Singapore VCC insights
13O Annual Compliance Calendar: MAS, IRAS and ACRA Deadlines After Year End
Short answer: Key everything to the fund’s year end. Conditions are tested on the last day of the basis period. ECI follows within three months; the SFO annual return and fund declaration to MAS within four; the VCC AGM and annual return at six and seven; Form C by 30 November. CRS and FATCA returns are due each 31 May.
Key facts at a glance
- MAS FDD Circular 05/2026 (31 July 2026): an SFO fund needs at least S$20 million of assets under management in designated investments (AUM in DI) at the end of each basis period under section 13O of the Income Tax Act 1947, and S$50 million under section 13U.
- A single family office (SFO) relying on the licensing exemption files its MAS annual return within four months of its financial year end (FYE). MAS will grant no further extension.
- Estimated Chargeable Income (ECI) is generally due to the Inland Revenue Authority of Singapore (IRAS) within three months of FYE. Form C is due on 30 November.
- A variable capital company (VCC) cannot use Form C-S or Form C-S (Lite); it files Form C.
- Under the Variable Capital Companies Act 2018, a VCC holds its annual general meeting (AGM) within six months of FYE and files its annual return with ACRA within seven months.
- Common Reporting Standard (CRS) and Foreign Account Tax Compliance Act (FATCA) returns are due by 31 May for the previous calendar year.
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.
Many families think of 13O annual compliance as a single MAS declaration each year. In practice it is three workstreams that share one year-end date. The fund vehicle files with IRAS and ACRA. The fund manager, often an exempt SFO, files with MAS. Some reporting runs on the calendar year rather than the fund’s year. Below is a recurring calendar keyed to FYE, showing who owns each item and when it falls due. Every deadline was checked on 24 October 2026 against MAS, IRAS and ACRA sources. For the evidence that supports the declaration, see building the annual evidence file for 13O and 13U. For a fund in its launch year, start with the first-year VCC compliance calendar.
Who owns which part of 13O annual compliance?
The work is split between the fund vehicle, the fund manager and, for a family office, the SFO itself. Each has its own Corppass access and portal, so assign every deadline to one entity.
FDD Circular 05/2026 defines an SFO fund as a fund vehicle whose assets come mainly from members of one family and which is managed by an SFO that is exempt from licensing under paragraph 5(1)(ba) of the Second Schedule to the Securities and Futures (Licensing and Conduct of Business) Regulations. Any other fund is a non-SFO fund, typically managed by a licensed fund management company (FMC). The economic conditions differ between the two.
| Owner | Recurring obligations | Counterparty |
|---|---|---|
| Fund vehicle (company, VCC or sub-fund) | ECI; Form C; quarterly GST remission claims; CRS and FATCA returns if a Reporting Singaporean Financial Institution (SGFI); AGM and annual return | IRAS, ACRA |
| Fund vehicle, through its manager | Annual declaration to MAS that the award conditions were met; notices of post-approval changes | MAS |
| SFO as manager | Annual return under the licensing exemption; employing qualifying investment professionals (IPs) throughout the basis period; its own corporate and tax filings | MAS, IRAS, ACRA |
| Licensed FMC (non-SFO funds) | Employing the required IPs; its licensee returns, which are outside this calendar | MAS |
What does a 13O annual compliance calendar look like month by month?
Almost every recurring deadline is set by reference to FYE. CRS and FATCA are the exception and run on the calendar year. The table assumes a 31 December FYE. For any other year end, shift the FYE-linked rows by the same number of months.
| Date (31 December FYE) | Months after FYE | Obligation | Owner |
|---|---|---|---|
| October to December | Before FYE | MAS publishes the GST fixed recovery rate for the next calendar year | Fund |
| 31 December | 0 | Basis period ends. AUM in DI, local spending, capital deployment and banking conditions are tested; the IP count must have held throughout the period | Fund and SFO |
| 31 January, 30 April, 31 July, 31 October | 1, 4, 7, 10 | Quarterly GST Statements of Claims | Fund |
| 31 March | 3 | ECI to IRAS, unless waived | Fund |
| 30 April | 4 | SFO annual return to MAS; annual declaration to MAS for the fund’s incentive (confirm the date in your letter of award) | SFO; fund through manager |
| 31 May | Calendar year | CRS and FATCA returns or nil returns; latest date for a VCC dispensing with its AGM to send audited financial statements | Fund; VCC |
| 30 June | 6 | VCC AGM, unless exempt or validly dispensed with | VCC |
| 31 July | 7 | VCC annual return to ACRA | VCC |
| 30 November | 11 | Form C for the Year of Assessment (YA) | Fund |
What must be true on the last day of the basis period?
