WhatsApp for financial advisors in Singapore: what PDPA, Do Not Call and MAS allow

The Do Not Call provisions are Part 9 of the Personal Data Protection Act. They apply to a "specified message" addressed to a Singapore telephone number: broadly, a message with a marketing purpose, such as offering or promoting goods, services or an investment opportunity. The PDPC's guide says a message with both service and marketing parts counts as marketing if any part of it has a marketing purpose.

The Act defines a message as any message in sound, text, visual or other form. The PDPC's guide talks about voice calls, text messages and faxes. On our reading, a WhatsApp sent to a Singapore mobile number is a text message to that number, so the same rules apply. Your firm's compliance team may read it more strictly.

Before a marketing message, you need one of two things:

• a check against the Do Not Call Registry, made within 21 days before you send it, showing the number isn't listed, or
• the person's clear and unambiguous consent to receive those messages on that number, evidenced in writing or another form you can refer back to.

Here's how that plays out, on our reading:

• Clear and unambiguous, given through a positive action, such as ticking a box or replying yes to a specific question. The PDPC says it shouldn't be hidden in general terms and conditions.
• Specific to marketing messages sent to their Singapore number, so the person knows what they're agreeing to.
• Recorded in a form you can find again: a signed form, a saved message, a record in your CRM with the date.
• Not a condition of doing business beyond what's reasonable. The Act says consent demanded as a condition of supplying something, beyond what's reasonable to supply it, isn't validly given.
• Withdrawn as easily as it was given. Put the way to stop in your messages, such as "Reply STOP and I won't message again", and stop when asked. The PDPC's guide says to stop sending within 21 days of someone withdrawing consent.

WhatsApp's Business Messaging Policy covers both the WhatsApp Business app and the WhatsApp Business Platform. It says:

• You may only contact people on WhatsApp if they've given you their mobile number and you've received opt-in permission confirming they want to hear from you.
• You're responsible for getting that opt-in in a way that complies with the laws that apply to you.
• You must respect every request, on or off WhatsApp, to block, stop or opt out of your messages.
• Don't share or ask people to share full payment card numbers, financial account numbers, personal ID card numbers or other sensitive identifiers.
• On the Business Platform, you can reply freely within 24 hours of a customer's message. Outside that window, you can only send approved message templates.
• People can block or report a business, and WhatsApp may limit how many messages a business can send based on that feedback.

That last point is how numbers get restricted: messages people didn't ask for get reported, and the number loses its reach.

MAS's Guidelines on Standards of Conduct for Digital Advertising Activities were issued on 25 September 2025 and took effect on 25 March 2026. They apply to financial institutions and their digital marketers, who include their representatives, when advertising financial products or services through digital media such as email, websites and social media. The guidelines say re-posting or sharing content counts as disseminating an advertisement, and they ask firms to monitor what their digital marketers put out.

MAS's 2026 information paper on market conduct lists good practices it saw at firms: representatives showing their names and representative numbers on their social media accounts and digital advertisements, getting approval before using marketing material they made themselves, and sending the firm a screenshot and link within 3 days of posting.

If you post promotions to your WhatsApp status or a channel, ask your firm how these rules apply to them, and get the content approved first.

1. Use the number your firm allows for client work. Many firms want client chats on a number or system they can see and keep, so a client isn't left without their history when an advisor moves on.
2. Fill in the business profile: your name, your firm, your representative number and how else to reach you.
3. Keep a record of consent for anyone who agreed to hear about new products, with the date and how they agreed.
4. Open a Do Not Call checking account. The PDPC says a sole practitioner without a UEN can use Singpass, and each main account gets 1,000 free checks a year.
5. Check your list against the registry no more than 21 days before any marketing send, and keep the result.
6. Save quick replies for the things you type every week, such as directions to your office or what to bring to a review.
7. Label chats by where each person is, so a follow-up doesn't slip.

Good for WhatsApp:

• Meeting confirmations and reminders
• Service updates on a client's own policy
• Documents your firm allows you to send this way
• A thank-you after a meeting, with the next step and its date

Keep off WhatsApp, or ask your firm first:

• NRIC photos and personal ID numbers. WhatsApp's own policy says not to ask for them.
• Medical reports. Ask your firm how it wants them sent.
• Any promise of returns or a guaranteed outcome.
• A product recommendation before a proper fact-find.

• After a client has introduced you in a group chat: "Hi Mei Ling, Daniel here, from [firm], representative number [number]. Thanks for letting Jason connect us. Would a 20-minute call on Thursday or Saturday suit you?"
• Confirming a meeting: "Hi Mei Ling, confirming Thursday 7pm at [place]. Please bring your current policy documents if you have them. See you then."
• A review reminder to an existing client: "Hi Mr Tan, it's a year since we last went through your policies. Would you like to book a review this month? Reply with a day that suits you."
• The opt-out line for any marketing message: "Reply STOP and I won't send these again."

The WhatsApp message templates for financial advisors has more, sorted by moment.

For a client who hasn't saved your number yet, the free WhatsApp link generator makes a wa.me link and a QR code that open a chat with you, with a first message typed in.

• Send marketing broadcasts only to people who agreed to receive them, or whose numbers you checked against the registry within the last 21 days.
• Put their name in it and write it for them, so it reads like a message, not a flyer.
• Space the sends out over the hours people expect to hear from you.
• Include the opt-out line, and take anyone who replies STOP off the list that day.
• Test it on your own phone first.

• Treating WhatsApp as exempt from the Do Not Call rules.
• Adding a promotion to a service message and assuming it's still a service message.
• Broadcasting to every contact on the phone.
• Asking a client to send a photo of their NRIC.
• A profile with no name, firm or way to verify who you are.
• Keeping every client chat on a personal phone your firm can't see.

This guide is free. ActivityTracker, the app we make, is paid. Here's what it does for WhatsApp.

• The WhatsApp inbox puts every chat on one screen, and your team can work the same number from their own phones or laptops, each with read, reply or full access
• A new enquiry becomes a contact in your book, with the chat on their record
• Assign a chat to the teammate who knows the client, and leave notes the client can't see
• Broadcasts send one message at a time, spaced out, only in the hours you set, and leave out anyone marked as opted out
• Send a test to your own phone first, filled in as one of your clients