Proposed Joint Implementation of Supplementary Retirement Scheme (“SRS”) Framework for On-boarding and Management of SRS Product Providers

Reference: CCS 400-110-2023-001 
Notifying Parties:

The parties to the agreement are

  • DBS Bank Limited (“DBS”);
  • Oversea-Chinese Banking Corporation Limited (“OCBC”); and
  • United Overseas Bank (“UOB”),

(collectively, the “Applicants”)

Notifying Date: 10 October 2023 
Summary of transaction:

Note: The summary of the transaction posted on this Public Register is provided by the Applicants. CCCS makes no representation as to the accuracy or veracity of the summary information posted.

In 2001, the Applicants were appointed by the Minister of Finance to operate Singapore’s Supplementary Retirement Scheme (“SRS”) (i.e., appointed as SRS operators) under the Income Tax (Supplementary Retirement Scheme) Regulations 2003 (“SRS Regulations”).1 In the absence of any regulatory guidance regarding the onboarding of SRS product providers (“PPs”) and to broaden the choices of SRS investment products for consumers (“SRS Members”), the Applicants propose to jointly implement a framework to onboard and manage SRS PPs and products (“SRS Framework”).

Key provisions of the SRS Framework include:

(a) eligibility criteria for onboarding of SRS PPs and products which are based on the criteria set out in the SRS Regulations and on the principles of:

i. Risk - products have to be conservative as the funds are retirement monies;
ii. Complexity - products must be simple and easy to understand; and
iii. Transparency - pricing and other terms must be easily accessible.

(b) Initial and annual third-party audit reports to be provided by all (new and existing) SRS PPs to determine eligibility and to verify ongoing compliance with the SRS Framework respectively; and

(c) Mechanisms to enforce the SRS Framework (including to manage situations where SRS PPs or products do not comply with the SRS Framework).

Clear and transparent onboarding requirements and processes will allow for a broader range of SRS PPs to supply products in the SRS and thereby broaden the choices of SRS investment products for SRS Members.


Interested parties are invited to submit their views on the Proposed SRS Framework.  If the submission or correspondence contains confidential information, interested parties should also provide CCCS with a non-confidential version of the submission or correspondence.

Comments should reach the CCCS no later than 11 December 2023, 5.00 p.m.

Please send your comments (titled: Proposed SRS Framework by DBS, OCBC and UOB)to:



Competition and ConsumerCommission of Singapore

45 Maxwell Road


The URA Centre

Singapore 069118


Attention: Marcel TanAssistant Director (Business and Economics Division)


Supporting Documents: Please write or email your submission (titled:Proposed SRS Framework by DBS, OCBC and UOB)to the above contact details.


1Consumers contribute varying amounts to the SRS at their own discretion and contributions are used to purchase various investment instruments. The SRS Operators act as custodians of contributions made under the SRS and also help to settle transactions between SRS PPs and SRS Members.