and SASB metrics.

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Data as the Foundation to Implementing Transition Planning Guidelines

The focus on stewardship is a recognition that asset managers should identify companies - especially in carbon intensive sectors - that have the ability and ambition to transition. Engagement is then used to drive this transition. This also means that data needs to support the idea that companies can viably transition.

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Relevant metrics may include:

1. Does the company have a target aligned with the trajectory its sector needs to align with 1.5 degrees?
2. Does its emissions profile suggest it can meet those targets?
3. Do real-economy plans (like fossil fuel expansion) match what is required by the target?

On the implementation side this allows us to:

1. Identify high risk companies based on sector specific transition requirements
2. Understand the gap between where companies are and where they need to get to
3. Use structured engagement to ensure progress is being made against that trajectory, supported by metrics to track progress

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Asset managers can think about completing the below steps on your data journey

Your Immediate Next Steps

1. Conduct a Gap Assessment: Compare your current internal policies against the MAS TPG
2. Budget for 2026/2027: Ensure there is a dedicated budget for specialised climate data and potentially a Stewardship Officer.
3. Engage external experts
4. Start early

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How we can support

Matter Advisory can support asset owners and asset managers across the four pillars of the guidelines from Governance and Strategy, Portfolio Risk Management, Engagement, and Disclosure and Monitoring.

Matter Data services 

Financial institutions must implement structured disclosure practices for GHG emissions associated with their investment portfolios. 

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Using Matter data, financial institutions can:

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Measure GHG emissions disclosures, in line with standardised frameworks

1. Access reported corporate GHG emissions, linked to source
2. Measure and disclose Scope 3 financed emissions in line with Partnership for Carbon Accounting Financials (PCAF) Standard. Disclose estimated and reported share

Align with standardised frameworks

Align reporting with the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD)

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Leverage Forward-Looking Metrics‍

1. Report on metrics such as the percentage of the portfolio covered by Science-Based Targets, the “Implied Temperature Rise” of the fund, or issuer's policy Cost of Carbon under different scenarios.
2. Include the qualitative and quantitative milestones required by the Guidelines to measure progress against decarbonisation commitments.

Support Portfolio Screening & Engagement  

Support screening and engagement efforts by identifying companies based on critical transition metrics, including:

1. GHG emissions driving portfolio emissions.
2. Exposure to climate solutions (aligned with IICGG).
3. Existence of Net Zero Targets or Science Based Targets.
4. Impact on portfolio temperature alignment (Implied Temperature Rise).
5. Net Zero Maturity within sectors most critical to the transition.

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Get in touch

Book an intro call and receive TPG checklist‍

You can directly book an introduction call with the team here, share your goals and receive a short gap assessment checklist:

https://tinyurl.com/y2mk93c3

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Email us

leonie@thisismatter.com

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