For SFO funds, most economic conditions are tested once, on the last day of the basis period. If one fails, the fund loses its exemption for that basis period only. The circular reserves permanent revocation for non-economic failures, such as not producing documents when asked, and for serious offences.
For new SFO awards approved on or after 1 August 2026, the year-end tests are:
- AUM in DI of at least S$20 million (13O or 13OA) or S$50 million (13U). The SFO fund “will only be required to report that it meets the minimum AUM in DI threshold at the point of application and at the end of each basis period”. Investments in the family’s operating businesses do not count towards the minimum.
- Local spending based on year-end AUM in DI: S$200,000 below S$250 million; S$500,000 from S$250 million up to S$2 billion; S$1,000,000 at S$2 billion or more. Part of this can be met through eligible donations and blended finance grants, but a minimum amount must be local business spending.
- A capital deployment requirement of the lower of 10% of AUM in DI or S$10 million. This is first tested at the end of the basis period for the first full YA after the award starts.
- A private banking account with a MAS-licensed financial institution, held throughout each basis period.
The IP condition must be met throughout the period, not only at year end. A 13O SFO fund needs at least 2 qualifying IPs, at least 1 of whom is not a family member; a 13U SFO fund needs at least 3. A new fund may apply with one fewer. If the full complement is not in place by the end of the first YA’s basis period, the award is revoked back to its start date. For an award that started on 1 August 2026, with a 31 December FYE, that deadline is 31 December 2026.
Non-SFO funds no longer face an annual minimum AUM in DI condition; it was removed retroactively from 1 January 2025. Their FMC must still employ the required IPs and meet tiered local business spending.
What does the SFO file with MAS, and when is the fund’s declaration due?
An exempt SFO files its own annual return within four months of its FYE, separately from the fund’s incentive declaration. MAS’s FAQs on the licensing exemption framework (issued 12 June 2026) state: “There will not be any further extension granted for SFOs to submit the annual returns”. MAS describes it as a straightforward return covering total assets under management and the name of the SFO’s bank.
A new SFO must notify MAS within 14 days of starting operations. An SFO already operating has until 15 June 2027 to meet the conditions and file its notification. For an SFO with a 31 December FYE that notifies during 2026, the first annual return is due by 30 April 2027. FAQ 6 states that the SFO does not need to file an annual return for its previous financial year before it notifies MAS.
MAS has said the fund’s annual declaration is due within four months of FYE. In its 2024 response to feedback on the SFO framework, MAS said it had aligned the SFO return timeline with the existing 13O and 13U reporting requirement. Treat the letter of award and the standard terms as controlling: under FDD Circular 05/2026, Annex 13 applies to all 13O, 13OA and 13U funds from 1 August 2026 and overrides inconsistent terms in older award letters.
Some duties are triggered by events rather than the calendar. In its FAQs on the schemes for SFOs (last updated 14 September 2026), MAS asks SFO funds to notify it when beneficial owners change, when the SFO’s shareholders, directors, C-suite or IPs are added or replaced, and when new intermediate holding entities are introduced. A fund that switches between a non-SFO manager and an SFO manager must also file a declaration up to the last day of its old award. Our article on the exempt SFO’s continuing obligations covers the licensing side.
How do IRAS filings fit around the incentive?
An exemption on specified income does not exempt the fund from filing. It still files ECI, Form C and, if it claims GST remission, quarterly statements.
- ECI: IRAS says companies generally file within three months of FYE. IRAS’s VCC e-Tax Guide (Fourth Edition, 22 April 2026) waives the filing for a VCC whose annual revenue is not more than S$5 million and whose ECI is nil. For an umbrella VCC, revenue is the total of all sub-funds.
- Form C by 30 November: the same guide states that Form C-S and Form C-S (Lite) “do not apply to VCCs”. A VCC files a complete Form C with its financial statements, tax computation and supporting schedules, and an umbrella VCC must show each sub-fund’s chargeable income. A 13O fund set up as an ordinary company should also expect to file Form C, because one of IRAS’s Form C-S conditions is that the company only derives income taxable at 17%. See our Form C pack for an umbrella VCC.
- GST remission: Annex 4 of the circular continues it until 31 December 2029 for funds that met the income tax conditions on the last day of their preceding financial year. Each qualifying VCC, or each sub-fund of an umbrella VCC, files a quarterly Statement of Claims, due one month after the quarter ends. IRAS asks a fund making its first claim for its MAS approval letter and every annual declaration filed since approval.
