Singapore VCC insights

Family Office Singapore Employment Pass: Hiring the Investment Professionals 13O and 13U Require

By VCC Editorial Team · Published 17 October 2026

Short answer: A single family office claiming the 13O or 13U fund tax incentive must employ qualifying investment professionals in Singapore. Foreign hires need an Employment Pass, which requires the age-based qualifying salary (higher for financial services) and 40 COMPASS points unless exempt. For awards approved from 1 August 2026, missing the first-year hiring deadline revokes the award from day one.

The family office Singapore Employment Pass question is no longer a back-office detail. MAS Circular FDD Cir 05/2026 of 31 July 2026 lets a new single family office (SFO) fund apply for the section 13O or 13U scheme before its investment team is complete, but the full team must be in place by the end of the first basis period or the award is revoked from its commencement date. Where those hires are foreign nationals, the Ministry of Manpower (MOM) work pass process often sets the critical path. This article sets out who counts, what MOM requires, and how to sequence the two.

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.

Who counts as an investment professional for a 13O or 13U family office?

An investment professional 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. All four elements must be met; a senior title alone does not qualify.

MAS’s FAQs for SFO funds (Annex 11 of the Circular) describe the expected work: building and managing portfolios, investment research leading to buy or sell recommendations, and trading, which can include liquidity management and deal structuring. Roles primarily in operations, administration or finance do not qualify; MAS’s examples include budgeting, capital account management, cash-flow monitoring, legal documentation, fund wiring, tax planning support and keying in or confirming orders. A chief operating officer or family office controller will not usually count.

An IP should also have relevant experience (investment experience, which can include personal investment, or professional experience in portfolio management, research, trading or mergers and acquisitions) or relevant qualifications (a degree or master’s in accountancy, finance, economics, business or financial engineering, a relevant Singapore diploma, or a certification such as CMFAS or CFA).

Two further points shape hiring. MAS’s general FAQs (Annex 12) require IPs to be employed directly by the fund manager under a formal employment contract exercised in Singapore, and state that the IP must possess a valid Employment Pass where applicable. And at least one IP must not be a family member of the fund’s beneficial owners, so an all-family team will not satisfy the condition.

How many investment professionals does an SFO need, and by when?

For new awards approved on or after 1 August 2026, a 13O or 13OA SFO fund needs 2 IPs and a 13U SFO fund needs 3, each including at least 1 non-family member. Both may apply with one fewer, provided the full team is in place by the end of the basis period for the first year of assessment (YA) of the award.

Condition	13O / 13OA SFO fund	13U SFO fund
IPs at the point of application	At least 1 (family member or otherwise)	At least 2 (family members or otherwise)
IPs by the end of the first YA’s basis period	At least 2, of whom at least 1 is a non-family member	At least 3, of whom at least 1 is a non-family member
Missing the first-year deadline	Award revoked from the commencement date	Award revoked from the commencement date
Subsequent YAs	At least 2 IPs throughout each basis period	At least 3 IPs throughout each basis period
Minimum AUM in designated investments	S$20 million at application and each basis period end	S$50 million at application and each basis period end

Source: MAS FDD Cir 05/2026, paragraphs 4.3 and 4.4.

MAS’s own example shows how short the window can be: if an award commences on 1 August 2026 and the fund’s year ends on 31 December, the final IP must be employed by 31 December 2026, failing which the award is revoked from 1 August 2026. After the first year, a shortfall costs only the exemption for that basis period; a first-year shortfall unwinds the award. Awards made under earlier conditions move to a separate set of conditions (Annexes 6B and 7B) from the YA whose basis period ends on or after 1 August 2026. Our note on family office minimum AUM under MAS, 13O, 13U and the GIP covers the asset thresholds.

Which family office Singapore Employment Pass salary threshold applies?

Plan on the financial services scale. MOM sets a higher Employment Pass (EP) qualifying salary for financial services, and its published list of financial services activities includes fund management activities and trusts, funds and similar financial entities.

The list is stated to be non-exhaustive and does not name single family offices, so classification turns on the SFO’s registered business activity; budgeting to the higher scale avoids a rejection. The qualifying salary is Stage 1 of a two-stage test, and a candidate below it is ineligible whatever their COMPASS score.

Age	Financial services: current	Financial services: new applications from 1 January 2027	Other sectors: current	Other sectors: from 1 January 2027
23 or below	S$6,200	S$6,600	S$5,600	S$6,000
30	S$7,982	S$8,541	S$7,223	S$7,750
35	S$9,255	S$9,927	S$8,382	S$9,000
40	S$10,527	S$11,314	S$9,541	S$10,250
45 or above	S$11,800	S$12,700	S$10,700	S$11,500

Source: MOM, Eligibility for Employment Pass, checked 17 October 2026. The 2027 figures also apply to renewals of passes expiring from 1 January 2028.

The MAS floor of S$3,500 is therefore academic for a foreign hire; the MOM floor binds. Filing dates matter: an offer agreed in November 2026 but filed after 1 January 2027 must meet the 2027 scale, so a 38-year-old analyst offered S$10,500 would qualify today (S$10,018) but not from that date (S$10,759). Our article on the Employment Pass route for SFO principals discusses the principal’s own pass and Dependant’s Passes.

