Singapore VCC insights

Trust Business Licence Singapore: MAS Capital, Resident Managers and the Licensed-or-PTC Decision

By VCC Editorial Team · Published 19 October 2026

Short answer: A company that carries on trust business in or from Singapore needs a trust business licence from the Monetary Authority of Singapore (MAS) under the Trust Companies Act 2005, unless an exemption applies. MAS expects S$250,000 of paid-up capital or qualifying assets, two approved resident managers, adequate professional indemnity insurance and up to six months of review.

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

A trust business licence in Singapore is the authorisation a company needs before it can act as a professional trustee, create trusts for clients or administer them. This guide is for family offices, multi-family offices and wealth managers deciding whether to build a licensed trust company, use a private trust company or appoint an existing trustee, and sets out what the Monetary Authority of Singapore (MAS) requires. All sources were checked on 19 October 2026 and in-force statements are as at that date.

What counts as trust business, and who needs a trust business licence in Singapore?

Anyone who provides trust services to an express trust, as a business, in or from Singapore needs a licence unless they fall within an exemption. The Trust Companies Act 2005 (TCA) is administered by MAS and has applied since 1 February 2006.

The First Schedule to the TCA defines trust business as four activities: providing services for the creation of an express trust; acting as trustee of an express trust; arranging for any person to act as trustee of an express trust; and providing trust administration services to an express trust. MAS’s FAQs note that executors, administrators, bare trustees and business trust trustees sit outside the TCA.

Section 3(1) provides that a person “must not carry on any trust business or hold himself, herself or itself out as carrying on any trust business in or from within Singapore unless that person is a licensed trust company”. MAS’s FAQs treat activity conducted “with system, repetition and continuity” as carrying on a business. Contravention is an offence carrying a fine of up to S$75,000, imprisonment of up to 3 years or both, plus up to S$7,500 a day for a continuing offence (section 3(4)).

Which exemptions mean a family or adviser may not need a licence?

Several categories are exempt under section 15 of the TCA and regulation 4 of the Trust Companies (Exemption) Regulations, but each exemption is narrow and tied to particular activities. The table summarises those most relevant to families and their advisers.

Person	Scope of exemption	Source
Bank or merchant bank licensed under the Banking Act 1970	Trust creation, arranging a trustee, and procedural and non-discretionary administration only; notify MAS (Form 8) within one month of starting	TCA s 15(1)(a), (b), (2), (3)
Capital markets services (CMS) licensee, or person exempt from a CMS licence, for fund management or custody	Only “in respect of the provision of fund management or custodial services”; does not extend to acting as trustee	TCA s 15(1)(c)
Private trust company	Trust business for trusts whose settlors are connected persons and whose beneficiaries are connected to the settlor or a charity; no soliciting the public; must engage a licensed trust company for AML/CFT checks	Exemption Regulations reg 4(1)(a), (2)
Practising solicitors and Singapore law practices	Creation, arranging and certain administration; fuller trust business only within limits including financial assets settled per client not exceeding S$2 million and no more than 30 clients per solicitor, with Form 8 notice	Exemption Regulations reg 4(1)(b)
Any person acting under an arrangement with a licensed trust company	Trust creation and arranging a trustee only	Exemption Regulations reg 4(1)(e)

Two points matter for family offices. The section 15(1)(c) exemption covers fund management and custody, not trusteeship, so a single family office’s exemption from a CMS licence does not let it act as trustee. And a multi-family office can help clients create trusts under an arrangement with a licensed trust company (regulation 4(1)(e)), but acting as trustee for unconnected families needs a licence. Our guide to multi-family office requirements in Singapore covers the parallel fund management question.

What does MAS require to grant a trust business licence in Singapore?

MAS grants a licence only to a Singapore company or a registered foreign company that meets prescribed financial and other requirements and passes a fit and proper assessment of the company, its officers and its substantial shareholders. Section 5(1) restricts licences to a company incorporated under the Companies Act 1967 or a foreign company registered under Division 2 of Part 11 of that Act, and the Guidelines on Criteria for the Grant of a Trust Business Licence (TCA-G02) add that the applicant “is required to establish a physical presence in Singapore”.

