Singapore VCC insights

Family Office Singapore Minimum AUM: What MAS, the 13O and 13U Schemes and the GIP Each Require

By VCC Editorial Team · Published 11 October 2026

Short answer: There is no minimum AUM in the published conditions of MAS’s single family office licensing exemption. Thresholds come from the optional regimes: S$20 million in designated investments for a section 13O fund, S$50 million for section 13U, and S$200 million in assets under management for Global Investor Programme Option C.

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.

The family office Singapore minimum AUM question is one of the most searched questions about the jurisdiction, and one of the most confused. Figures of S$10 million, S$20 million, S$50 million and S$200 million circulate, often without saying which regime they belong to. The confusion arises because three separate regimes apply to a single family office: MAS licensing, the fund tax incentives administered by MAS, and the Economic Development Board’s Global Investor Programme. Each has its own financial test, and only one of them is compulsory. This guide separates them, using MAS and EDB sources checked on 11 October 2026.

Is there a minimum AUM to set up a single family office in Singapore?

No minimum appears in the conditions MAS has published for the licensing exemption. A family can establish a single family office (SFO) of any size, provided it meets the qualitative conditions.

The Monetary Authority of Singapore’s revised framework took effect on 15 June 2026. A qualifying SFO is exempt from holding a capital markets services licence for fund management as a class: it does not apply for an individual exemption. The conditions published in MAS’s media release and FAQs concern who the SFO serves and how it operates, not how much it manages. The SFO must be incorporated in Singapore; serve only family members (including family trusts, wholly owned family companies and charities funded solely by the family) and key employees; keep key employees’ assets within 10% of total AUM; notify MAS within 14 days of starting operations; keep an account with a MAS-licensed bank for the SFO and each fund vehicle; and file an annual return within four months of financial year end reporting total AUM and the bank used.

The absence of a threshold is a reading of the published conditions, not an MAS statement that size is irrelevant. In practice, banks set their own minimums for private banking relationships, and the cost of running a compliant office makes very small SFOs uneconomic. Existing SFOs have until 15 June 2027 to meet the conditions and notify MAS.

What are the minimum fund sizes for the 13O and 13U tax incentives?

Under MAS FDD Circular 05/2026 (31 July 2026), a section 13O fund needs at least S$20 million, and a section 13U fund at least S$50 million, in designated investments. The test applies at application and at the end of each basis period.

The incentives exempt specified income from designated investments under sections 13O and 13U of the Income Tax Act 1947. The 2026 Circular applies to SFO awards approved on or after 1 August 2026; funds with earlier awards remain bound by the conditions in their award letters. Investments in the family’s own operating businesses do not count towards the fund size.

Fund size is only one of several conditions. The fund must employ investment professionals (two for 13O, three for 13U, at least one of whom is not a family member) who are Singapore tax resident and earn more than S$3,500 a month. A new fund may apply with one (13O) or two (13U) professionals, who may be family members, but must reach the full complement by the end of the basis period for its first year of assessment, or the award is revoked from its start. The fund must also hold a private banking account with a MAS-licensed financial institution and meet the local investment requirement of the lower of 10% of assets or S$10 million.

Regime	Financial threshold	Measured how	Source
MAS SFO licensing exemption	None in published conditions	Total AUM reported annually	MAS media release and FAQs, June 2026
Section 13O fund	S$20 million	Designated investments, at application and each basis period end	MAS FDD Circular 05/2026
Section 13U fund	S$50 million	Designated investments, at application and each basis period end	MAS FDD Circular 05/2026
GIP Option C (office)	S$200 million AUM	S$50 million deployed in specified investments within 12 months	EDB Global Investor Programme
GIP family office principal	S$200 million net investible assets	Plus a five-year track record	EDB Global Investor Programme

How does AUM affect the minimum spending requirement?

From 1 August 2026, the business spending condition is tiered by the fund’s assets in designated investments, so a larger fund must spend more in Singapore each year.

Assets in designated investments	Total minimum spending	Of which local business spending
Below S$250 million	S$200,000	S$200,000
S$250 million to below S$2 billion	S$500,000	At least S$300,000
S$2 billion and above	S$1 million	At least S$500,000

Above the local business spending floor, the balance may be met through qualifying donations and blended-finance grants, which the Circular counts at twice their value. Older bands keyed to S$50 million and S$100 million no longer apply to SFO awards under the new Circular. Our guide on building a quote-backed family office budget shows how to evidence spending.