How does COMPASS score a small family office hire?

An SFO with fewer than 25 professional, managerial, executive and technical (PMET) staff scores 10 points by default on each of the two firm-based criteria, so the candidate must earn the remaining 20 points from salary and qualifications.

COMPASS, the Complementarity Assessment Framework, is Stage 2 of the EP test and requires 40 points. Its four foundational criteria each award 0, 10 or 20 points:

• C1, salary: 20 points at or above the 90th percentile of local PMET salaries for the sector; 10 points from the 65th to below the 90th percentile.
• C2, qualifications: 20 points for a degree from an institution on MOM’s top-tier list; 10 points for other degree-equivalent qualifications.
• C3, diversity, and C4, support for local employment: 10 points each by default for employers with fewer than 25 PMETs.

A small SFO therefore reaches 40 with a candidate who holds a top-tier degree, or is paid at the 90th percentile of the sector benchmark, or scores 10 on each. A candidate on a fixed monthly salary of at least S$22,500 is exempt from COMPASS, as is an overseas intra-corporate transferee. MOM’s Self-Assessment Tool should be run before an offer is finalised.

Does the family office have to advertise the role first?

Often not at the start. MOM’s Fair Consideration Framework requires an EP job to be advertised on MyCareersFuture for at least 14 consecutive days, but not where the company has fewer than 10 employees or the fixed monthly salary is S$22,500 or more.

Once headcount reaches 10, every EP role below S$22,500 must be advertised, and no job offer should be made during the 14 days. The advertised occupation, employer and salary range must match the application, the top of the range cannot exceed twice the bottom, and changing those details restarts the 14 days.

How does pass timing interact with the incentive deadline?

Work backwards from the last day of the first basis period. The IP must be employed by the SFO, holding a valid EP, by that date, and MOM’s processing time is added to the search, not absorbed by it.

1. Fix the deadline: the end of the basis period for the first YA, from the award commencement date and the fund’s financial year end.
2. Confirm the role qualifies: write the job scope around portfolio management, research or trading.
3. Pre-assess the candidate on the financial services scale, checking whether filing after 1 January 2027 changes the threshold.
4. Advertise for at least 14 consecutive days if the SFO has 10 or more employees and the salary is below S$22,500.
5. File the EP: online applications are processed or updated within 10 business days, longer if documents are requested; an overseas company applying through a local sponsor should allow up to 6 weeks for most cases.
6. Bring the candidate in: the in-principle approval gives 6 months to enter and have the pass issued, issuance is immediate once the candidate is in Singapore, and the notification letter permits work to start.
7. Document the hire: keep the employment contract, job description and evidence of experience or qualifications, and notify MAS of the new IP as Annex 11 requires.

On MAS’s example, an award commencing 1 August 2026 with a 31 December year end leaves under 11 weeks from 17 October 2026. A search that ends in December, followed by an advertisement and a 10-business-day assessment, would miss the deadline. A prudent SFO treats the work pass as part of the hiring plan from the first conversation and keeps a back-up candidate who is a Singapore citizen or permanent resident. Our sister agency, Little Big Employment Agency (MOM EA Licence 19C9790), handles Employment Pass applications for employers.

What keeps an IP counting after the first year?

From the second YA, the headcount must be maintained throughout each basis period, so tax residency, a valid pass and direct employment must all hold for the whole year.

Tax residency is rarely the obstacle. Under IRAS’s published rules, a foreigner is resident after at least 183 days in Singapore in the previous calendar year, and a foreigner issued with a work pass valid for at least 1 year is also treated as resident, subject to review at tax clearance. As a first EP runs for up to 2 years, a newly arrived IP will normally be treated as resident from the start.

The weaker points are renewals and departures. Renewals of passes expiring from 1 January 2028 must meet the 2027 scale, so salary reviews should track pass expiry dates, and the non-family IP in particular needs a succession plan. Our guide to the annual evidence file for 13O and 13U sets out the records worth keeping, and SFOs reviewing their wider position should read restructuring options before 15 June 2027.

Frequently asked questions

Can a family member be one of the SFO’s investment professionals?

Yes. For new awards, the first IP of a 13O or 13OA fund, and the first two of a 13U fund, may be family members. By the end of the first basis period, at least one IP must not be a family member of the fund’s beneficial owners.

Does a chief operating officer or CFO count as an investment professional?

Generally not. MAS states that roles primarily in operations, administration, finance or accounting do not qualify.

Can the SFO use an investment professional employed by a related company?

Only as a secondee meeting MAS’s conditions: full-time work for the manager, no double-counting for another incentive, payroll costs charged to the manager, control by the manager and a bona fide commercial reason. Otherwise the IP must be employed directly.

Is an investment professional earning S$25,000 a month exempt from COMPASS?

Yes. A fixed monthly salary of at least S$22,500 exempts the candidate from COMPASS and the role from MyCareersFuture advertising. The candidate must still meet the EP qualifying salary, which that salary exceeds.

What happens if the final IP is hired a week late?

For awards approved on or after 1 August 2026, the Circular states that the award will be revoked with effect from its commencement date if the required IPs are not employed by the end of the first basis period. Build the timetable with margin.

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: 17 October 2026. The Editorial Team, variablecapitalcompaniesact.com.