Statute Details
- Title: Securities and Futures (Designated Benchmarks) (Withdrawal and Revocation) Order 2025
- Act Code: SFA2001-S634-2025
- Legislation Type: Subsidiary legislation (SL)
- Authorising Act: Securities and Futures Act 2001 (SFA 2001)
- Authorising Provisions: Sections 123B and 123C of the Securities and Futures Act 2001
- Commencement: 1 October 2025
- Order Number / Citation: No. S 634
- Enacting Authority: Monetary Authority of Singapore (MAS)
- Made Date: 24 September 2025
- Key Operative Provisions:
- Section 2: MAS withdraws the designations of all designated benchmarks in the Schedule to the Securities and Futures (Designated Benchmarks) Order 2018.
- Section 3: Revokes the Securities and Futures (Designated Benchmarks) Order 2018.
- Legislative Status (as provided): Current version as at 27 Mar 2026
- Related Legislation (as provided): Securities and Futures Act 2001; Securities and Futures (Designated Benchmarks) Order 2018 (G.N. No. S 644/2018)
What Is This Legislation About?
The Securities and Futures (Designated Benchmarks) (Withdrawal and Revocation) Order 2025 (“the Order”) is a short but consequential piece of subsidiary legislation made by the Monetary Authority of Singapore (MAS). In plain terms, it removes Singapore’s prior “designations” of certain benchmarks—meaning MAS no longer treats those benchmarks as “designated benchmarks” under the Securities and Futures Act 2001 framework.
The Order does this in two connected steps. First, MAS withdraws the designation status of all benchmarks that were previously listed in the Schedule to the earlier Securities and Futures (Designated Benchmarks) Order 2018. Second, it revokes the 2018 Order entirely. The effect is to clear the regulatory basis for treating those benchmarks as designated benchmarks going forward from the commencement date.
Although the Order is brief, it is anchored in specific statutory powers in the Securities and Futures Act 2001. Those provisions allow MAS to withdraw designations where MAS forms the opinion that the statutory considerations for designation are no longer satisfied. The Order therefore reflects a regulatory reassessment of whether the benchmarks continue to meet the legal criteria for designation.
What Are the Key Provisions?
Section 1 (Citation and commencement) provides the formal identity of the instrument and sets the date it takes effect. The Order is cited as the “Securities and Futures (Designated Benchmarks) (Withdrawal and Revocation) Order 2025” and comes into operation on 1 October 2025. For practitioners, the commencement date is critical: it determines when the withdrawal and revocation become legally effective and when compliance obligations tied to “designated benchmark” status cease (or change) accordingly.
Section 2 (Withdrawal of designated benchmarks) is the operative provision that changes the regulatory status of the benchmarks. It states that MAS “withdraws the designations of all the designated benchmarks set out in the Schedule” to the Securities and Futures (Designated Benchmarks) Order 2018. The withdrawal is expressly justified by MAS’s opinion that “the considerations in section 123B of the Act are no longer satisfied.”
In practical terms, Section 2 does not merely amend the list; it withdraws designations for all benchmarks previously designated under the 2018 Order. This is a sweeping regulatory action. For legal and compliance teams, the key question becomes: what legal consequences flow from a benchmark losing designated status? While the Order itself does not list those consequences, the underlying statutory regime (in the Securities and Futures Act 2001) typically links designation to regulatory oversight, governance expectations, and potentially requirements relating to benchmark administration, publication, and integrity. Once designation is withdrawn, the benchmark administrators and users may no longer be subject to the designated-benchmark-specific obligations that were triggered by designation.
Section 3 (Revocation) completes the legislative change by revoking the Securities and Futures (Designated Benchmarks) Order 2018 (G.N. No. S 644/2018). Revocation is legally significant because it removes the earlier instrument from the statute book. Even if Section 2 already withdraws designations, revocation ensures there is no lingering legal instrument that could be relied upon for the continued existence of the designated benchmark list.
From a drafting and enforcement perspective, revocation also reduces interpretive uncertainty. Without revocation, parties might argue about the continued relevance of the 2018 Schedule or whether any residual designations remain. By revoking the entire 2018 Order, MAS makes clear that the designation regime established by that instrument is fully discontinued.