What AUM does the Global Investor Programme require for a family office?

GIP Option C is the only family office route with a nine-figure threshold: the single family office must have at least S$200 million in assets under management.

According to the Economic Development Board (EDB), Option C requires S$50 million of that AUM to be transferred to Singapore and deployed in EDB-specified investment categories within 12 months of final approval, and kept there. The principal must have at least five years of track record and net investible assets of at least S$200 million. The application fee is S$20,000, plus an ICA processing fee of S$100 per applicant. Options A (at least S$10 million in a business) and B (S$25 million in a GIP-select fund) are not family office routes.

The re-entry permit lasts five years. For a five-year renewal under Option C, the family office must employ five additional professionals, at least three of them Singapore citizens, keep the S$50 million deployed, and the applicant or dependants must reside in Singapore for more than half the time. Meeting either limb secures a three-year renewal. Our comparison of GIP Option C and the fund tax incentives covers families who qualify for both, and Singapore Employment Agency covers pass-based alternatives for principals below the GIP threshold.

How should a family below S$20 million structure its Singapore office?

A family below the 13O threshold can still run a compliant SFO under the class exemption; it simply operates without the fund tax incentive and must manage its tax position under the general rules.

Singapore’s corporate tax rate is 17%, and IRAS states that gains on the disposal of assets that are capital in nature are not taxed. Investment returns that are revenue in nature, such as interest and some trading gains, are taxable without an incentive. Section 10L of the Income Tax Act 1947 also taxes gains on the disposal of foreign assets received in Singapore by an entity in a relevant group that lacks adequate economic substance in Singapore, for disposals on or after 1 January 2024. For a smaller family the practical steps are:

1. Confirm the SFO meets each class exemption condition and notify MAS within 14 days of starting operations.
2. Open accounts with a MAS-licensed bank for the SFO and each investment vehicle.
3. Review the tax character of the expected returns and the section 10L position of any holding company.
4. Plan for growth: if designated investments are expected to reach S$20 million, prepare the investment professional, spending and local investment evidence before applying.
5. Keep fund and office records separate from the outset, as our note on separating family office and VCC fund records explains.

Does the AUM requirement have to be met continuously?

For the tax incentives, yes at defined points. The S$20 million or S$50 million must be met at application and at the end of each basis period. For the licensing exemption, there is no AUM test to fail, but total AUM is reported to MAS every year.

MAS has also removed the annual minimum AUM condition for non-SFO funds under the incentives, which matters for fund managers but not for family offices. A fall below the SFO threshold at a basis period end puts the incentive at risk for that period, so families with volatile portfolios should run headroom above the minimum. Our guide to the annual evidence file for 13O and 13U lists what to keep.

Frequently asked questions

What is the minimum investment to set up a family office in Singapore?

The MAS licensing exemption carries no published minimum. If the family wants the 13O tax incentive, the fund needs S$20 million in designated investments; for 13U, S$50 million.

What is the minimum net worth for a Singapore family office?

No net worth test applies to the licensing exemption. GIP Option C requires the principal to have net investible assets of at least S$200 million and a five-year track record.

Is the old S$10 million figure still relevant?

Not for an SFO award approved on or after 1 August 2026. Under MAS FDD Circular 05/2026, the 13O minimum is S$20 million in designated investments. Funds with earlier awards should check their own award conditions.

Does money invested in the family business count towards the S$20 million?

No. MAS’s Circular excludes investments in the family’s operating businesses from the fund size calculation.

Do existing family offices face a new AUM test by 15 June 2027?

No. The 15 June 2027 deadline is for existing SFOs to meet the licensing exemption conditions and notify MAS, and those conditions contain no AUM minimum. Incentive conditions for existing funds continue to follow their award letters.

Sources

• MAS: fund tax incentive schemes for family offices
• MAS: revised framework for single family offices
• EDB: Global Investor Programme

Raffles Corporate Services helps family offices and fund managers with VCC incorporation, single family office set-up and MAS notification, and ongoing compliance for 13O and 13U funds. Email hello@rafflescorporateservices.com or Call/SMS/WhatsApp +65 8501 7133, or visit Raffles Corporate Services.

Last reviewed: 11 October 2026. The Editorial Team, Variable Capital Companies Act.