MAS’s licence page lists the factors it weighs: fitness and propriety of the applicant, its shareholders, resident managers and directors; track record and management expertise of the applicant and its parent or major shareholders; ability to meet the minimum financial and professional indemnity insurance (PII) requirements; strength of internal compliance systems; and the business model, projections and associated risks. Section 5(3) also lets MAS refuse where it is not satisfied about the “record of past performance or expertise of the applicant”.

Requirement	What MAS expects	Source
Capital at grant	Paid-up capital (Singapore company) or qualifying assets (foreign company) of S$250,000	Trust Companies Regulations reg 11; TCA-G02 para 7
Ongoing financial resources	Singapore company: net asset value of at least the higher of one-quarter of the prior year’s relevant annual expenditure or three-quarters of S$250,000. Foreign company: qualifying assets in the Singapore branch of at least the higher of one-quarter of relevant annual expenditure or S$250,000	Trust Companies Regulations reg 12; MAS FAQs
Professional indemnity insurance	Standalone non-hybrid PII covering negligent discharge of duties; MAS is likely to consider it adequate at the higher of S$1 million or 2.5 times turnover, capped at S$10 million, with a deductible of not more than 50% of net asset value	Trust Companies Regulations reg 14; TCA-G02 paras 13 to 16
Resident managers	At least two, with acceptable tertiary or professional qualifications; one with at least 5 years and the others with at least 3 years of relevant experience	Trust Companies Regulations reg 8; TCA-G02 paras 9 to 11
Parent support	Letter of Responsibility from the parent company in MAS’s format, unless there is no corporate parent	TCA-G02 para 17
Systems and conduct	Adequate internal compliance systems as set out in the Guidelines on Standards of Conduct for Licensed Trust Companies (TCA-G03)	TCA-G02 para 8

TCA-G02 also permits group and hybrid PII on conditions, and treats its figures as minimums. The fit and proper standard is set by MAS’s Guidelines on Fit and Proper Criteria (FSG-G01), last revised 30 May 2025 with effect from 30 June 2025, which expect relevant persons to be “competent, honest, to have integrity and to be of sound financial standing”.

How does the trust business licence application process work?

The applicant files Form 1 under the Trust Companies Regulations with supporting documents, pays a non-refundable S$1,000 application fee and then works through MAS’s queries. The sequence below reflects the steps MAS publishes.

1. Incorporate the applicant (or register the foreign company) and secure Singapore premises, the S$250,000 capital and a PII quotation that meets TCA-G02.
2. Recruit at least two resident managers who meet the qualification and experience thresholds, and assemble the board, compliance and AML/CFT arrangements.
3. Prepare the business plan, projections, TCA-G03 policies and any parent Letter of Responsibility, then submit Form 1 (last revised 24 January 2025).
4. Answer MAS’s queries. MAS “expects to take not more than 6 months” if the business model is straightforward and the application complete and clear, and longer for complex or incomplete cases.
5. On grant, comply with any licence conditions imposed under section 7, lodge the Form 5 statement of net asset value or qualifying assets within 14 days, and begin trust business. MAS’s FAQs state that the licence lapses if trust business has not commenced within 6 months of grant.

Once licensed, the company is listed on MAS’s Financial Institutions Directory and pays the S$4,000 annual licence fee. Regulation 4(4) of the Trust Companies Regulations allows MAS to impose a late payment fee of up to S$100 a day, capped at S$3,000. Incorporation, registered office and company secretarial work for the applicant can be handled through Singapore Secretary Services.

Which people and owners must MAS approve?

MAS must approve resident managers, key directors and anyone becoming a 20%, 50% or indirect controller of a Singapore-incorporated licensed trust company.

Under section 13(1), a licensed trust company must obtain MAS’s approval before appointing a resident manager, or a director who resides in Singapore or is directly responsible for its Singapore business. MAS’s Form 4 (last revised 7 April 2026) is used for these appointments. Section 14, as amended by the Financial Institutions (Miscellaneous Amendments) Act 2024 with effect from 24 January 2025, requires MAS’s consent before a disqualified person (for example, an undischarged bankrupt) acts as an officer, resident manager or director, and lets MAS direct removal of anyone it considers not fit and proper.

Section 16 requires MAS’s prior approval before a person becomes a “20% controller”, “50% controller” or “indirect controller” of a licensed trust company incorporated in Singapore. Shareholdings are aggregated with associates, which include close family members, so a family that collectively holds 20% or more is caught. Applications are made on Form 3 and MAS must be satisfied that the applicant is fit and proper (section 17).