How Is This Legislation Structured?
The Order is structured in a conventional, minimal format for a withdrawal/revocation instrument. It contains:
(a) Section 1: Citation and commencement—identifies the instrument and sets the effective date.
(b) Section 2: Withdrawal of designated benchmarks—withdraws designations of all benchmarks listed in the Schedule to the 2018 Order, based on MAS’s opinion that statutory considerations are no longer satisfied.
(c) Section 3: Revocation—revokes the 2018 Order in its entirety.
Notably, the Order as provided does not reproduce the Schedule of designated benchmarks. Instead, it incorporates that list by reference to the 2018 Order’s Schedule. This “incorporation by reference” approach is common in Singapore subsidiary legislation: it keeps the withdrawal instrument short while still targeting the correct set of benchmarks.
Who Does This Legislation Apply To?
In scope, the Order applies to the benchmarks that were previously designated under the Securities and Futures (Designated Benchmarks) Order 2018. While the Order is not addressed to a particular class of persons (such as benchmark administrators, contributors, or users) in the text provided, the practical impact will fall on those market participants whose regulatory duties or contractual arrangements depend on whether a benchmark is “designated” under the Securities and Futures Act 2001.
Accordingly, the Order is most relevant to: (1) benchmark administrators and other persons responsible for the governance and publication of the affected benchmarks; (2) financial institutions and trading venues that use designated benchmarks in pricing, valuation, hedging, or derivatives; and (3) compliance, risk, and legal teams that maintain regulatory mappings of which benchmarks are designated and what obligations attach to that status.
Because the Order withdraws designations of all designated benchmarks listed in the 2018 Schedule, its effect is not limited to a narrow subset of benchmarks. Practitioners should therefore conduct a comprehensive review of internal benchmark inventories and regulatory compliance controls to identify whether any designated-benchmark-specific processes were implemented based on the 2018 designation list.
Why Is This Legislation Important?
Even though the Order is brief, it can have outsized consequences for market participants. “Designated benchmarks” are typically subject to heightened regulatory attention because they may be systemically important to financial markets or widely used in financial contracts and instruments. When MAS withdraws designation status, it signals that the statutory criteria for designation—captured in section 123B of the Securities and Futures Act 2001—are no longer satisfied. That change can affect how benchmarks are regulated, monitored, and relied upon.
From an enforcement and compliance standpoint, the Order creates a clear legal endpoint for the 2018 designation regime. For example, if any internal policies, contractual representations, or regulatory reporting obligations were premised on a benchmark being designated, those assumptions may need to be updated as of 1 October 2025. Practitioners should also consider whether any transitional arrangements exist in the underlying Act or in other MAS instruments. The Order itself does not mention transition, so the default position is that the withdrawal and revocation take effect on commencement.
For contractual and dispute-risk management, the withdrawal of designation status may matter where contracts define benchmarks by reference to their regulatory designation (or where they include fallback provisions tied to regulatory events). Lawyers should check whether relevant agreements (such as derivatives documentation, loan agreements, or structured products) refer to “designated benchmarks” as a regulatory category. If so, the loss of designation could trigger contractual consequences, including the need to apply fallback methodologies or renegotiate benchmark terms.
Finally, the revocation of the 2018 Order is important for legal certainty. Revocation ensures that there is no continuing legal basis for the designation list. This reduces the risk of arguments that the 2018 Schedule remains relevant after withdrawal. It also simplifies regulatory compliance: instead of maintaining a living list under the 2018 Order, parties must treat the designation framework as having been fully removed by the 2025 Order.
Related Legislation
- Securities and Futures Act 2001 (including sections 123B and 123C, which provide MAS’s powers to withdraw designations and revoke designation instruments)
- Securities and Futures (Designated Benchmarks) Order 2018 (G.N. No. S 644/2018) — the instrument withdrawn and revoked by this Order
- Futures Act 2001 (listed in the provided metadata as related legislation; practitioners should verify the precise cross-references in the benchmark designation framework)
Source Documents
This article provides an overview of the Securities and Futures (Designated Benchmarks) (Withdrawal and Revocation) Order 2025 for legal research and educational purposes. It does not constitute legal advice. Readers should consult the official text for authoritative provisions.