VCC Act 2018 — Section 46 Permissible Fund Manager rules — Costs and fees breakdown
Raffles Corporate Services works with a panel of corporate and employment law firms; this article is general information, not legal advice.
The VCC Act 2018 (formally the Variable Capital Companies Act 2018) governs the VCC, Singapore’s dedicated corporate structure for investment funds. A central requirement under the VCC Act 2018 is that a VCC must be managed by a Permissible Fund Manager, a regulated entity authorised to conduct fund management in Singapore. This requirement anchors the VCC within Singapore’s regulated fund-management perimeter and is a gating condition for incorporation and ongoing operation.
VCC Act 2018: the Permissible Fund Manager requirement
The Variable Capital Companies Act 2018 establishes that a VCC must at all times have its assets managed by a Permissible Fund Manager. In practice this means a holder of a Capital Markets Services licence for fund management, a licensed or registered fund management company regulated by the Monetary Authority of Singapore, or another category the Act and its regulations recognise. The requirement ensures the fund vehicle sits within MAS’s regulated ecosystem rather than operating as an unregulated pooling vehicle. See the official guidance at sso.agc.gov.sg/Act/VCCA2018.
Who this affects
Fund managers launching Singapore-domiciled funds, family offices structuring investment vehicles, and service providers advising on VCC set-up. Anyone considering a VCC must first confirm that a Permissible Fund Manager will be appointed, because the structure cannot function without one.
Requirements and eligibility
The manager must fall within the classes the Act permits, most commonly a licensed fund management company or a registered fund management company under the Securities and Futures Act 2001. The VCC’s constitution and its arrangements with the manager must reflect this. Directors of the VCC retain their statutory duties, but investment management is delegated to the permissible manager.
Costs, fees and timeline
VCC incorporation with ACRA carries a name-application fee of S$15 and an incorporation fee of S$8,000, materially higher than an ordinary company. Professional set-up fees commonly range from S$8,000 to S$20,000 for a single VCC, more for an umbrella structure. Appointing an external fund manager involves the manager’s own fees; where a manager must first obtain MAS licensing, allow several months. From a ready fund manager and documents in place, VCC incorporation itself typically takes 2 to 4 weeks.
Step-by-step process
Confirm or appoint a Permissible Fund Manager holding the appropriate MAS status. Prepare the VCC constitution and fund documents. Appoint at least one Singapore-resident director and a qualified corporate secretary. Lodge incorporation with ACRA and pay the S$8,000 fee. Put the management agreement in place, then commence fund operations under the manager’s oversight.
Common mistakes and gotchas
Promoters sometimes assume they can self-manage a VCC without an MAS-regulated manager; this is not permitted. Others underestimate the higher ACRA fee and the lead time to obtain fund-management licensing. The management agreement must align with MAS expectations, or the arrangement may be questioned.
Related guides across the Raffles group
- Running an E-Commerce Business in Singapore (2026): Tax and Compliance Guide on Raffles Corporate Services.
- Section 13O vs 13U: Comparing Singapore’s Two Family Office Tax Incentive Schemes (2026) on Singapore Secretary Services.
- VCC Act 2018 — Section 32-33 distribution out of capital — Costs and fees breakdown.
Official references
FAQs
Must every VCC have a fund manager?
Yes. Under the Variable Capital Companies Act 2018, a VCC must have its assets managed by a Permissible Fund Manager regulated by MAS.
Can I manage my own VCC?
Only if you hold or obtain the appropriate MAS fund-management status. A VCC cannot be self-managed by an unregulated party.
What does VCC incorporation cost?
ACRA charges a S$15 name application and S$8,000 incorporation fee, with professional set-up fees typically S$8,000 to S$20,000 for a single VCC.
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.