Where do CRS and FATCA sit in the cycle?
CRS and FATCA returns are due by 31 May for the previous calendar year, whatever the fund’s FYE. IRAS’s CRS e-Tax Guide (Fourth Edition, 31 October 2025) says that reporting “is to be done by 31 May of the year following the calendar year during which the Reportable Accounts were maintained”. IRAS uses the same date for FATCA, and requires a nil return from a Reporting SGFI that held no reportable accounts.
Whether a fund vehicle is an investment entity for CRS purposes depends on how it is managed and on its income. If it is, due diligence on investors and controlling persons continues all year. For the 2027 changes, see CRS 2.0 and CARF from 1 January 2027.
What changed in 2026 that affects the calendar?
Three changes in 2026 need a decision, not just a new calendar entry.
- FDD Circular 05/2026: existing SFO awards approved under the pre-18 April 2022, 18 April 2022 and 5 July 2023 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. For a 31 December fund, the first year tested under the new conditions is the year ending 31 December 2026.
- The SFO licensing framework took effect on 15 June 2026. It adds the four-month MAS annual return, and the transition period for existing SFOs ends on 15 June 2027.
- The second phase of the Corporate and Accounting Laws (Amendment) Act 2025 started on 20 October 2026. ACRA says companies filing annual returns must now confirm that the recorded particulars of directors, CEOs, secretaries, auditors and relevant members are accurate, and answer a new question on whether anyone performs the CEO role. This applies to an SFO, or a 13O fund, incorporated as a company. A VCC should follow ACRA’s VCC pages.
How should a family office build its 13O annual compliance calendar?
Start from the letter of award. Give every entry an owner, a portal and a source document.
- List each entity: every awarded fund or sub-fund, the SFO, and any SPV or feeder within an approved 13U structure. Record its FYE, Unique Entity Number (UEN), Corppass administrator and tax reference.
- Map the conditions for each award, using the letter of award, Annex 13 and the applicable annex (6A, 6B, 7A or 7B). Mark which conditions are tested at year end and which must hold throughout the period.
- Set a pre-year-end review about 60 days before FYE, while there is still time in the basis period to fix shortfalls in AUM, spending or capital deployment.
- Add the filings that run from FYE: three, four, six and seven months, and 30 November.
- Add the fixed calendar dates: 31 May for CRS and FATCA, and the fourth-quarter GST rate update.
- Reconcile the MAS submissions to the IRAS filings before Form C is lodged, so that the AUM, spending and investor figures agree.
Our sister firm Singapore Secretary Services handles the ACRA side of this calendar for companies and VCCs.
Frequently asked questions
Is the SFO’s annual return the same as the fund’s 13O annual declaration?
No. The SFO files its annual return under the licensing exemption, covering its total AUM and its bank. The annual declaration is made for each awarded fund. An SFO managing two awarded funds files one return and two declarations.
Can an SFO get more time for its MAS annual return?
No. MAS’s FAQs say no further extension will be granted beyond four months from FYE.
Does failing the AUM test end a 13O award?
Not on its own. Under FDD Circular 05/2026, the fund loses the exemption only for the basis period in which it fails an economic condition. Missing the first-year IP top-up is different: the award is revoked from its start date.
Can a VCC file Form C-S?
No. IRAS’s VCC e-Tax Guide says Form C-S and Form C-S (Lite) do not apply to VCCs. A VCC files Form C by 30 November.
Why are CRS returns due in May when the fund’s year ends in June?
CRS and FATCA follow the calendar year in which the reportable accounts were held, not the fund’s FYE.
Sources
- MAS FDD Circular 05/2026, Tax Incentive Schemes for Funds (31 July 2026)
- MAS FAQs on Licensing Exemption Framework for Single Family Offices (12 June 2026)
- IRAS e-Tax Guide, Tax Framework for Variable Capital Companies (Fourth Edition, 22 April 2026)
- ACRA, Deadline and requirements: VCC annual returns
- IRAS e-Tax Guide, Common Reporting Standard (Fourth Edition, 31 October 2025)
Raffles Corporate Services helps family offices and fund managers with VCC incorporation, family office set-up and ongoing compliance, including running the MAS, IRAS and ACRA calendar for 13O and 13U funds and their SFOs. Email hello@rafflescorporateservices.com or Call/SMS/WhatsApp +65 8501 7133, or visit Raffles Corporate Services.
Last reviewed: 24 October 2026. The Editorial Team, Variable Capital Companies Act.