VCC Act 2018 — Section 86 fund administrator requirements — 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 (the Variable Capital Companies Act 2018) and its regulations require a VCC to keep proper records and, in practice, to appoint a fund administrator to maintain its register of members and support anti-money-laundering obligations. While the Act allows certain functions to be delegated, the VCC must ensure its register and books are kept in Singapore or made available here, and that a regulated intermediary discharges customer due-diligence duties.
VCC Act 2018: the fund administrator requirement
The Variable Capital Companies Act 2018 obliges a VCC to maintain a register of members and proper accounting records. Because a VCC is a fund vehicle, these functions are typically delegated to a fund administrator, and the VCC must appoint an eligible financial institution to conduct anti-money-laundering and countering-the-financing-of-terrorism checks in line with MAS requirements. The register of members is not filed publicly with ACRA but must be kept and made available as the Act requires. See the official guidance at sso.agc.gov.sg/Act/VCCA2018.
Who this affects
Fund managers and VCC boards deciding how to resource administration, and family offices weighing in-house versus outsourced operations. It also affects fund administrators and MAS-regulated financial institutions that take on the AML/CFT responsible-party role.
Requirements and eligibility
The VCC must keep its register of members, either in Singapore or accessible from Singapore, and maintain accounting records for the statutory retention period. The AML/CFT duties must be performed by an eligible financial institution regulated by MAS, which the VCC formally appoints. Directors remain responsible for ensuring these obligations are met even when functions are outsourced.
Costs, fees and timeline
Fund administration fees are commercial and scale with fund size and complexity, commonly starting around S$12,000 to S$30,000 per year for a straightforward single fund, higher for umbrella VCCs with multiple sub-funds. Appointing the AML/CFT responsible party is usually bundled with administration or the fund manager’s mandate. This is separate from the S$8,000 ACRA VCC incorporation fee. Onboarding an administrator, including due diligence, typically takes 2 to 6 weeks.
Step-by-step process
Select a fund administrator with VCC experience. Appoint an eligible MAS-regulated financial institution as the AML/CFT responsible party. Document the delegation while retaining board oversight. Ensure the register of members and accounting records are maintained and accessible in Singapore. Review the arrangements annually against MAS expectations.
Common mistakes and gotchas
Boards sometimes assume outsourcing transfers legal responsibility; directors remain accountable. Others overlook that the AML/CFT duties must sit with an eligible regulated institution. Keeping the register of members inaccessible from Singapore, or failing to update it promptly, breaches the Act.
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 a VCC appoint a fund administrator?
The Act requires proper records and a register of members; in practice a fund administrator is appointed, and an eligible MAS-regulated institution must handle AML/CFT duties.
Is a VCC's register of members public?
No. Unlike an ordinary company, a VCC’s register of members is not filed publicly with ACRA, but it must be kept and made available as the Act requires.
What does VCC fund administration cost?
Fees commonly start around S$12,000 to S$30,000 per year for a single fund, higher for umbrella VCCs with multiple sub-funds.
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.