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Section 13U for a Family Office Under FDD Circular 05/2026: Enhanced-Tier Conditions Corrected for 2026

By VCC Editorial Team · Published 26 May 2026 · Updated 8 November 2026

Short answer: Under MAS FDD Circular 05/2026, a new section 13U award for a single family office fund approved on or after 1 August 2026 requires 3 qualifying investment professionals (2 at application), S$50 million in designated investments at application and every year end, tiered local spending from S$200,000, the capital deployment requirement and a private banking account.

This article is general information only and is not legal, tax or immigration advice. For matters needing legal advice, we work with a panel of experienced Singapore law firms.

This guide restates the section 13U conditions for a family office fund as they stand on 8 November 2026. It replaces the 26 May 2026 version of this page, which predated MAS FDD Circular 05/2026. Every threshold is quoted from the Circular and its Annex 7, checked on 8 November 2026. The parallel 13O rules are in our companion piece, Section 13O conditions for a VCC family office; this article covers what is particular to 13U.

What does section 13U offer a family office fund in 2026?

Section 13U exempts specified income from designated investments for an approved fund vehicle managed by a Singapore-based fund manager, including an exempt SFO. It is the enhanced tier: higher entry conditions than 13O, in exchange for wider freedom on the form and structure of the vehicle.

The Circular makes 13U available to “any approved standalone fund vehicle” or to vehicles in three approved structures: master-feeder, master-feeder holding investments through special purpose vehicles (SPVs), and master fund with SPVs (paragraph 2.5). Section 13O is confined to Singapore-resident companies, and 13OA to Singapore limited partnerships.

The exemption is available “for the life of the fund”, and funds awarded before the schemes expire on 31 December 2029 keep it while they meet the conditions in each basis period (paragraph 2.3). Failing an economic condition costs that basis period’s exemption only; failing a non-economic condition, such as not producing documents on request, can lead to permanent revocation (paragraph 2.4).

Which 13U conditions apply to a new SFO award approved from 1 August 2026?

Five conditions apply, set out in paragraphs 4.4 and 4.5 of the Circular. Two are specific to 13U (headcount and asset size); three are shared with 13O and 13OA.

An SFO fund is a vehicle whose assets come primarily from one family, managed by an SFO exempt from licensing under paragraph 5(1)(ba) of the Second Schedule to the Securities and Futures (Licensing and Conduct of Business) Regulations (footnote 3). The licensing exemption is a separate question; see family office licensing exemption or tax incentive.

Condition	Requirement for a new 13U SFO award	Circular reference
Investment professionals	SFO employs at least 3 qualifying IPs throughout each basis period, at least 1 a non-family member. Application may proceed with 2 (family members or otherwise); the third, including the non-family IP, must be in place by the end of the basis period of the first Year of Assessment (YA), or the award is revoked from its commencement date	Para 4.4(a), footnote 21
AUM in designated investments	At least S$50 million at application and at the end of each basis period; reported on those two dates only, not tracked continuously	Para 4.4(b), footnote 22
Local spending	S$200,000, S$500,000 or S$1,000,000 by AUM in DI at year end; the upper tiers may be met partly through eligible donations and blended finance grants, subject to a minimum amount of local business spending	Para 4.5(a), Table C
Capital deployment requirement (CDR)	Lower of 10% of AUM in DI or S$10 million in specified investments, first tested at the end of the basis period for the first full YA after commencement	Para 4.5(b)
Banking account	Private banking account with an MAS-licensed financial institution at application and throughout each basis period; MAS may revoke the award if breached	Para 4.5(c)

A qualifying IP is a portfolio manager, research analyst or trader who is a Singapore tax resident, earns more than S$3,500 a month and is engaged substantially in fund management (footnote 18). In the Circular’s example, a 13U award commencing on 1 August 2026 with a 31 December year end needs the third IP by 31 December 2026, or it is revoked from 1 August 2026. The hiring plan belongs in the application file.

Investment in the family’s operating businesses, “whether in the form of equity, debt or other financing arrangements”, cannot count towards the S$50 million minimum, though it counts for the other conditions if it qualifies as a designated investment (footnote 22). Spending tiers and donations are covered in our guide to 13U local business spending; the banking condition, including the position after the transitional grace period, is in our note on the SFO fund banking account condition.

How does section 13U differ from 13O for an SFO fund?

For new SFO awards, the two schemes now share the spending, capital deployment and banking conditions. The differences are headcount, asset size, vehicle form, structure and the fund administrator rule.

Point	13O / 13OA SFO fund	13U SFO fund
Qualifying IPs	2 (1 at application)	3 (2 at application)
Minimum AUM in DI	S$20 million	S$50 million
Eligible vehicle	Singapore-incorporated, Singapore-resident company (13O) or Singapore limited partnership (13OA)	Any standalone vehicle, or an approved master-feeder or SPV structure
Singapore fund administrator	Required	Required only where the fund, master fund or feeder fund is a Singapore-incorporated, Singapore-resident company (Annex 7, para 1(b))
Local spending, CDR, banking	Same tiers and tests (paras 4.5(a) to (c))

The choice for a fund above S$50 million is analysed in our 13O vs 13U decision guide for a new SFO fund.

How are the 13U conditions applied across a master-feeder or SPV structure?

Since 1 January 2025, a 13U structure meets its economic conditions once, as though it were a single standalone fund (paragraph 5.3(a); Annex 7, paragraph 3).

