Singapore's Shared Responsibility Framework: Why Your Bank Now Makes You Wait
A Report by CYS Global Remit FinTech Development Unit
A 12-hour delay before you can add a new payee. A 24-hour freeze on large transfers. These are not glitches — they are deliberate, regulator-mandated friction designed to stop scams before they succeed.
From Instant to Intentional
For years, digital banking has been defined by speed — instant transfers, instant payee additions, instant everything. In late 2025 and through 2026, Singapore's major banks quietly reversed that instinct for a narrow set of high-risk actions, introducing deliberate delays precisely where scammers rely on speed to succeed.
The trigger was the Shared Responsibility Framework (SRF), a joint MAS-Infocomm Media Development Authority (IMDA) initiative that took effect on 16 December 2024. The SRF formalised, as a regulatory duty rather than a voluntary best practice, a set of anti-scam controls that banks and payment service providers must now implement.
What the Framework Requires
The SRF assigns clear responsibilities across three parties in the payments chain — financial institutions, telecommunications providers, and the customer — with specific duties for each. For banks and major payment institutions, the framework mandates:
A minimum 12-hour cooling period before activating a new soft token on a mobile device
Delays before executing certain high-risk account changes, such as adding new transfer recipients, raising transfer limits, or updating registered contact details
Real-time alerts to customers when high-risk activities occur — a new device login, a changed limit, a new payee
Enhanced fraud surveillance systems calibrated to a broader range of known scam patterns
Crucially, the SRF also establishes a liability-sharing mechanism: where a financial institution or telco fails to meet its obligations under the framework and a scam results, that party may bear a share of the resulting loss — a significant shift from the earlier position where consumers bore most of the burden of proving fault.
Timeline of Rollout OCBC (2022) and UOB (December 2024) introduced kill-switch and cooling measures early. DBS completed its rollout on 7 March 2026, aligning Singapore's major local banks on friction-based anti-scam controls.
The 24-Hour Cooling-Off Period
A related but distinct safeguard — the Cooling-Off Period (COP) — took effect on 15 October 2025 across major retail banks including DBS, OCBC, and UOB. This mechanism targets a different risk pattern: rapid, large-scale fund extraction from an account.
The COP applies to accounts with balances of at least S$50,000. If a transaction, combined with withdrawals over the preceding 24 hours, would move more than 50% of an account's balance, the transaction is either rejected outright or held for a mandatory 24-hour delay. Customers are notified immediately, giving them a critical window to intervene if they realise they have been scammed.
Cash withdrawals at bank branches or ATMs are explicitly excluded from this particular safeguard — the focus is squarely on the fast, large-scale digital transfers that characterise sophisticated scam operations.
Why This Matters for Cross-Border Payments
For businesses and individuals who regularly send money internationally, these measures introduce a small but important planning consideration. Adding a new overseas recipient, or increasing your transfer limit ahead of a large payment, may no longer happen instantly — a 12-hour wait can now be built into the process.
This is a deliberate trade-off. Singapore's banks and regulators have concluded that the marginal inconvenience of a short delay is worth the substantial reduction in successful scam attempts it produces. For businesses planning time-sensitive international payments — supplier settlements, payroll runs, or large one-off transfers — building this lead time into your planning avoids unnecessary last-minute friction.
What This Means in Practice
If you plan to send a large sum to a new overseas recipient, add that payee at least a day in advance
If you need to raise your transfer limit for a big transaction, request the change with sufficient lead time
Treat unexpected requests to bypass or rush these delays — even from someone claiming to be your bank — as a serious red flag
Scam losses in Singapore reached nearly S$500 million in the first half of 2025 alone, underscoring why regulators judged this friction necessary. For legitimate customers, a short wait is a modest cost. For scammers relying on urgency and speed, it is often enough to break the chain entirely.
Sources
Monetary Authority of Singapore (MAS) — Combatting Scams / Shared Responsibility Framework: https://www.mas.gov.sg/regulation/combatting-scams
MAS-IMDA Joint Media Release — Implementation of the Shared Responsibility Framework (24 October 2024): https://www.mas.gov.sg
Association of Banks in Singapore (ABS) — Enhanced Fraud Surveillance and Cooling-Off Period (October 2025): https://www.abs.org.sg
MAS — E-Payments User Protection Guidelines: https://www.mas.gov.sg
