AI Act vs MAS AI Guidelines: what they share and how they differ
AI Act and MAS AI Guidelines share 13 of 24 control themes and 11 checks. 55% of MAS AI Guidelines requirements can be proven with checks AI Act already uses, 36% the other way round.
Phasing in
AI Act
How to make an AI system compliant with the EU AI Act
33 requirementsNext Aug 2, 2027
Under discussion
MAS AI Guidelines
Preparing for the MAS AI risk management guidelines
11 requirementsNext Dec 2026
13/24shared control themes
11shared checks
55%of MAS AI Guidelines requirements covered by AI Act evidence
36%of AI Act requirements covered by MAS AI Guidelines evidence
At a glance
| AI Act | MAS AI Guidelines | |
|---|---|---|
| Jurisdiction | European Union | Singapore |
| Kind | Regulation | Supervisory guidelines |
| Status | Phasing in | Under discussion |
| Binding | Yes | No |
| Object analysed | AI system same | AI system same |
| Scope | Providers, deployers, importers and distributors of AI systems; providers of GPAI models. | All financial institutions supervised by MAS (banks, insurers, asset managers, intermediaries). |
| Territorial reach | Extraterritorial: applies when the system is placed on the EU market or its output is used in the EU. | Financial activities in Singapore, including branches of foreign groups. |
| Penalties | Up to €35M or 7% of worldwide turnover (prohibited practices); €15M or 3% (other obligations); €7.5M or 1% (incorrect information). | No penalty of their own. Once issued, they are supervisory expectations checked in inspections; shortcomings can lead to supervisory action. |
| Qualification axes | AI Act risk level, Organisation role, General-purpose model | Use-case risk materiality (impact, complexity, reliance) |
| Roles | Provider, Deployer, GPAI provider | Financial institution |
| Requirements | 33 | 11 |
| Next milestone | Aug 2, 2027, Annex I high risk (regulated products); GPAI placed on the market before Aug 2025 | Dec 2026, Expected issuance of the final guidelines |
Theme by theme
requirements per theme
AI ActMAS AI Guidelines
Governance
Assessment
Build
People & use
Lifecycle & third parties
What they share: one piece of evidence, two frameworks
11
| Code | Check | Requirements AI Act | Requirements MAS AI Guidelines |
|---|---|---|---|
| VER-003-01 | Documented and up-to-date risk register | ||
| VER-004-01 | Documented data governance (collection process, bias, quality) | ||
| VER-005-01 | Complete technical documentation compliant with Annex IV | ||
| VER-006-01 | Documented log retention policy | ||
| VER-008-02 | System designed to allow human oversight (stop button, override) | ||
| VER-008-03 | Competent overseers assigned to the system | ||
| VER-009-03 | Cybersecurity of the AI system verified | ||
| VER-021-D-03 | Operation monitoring | ||
| VER-AUTO-01 | Suspension procedure in the event of risk | ||
| VER-009-F-04 | Resilience to adversarial attacks tested | ||
| VER-033-D-02 | System explanation capability verified |
Differences: requirements specific to each framework
Requirements with no check serving the other framework: the extra work.
AI Act
21
EX-001
AI literacy Art. 4
EX-002
Prohibited practices Art. 5
EX-007
Transparency to deployers Art. 13
EX-010
QMS Art. 17
EX-011
10-year retention Art. 18
EX-013
Corrective actions Art. 20
EX-015
EU declaration of conformity Art. 47
EX-016
CE marking Art. 48
EX-017
EU database registration Art. 49
EX-018
Transparency for all systems Art. 50
EX-019
DPIA Art. 26§9
EX-020
FRIA Art. 27
EX-023
Accessibility Art. 16(l)
EX-024
Conformity assessment Art. 43
EX-025
EX-026
Value chain Art. 25
EX-027
Compliant use Art. 26§1
EX-028
Input data Art. 26§4
EX-029
Information to affected persons Art. 26§11
EX-030
Information to workers' representatives Art. 26§7
EX-031
GPAI obligations Art. 53
MAS AI Guidelines
5
Timelines
PastSet in the textPotentialTo verify
Nov 12, 2018MAS AI Guidelines · FEAT principles (fairness, ethics, accountability, transparency)
Apr 21, 2021AI Act · Commission proposal
Jul 12, 2024AI Act · Published in the Official Journal
Aug 1, 2024AI Act · Entry into force
Dec 2024MAS AI Guidelines · Information paper on AI model risk management
Feb 2, 2025AI Act · Prohibited practices (Art. 5) and AI literacy (Art. 4)
Jul 10, 2025AI Act · GPAI Code of Practice published
Aug 2, 2025AI Act · GPAI obligations, governance, penalties, notified bodies
Nov 13, 2025MAS AI Guidelines · Public consultation on the guidelines
Nov 19, 2025AI Act · Digital Omnibus proposal: high-risk delay tied to standards
Jan 31, 2026MAS AI Guidelines · Consultation closes
Aug 2, 2026AI Act · General application: Art. 50, sandboxes, Annex III high risk (unless Omnibus delay)
Dec 2026MAS AI Guidelines · Expected issuance of the final guidelines
Aug 2, 2027AI Act · Annex I high risk (regulated products); GPAI placed on the market before Aug 2025
Dec 2, 2027AI Act · Omnibus backstop for Annex III high risk
Dec 2027MAS AI Guidelines · End of the 12-month transition (if issued late 2026)
Aug 2, 2028AI Act · Omnibus backstop for Annex I high risk
Aug 2, 2030AI Act · High-risk systems of public authorities already in service (Art. 111)
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