Product Governance / SC Guidelines Review

SC Product Governance Review

An independent review of a capital market product issuer's or distributor's compliance with SC's Guidelines on Product Governance, in force since 2 January 2026, for firms that built an informal process at best and now need to show one that holds up to a review.

Target market methodology tested against how products are actually identified, not just described Approval sign-off evidence checked against what the guidelines actually require Distributor due diligence reviewed where a firm distributes products it did not design
Overview

SC Product Governance Review

What it is

An independent review of a capital market product issuer's or distributor's compliance with SC's Guidelines on Product Governance: target market identification methodology, product approval process and sign-off evidence, ongoing product review and monitoring, and distributor due diligence.

Why organisations need it

The Guidelines on Product Governance took effect on 2 January 2026, which means the obligation to identify a target market, document a product approval and keep reviewing a product after launch is not new, it is overdue. Many firms have something informal: a launch meeting that happened, a target market description nobody wrote down, a review that was meant to happen and did not. A review tests what actually exists against what the guidelines expect, before a regulator or an institutional counterparty does.

Key features

What the engagement covers

Target market methodology review

How the firm identifies a target market for a product, and whether the definition is specific enough to be tested later.

Product approval process review

Who signs off a product before launch or distribution, and whether that decision leaves evidence a reviewer could later examine.

Ongoing product review assessment

Whether a review cycle exists, what triggers an early re-review, and whether it has actually been run rather than scheduled.

Distributor due diligence review

Where the firm distributes products it did not design, whether it has done the due diligence on the issuer's own product governance that the guidelines expect.

Documentation gap analysis

Product governance files checked against what the SC would expect to see in a review.

Remediation plan

Findings ranked by exposure, with owners and target dates.

Business value

What the business gets out of it

Tests practice against an already-effective guideline

The guidelines are not upcoming. This review checks where the organisation actually stands against a requirement already in force.

Independent

A review, not a referral to a compliance software vendor.

Separates issuer and distributor obligations

Findings organised by which side of the product chain owns each gap.

Ranked by exposure

Findings prioritised by regulatory and distribution risk, not listed alphabetically.

Board or management-ready reporting

A summary senior management can act on without translating it first.

How it works

How the engagement runs

01

Scoping

Product range, distribution model and existing documentation.

02

Target market review

Methodology and definitions tested against sample products.

03

Approval process review

Sign-off evidence checked against the guidelines.

04

Distributor due diligence review

Where applicable, checked against third-party product governance.

05

Report

Findings, remediation plan and a management summary.

Deliverables

What you receive

Compliance review report

Findings ranked by exposure, with evidence.

Target market gap list

Products with no, or an inadequate, target market definition.

Approval evidence findings

What is documented and what is not.

Distributor due diligence findings

Where applicable.

Remediation plan

Owners, actions and target dates.

Who it is for

Who this is built for

Industries

SMEsMid-marketLarge enterpriseGroup structures

Company sizes

Fund management companiesUnit trust management companiesStockbroking firmsOther SC-licensed product issuers and distributors

Departments

ProductComplianceLegalDistribution
Why Orbix

Why organisations choose Orbix

A governance approach, not a tool sale

We do not resell products, so nothing here is shaped by a vendor margin. The recommendation is whatever your risk and your budget actually justify, including telling you that you do not need the engagement yet.

Recommendations you can actually implement

Findings come with a sequence, an owner and a realistic effort estimate, sized to the team you have rather than the team a framework assumes. A report that cannot be acted on is an expense, not a control.

Consultants who have sat on your side of the table

Our people have carried the obligation internally, not only audited it. That shows up in what we consider proportionate, and in how much documentation we think you genuinely need.

Built for the Malaysian operating context

Work is grounded in Malaysian law and regulator expectation, from the PDPA and the Cyber Security Act 2024 to Bursa, BNM and SC requirements, rather than translated from a European or American template.

HRD Corp expertise where it applies

Where an engagement includes training, the training component is structured to be HRD Corp SBL-Khas claimable, which changes what the programme costs you in practice.

Questions

Questions we get asked

Is this guideline actually in force, or still coming?

It is in force. SC issued the Guidelines on Product Governance on 24 June 2025 and they took effect on 2 January 2026, so this review tests current compliance, not readiness for something future.

Do you apply to issuers, distributors, or both?

Both, but the obligations differ. The review tells you which obligations apply to your role in the product chain and checks each separately.

What if we distribute products we did not design?

The review covers the due diligence a distributor is expected to perform on a product it did not create, which is a distinct obligation from the issuer's own target market and approval process.

Do you replace our compliance function?

No. The review assesses the output of the existing process and reports findings; it does not run product governance on an ongoing basis.

How long does this take?

Typically three to five weeks, depending on the size of the product range and the distribution model.