VCC MAS Form 1 and Form 25 reporting — Step-by-step walkthrough

VCC MAS Form 1 and Form 25 reporting are the regulatory returns a Variable Capital Company and its fund manager submit to the Monetary Authority of Singapore. VCC MAS Form 1 and Form 25 reporting keep MAS informed of the VCC’s incorporation particulars and ongoing fund details, complementing the VCC’s ACRA filings and forming part of its broader compliance posture.

Raffles Corporate Services works with a panel of corporate and employment law firms; this article is general information, not legal advice.

What the MAS forms cover

The Variable Capital Companies Act 2018 places VCCs within MAS’s regulatory perimeter for anti-money-laundering and fund-oversight purposes, even though incorporation itself is administered by ACRA. Section 17 of the Variable Capital Companies Act 2018 establishes the VCC, while MAS notices set out the reporting expected of the VCC and its permissible fund manager. The forms capture incorporation particulars and the fund’s regulatory profile so MAS can supervise the sector effectively.

Because the VCC straddles two regulators, families and managers must keep their ACRA and MAS records consistent. Directors comparing structures should read our Singapore VCC vs Cayman SPC (2026): The Fund Domicile Comparison for Asian Managers on the VCC against offshore options before committing.

Who files and when

Responsibility sits with the VCC’s directors and its eligible fund manager, which must be a permissible entity under the Act. Reporting is triggered at incorporation and on specified events or periodic cycles thereafter, so it is not a single one-off submission. Because the VCC must appoint a regulated fund manager, much of the MAS-facing reporting is handled by that manager’s compliance function.

This division of labour means the choice of fund manager materially affects how smoothly the VCC’s MAS obligations are met. Governance leads weighing director duties across entities may find our Derivative Actions Against Directors in Singapore: Breach of Fiduciary Duty useful. Current procedures should be confirmed with ACRA at Accounting and Corporate Regulatory Authority (ACRA) and MAS at Monetary Authority of Singapore.

VCC MAS Form 1 and Form 25 reporting, step by step

First, confirm the permissible fund manager and its regulatory status. Second, gather the VCC’s incorporation and officer particulars. Third, complete the relevant MAS form through the prescribed channel. Fourth, align the MAS submission with the corresponding ACRA filing so the two records are consistent. Fifth, diarise any periodic or event-driven reporting so nothing is missed between annual cycles.

The reconciliation step in particular is where errors surface, because a mismatch between ACRA and MAS records can prompt queries. Our VCC AML/CFT under MAS Notice SFA 04-N02 — Step-by-step walkthrough covers the related AML/CFT obligations in detail.

AML/CFT and the manager's role

The permissible fund manager carries primary anti-money-laundering and countering-the-financing-of-terrorism duties for the VCC under MAS notices, including customer due diligence on investors. The MAS forms sit within this supervisory framework, so accurate, timely reporting is part of the VCC’s broader compliance posture rather than a stand-alone box-ticking exercise.

A VCC that treats MAS reporting as integral to its AML/CFT programme, rather than as an afterthought, is far less likely to encounter supervisory friction. The statutory basis can be checked against the Variable Capital Companies Act 2018 at Variable Capital Companies Act 2018.

Cost and timeline — the numerical breakdown

Most MAS reporting cost is absorbed within the fund manager’s compliance retainer rather than charged as a separate line. The figures below are indicative planning numbers and will vary with the manager and the complexity of the fund.

Indicative 2026 MAS reporting figures

• Fund manager compliance retainer (incl. MAS reporting): often bundled, S$10,000–S$40,000 per year.
• Permissible fund manager: mandatory — the VCC must be managed by an eligible regulated entity.
• Reporting triggers: at incorporation and on specified events or periodic cycles.
• AML/CFT due diligence: performed on investors by the fund manager.
• Consistency check: MAS and ACRA records should reconcile.

FAQs

What are MAS Form 1 and Form 25 for a VCC?
They are regulatory returns capturing the VCC's incorporation particulars and fund profile so the Monetary Authority of Singapore can supervise the sector.

Who is responsible for MAS reporting?
The VCC's directors and its permissible fund manager, whose compliance function usually handles much of the MAS-facing reporting.

Must a VCC have a regulated fund manager?
Yes. Under the Variable Capital Companies Act 2018, a VCC must be managed by a permissible, regulated fund manager.

How does MAS reporting relate to ACRA filing?
They are separate but should reconcile; ACRA handles incorporation and annual returns, while MAS oversees fund regulation and AML/CFT.

Need help with this? Call, SMS or WhatsApp +65 8501 7133, or email hello@rafflescorporateservices.com. Raffles Corporate Services works with a panel of corporate and employment law firms; this article is general information, not legal advice.