Previously each additional SPV or trading feeder carried its own AUM and spending requirements. In the Circular’s example, a master fund with 2 SPVs and S$100 million of AUM in DI now incurs one S$200,000 of local business spending as a structure. The same logic runs through the other conditions:

• Capital deployment: the structure meets the CDR if the approved entities collectively invest at least the lower of 10% of the structure’s total AUM in DI or S$10 million in specified investments (footnote 26).
• Banking: the condition is met if at least one approved entity in the structure owns the private banking account (footnote 31).
• Failure: if the structure fails a condition for a basis period, all entities in it lose the exemption for the corresponding YA (Annex 7, paragraph 7).

The structure rules also impose design constraints. Where SPVs are used, the master fund must be a Singapore company, trust or limited partnership that is Singapore tax resident for each basis period, and a limited partnership master qualifies only if all its partners are Singapore tax residents (Annex 7, paragraph 5(a) and footnote 110). Feeder funds and SPVs may be constituted in any form, with no limit on the number of SPV tiers. Co-investors in an SPV must be funds incentivised under sections 13D, 13O, 13OA, 13U or 13V, or non-resident foreign investors meeting the conditions the Circular cross-refers to in section 13U(5) (Annex 7, paragraph 5(c) and footnote 111).

Adding a feeder fund or SPV after approval needs MAS approval, and the structure must meet the S$50 million AUM in DI condition at the point of that application. Removing one needs only an update to MAS, with no AUM test (Annex 7, paragraph 6). Headroom above S$50 million is therefore a design point. For private credit holdings, which often sit in SPVs, see our guide to family office private credit through a 13O or 13U fund.

Which other 13U scheme conditions catch family offices out?

Beyond the SFO economic conditions, Annex 7 paragraph 1 sets general conditions for every 13U fund, and the standard terms in Annex 13 now apply to all awards.

• Investment purposes only, and no concurrent tax incentive scheme (Annex 7, paragraph 1(c) and (d)). A move to section 13D requires termination of the 13U award first (footnote 105).
• Singapore residence where the fund is a Singapore company: the Circular says control and management in Singapore generally requires board meetings in Singapore where strategic decisions are made (footnote 103). IRAS sets out the test on its tax residency of a company page.
• Part years. Conditions are prorated only for a basis period in which the award starts or ends: an award starting on 1 October 2026 with a December year end has its S$200,000 spending condition for YA 2027 prorated to S$50,411 (Annex 7, paragraph 2 and footnote 107).
• Standard terms. From 1 August 2026, the Annex 13 standard terms apply to all 13O, 13OA and 13U funds; where a letter of award issued before that date differs, the standard terms are additional and, to the extent of any inconsistency, supersede it unless MAS notifies otherwise in writing (paragraph 8.2).

What happens to existing 13U awards approved before 1 August 2026?

Existing SFO awards move to a separate set of conditions from the YA whose basis period ends on or after 1 August 2026, unless MAS notifies otherwise in writing (paragraph 4.6). For a 31 December year end, that is the year ending 31 December 2026.

The Circular groups existing awards into three vintages by the date of the preliminary submission, eligibility form or formal application to MAS:

• Pre-18Apr22 conditions: submitted before 18 April 2022 (footnote 32).
• 18Apr22 conditions: submitted on or after 18 April 2022 but before 5 July 2023 (footnote 33).
• 5Jul23 conditions: submitted on or after 5 July 2023 and approved before 1 August 2026 (footnote 34).

The conditions for each vintage of 13U award are tabulated in Annex 7B, to be read against the letter of award and the Annex 13 standard terms. Two earlier changes already apply to every 13U fund: separate AUM and spending conditions for each SPV or feeder have gone, and so has the rule that a fund may serve only its MAS-approved investment purpose (MAS should still be told of strategy changes). For awards that commenced before 1 January 2025, both apply from YA 2026 (paragraph 5.3 and footnote 37). What a missed annual condition costs, and when it escalates to revocation, is covered on our sister site in a 13O or 13U fund misses an annual condition.

How should a family office prepare a new 13U application?

Treat the application as the first year of compliance.

1. Confirm the SFO meets the licensing exemption, since it must manage or advise the fund directly throughout each basis period.
2. Value the portfolio against the designated investment list, exclude the family’s operating businesses and confirm at least S$50 million remains, with a margin for each year end.
3. Fix the structure, the master fund’s residence and any SPV co-investors.
4. Put 2 qualifying IPs in place for the application and a dated plan for the third, including the non-family IP, before the end of the first basis period.
5. Open the private banking account with an MAS-licensed financial institution in the name of an approved entity before filing.
6. Budget local spending for the likely tier and plan the CDR.
7. Diarise the annual cycle; our 13O annual compliance calendar applies equally to the MAS, IRAS and ACRA dates for a 13U fund.

Queries not answered by the Circular’s FAQs (Annexes 11 and 12) go to FO_13OU@mas.gov.sg, per the MAS fund tax schemes for family offices page.

Frequently asked questions

Can a foreign fund vehicle obtain a 13U award?

Yes. 13U accepts a standalone fund vehicle of any form, and feeder funds and SPVs may be constituted in all forms. Where the structure uses SPVs, the master fund must be a Singapore company, trust or limited partnership that is Singapore tax resident.

Do all three investment professionals need to be in place when we apply?

No. A new 13U SFO fund may apply with 2 qualifying IPs, who may be family members. The third, including at least 1 non-family IP, must be employed by the end of the basis period of the first YA, or the award is revoked from its commencement date.

Does each SPV in a 13U structure need S$50 million?

No. Since 1 January 2025 the structure meets the AUM, spending and capital deployment conditions as a single fund. The S$50 million test is applied to the structure at application, at each year end and when MAS is asked to add a feeder or SPV.

Is the AUM test applied continuously?

No. A new SFO fund reports the S$50 million minimum at application and at each basis period end only. The IP and banking conditions must hold throughout the period.

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.

Last reviewed: 8 November 2026. The Editorial Team, Variable Capital Companies Act.

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