What ongoing obligations follow a trust business licence?

A licensed trust company carries continuing prudential, conduct, reporting and anti-money laundering duties, and MAS inspects on-site as well as off-site.

• AML/CFT: MAS Notice TCA-N03 covers risk assessment, customer due diligence, record keeping, suspicious transaction reporting and internal controls.
• Annual filings described in MAS’s FAQs: audited accounts with an auditor’s report in Form 7 and the Form 5 financial resources statement within 5 months of financial year end, and a Form 6 statement on headcount, revenue sources and assets under trusteeship within 60 days of each calendar year end.
• Change notifications: under section 9, particulars of specified events, including a resident manager or controller ceasing to act, proceedings against the company or an officer, or a failure to meet minimum financial requirements, must be given to MAS within 14 days.
• Outsourcing: MAS’s Guidelines on Outsourcing (Financial Institutions other than Banks), effective 11 December 2024, apply. MAS’s FAQs also point licensed trust companies to the confidentiality provisions in section 49 of the TCA.
• Exit: section 11 prohibits a licensed trust company from ceasing trust business without the sanction of the court while any trust of which it is trustee remains wholly or partly unadministered.

A licensed trust company also falls within the Trustees Act 1967 definition of “trust corporation”, which covers the Public Trustee, a court-appointed corporation and a corporation “licensed as a trust company under the Trust Companies Act 2005”. A private trust company is not within that definition. On tax, see our note on taxation of trusts in Singapore.

When does a licensed trust company make more sense than a private trust company?

For a single family, a private trust company is usually lighter, because it needs no licence, capital floor or resident managers. A licensed trust company becomes the better choice only where the business will serve more than one unconnected family or must market its services. The private trust company route is analysed in our guide to the private trust company in Singapore.

The private trust company exemption has firm limits. Under regulation 2 of the Exemption Regulations, its purpose must be “solely to provide trust business services in respect of a specific trust or of specific trusts” whose settlors are connected persons and whose beneficiaries are connected to the settlor or a charity, and it must not solicit trust business from or provide services to the public. Taking on trusts for unconnected families, or offering trusteeship as a product, brings section 3 back into play.

Four questions usually decide it: will the trustee serve only connected persons as the family branches out; can the group carry two qualified resident managers, compliance, audit and PII indefinitely; does the family need the standing of a supervised “trust corporation”; and would an existing licensed trustee with a protector or reserved investment powers achieve the same at lower cost? Our licensed trustee scorecard covers how to choose an existing provider, and changing a Singapore trustee without losing control covers migration from one trustee to another.

Frequently asked questions

Is there a minimum capital for a trust business licence in Singapore?

Yes. Regulation 11 of the Trust Companies Regulations requires S$250,000 of paid-up capital, or qualifying assets for a foreign company, and regulation 12 sets an ongoing net asset value floor.

How long does MAS take to approve a trust business licence?

MAS expects not more than 6 months for a straightforward, complete application; complex or incomplete cases take longer.

Can a single family office act as trustee of the family’s trusts without a licence?

Not through its fund management exemption, which covers only fund management and custodial services. A family can use a separate private trust company, which is exempt under regulation 4(1)(a) of the Trust Companies (Exemption) Regulations if it serves only connected settlors and beneficiaries and engages a licensed trust company for AML/CFT checks.

Do the resident managers need to be Singapore citizens?

The TCA, the Trust Companies Regulations and TCA-G02 as reviewed do not impose a citizenship requirement. They require at least two resident managers with acceptable qualifications and 5 or 3 years of relevant experience, approved by MAS.

Sources

• MAS: Trust business licence
• Trust Companies Act 2005 (Singapore Statutes Online)
• MAS Guidelines on Criteria for the Grant of a Trust Business Licence (TCA-G02)
• Trust Companies (Exemption) Regulations (Singapore Statutes Online)
• MAS Notice TCA-N03 on AML/CFT for trust companies

Raffles Corporate Services helps families, multi-family offices and wealth managers set up and run the Singapore companies behind trust, family office and VCC structures, including incorporation, company secretarial support and ongoing compliance. Email hello@rafflescorporateservices.com or Call/SMS/WhatsApp +65 8501 7133, or visit Raffles Corporate Services.

Last reviewed: 19 October 2026. The Editorial Team, Variable Capital Companies Act.