Singapore VCC insights

Wealth Management Licence Singapore: CMS Licence, Financial Adviser Licence or Exemption?

By VCC Editorial Team · Published 16 October 2026

Short answer: Singapore has no single wealth management licence. Discretionary management and dealing need a capital markets services licence under the Securities and Futures Act 2001; investment advice needs a financial adviser’s licence unless exempt, as capital markets services licensees are; trustee services need a trust business licence. Single family offices use a class exemption.

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.

Founders asking which wealth management licence Singapore requires are usually asking the wrong question. The Monetary Authority of Singapore (MAS) licenses activities, not business labels, so a multi-family office (MFO), an external asset manager (EAM) or a private wealth boutique must break its service menu into regulated activities and map each to the Securities and Futures Act 2001 (SFA), the Financial Advisers Act 2001 (FAA) or the Trust Companies Act 2005 (TCA). Statutes on Singapore Statutes Online and MAS licensing pages were checked on 16 October 2026. Staffing and capital for the fund management licence itself are covered in our guide to building the fund management licence application; this article is the wider map.

Is there a single wealth management licence in Singapore?

No. A wealth firm holds whichever combination of licences, exemptions and notifications its actual activities require.

Three statutes do most of the work. The SFA regulates seven activities listed in Part 1 of its Second Schedule: dealing in capital markets products, advising on corporate finance, fund management, real estate investment trust management, product financing, providing credit rating services and providing custodial services. Section 82(1) prohibits any person from carrying on business in, or holding itself out as carrying on, any of these without a CMS licence for that activity, subject to the Third Schedule and the exemptions in section 99.

The FAA regulates financial advisory services, which MAS summarises as advising on investment products (other than corporate finance), issuing research on them, and arranging life policies. Section 6(1) prohibits acting as a financial adviser in Singapore unless licensed or exempt. Section 3(1) of the TCA prohibits carrying on trust business in or from Singapore without a trust business licence. Both carry fines of up to S$75,000, imprisonment of up to 3 years, or both.

Which wealth management licence Singapore firms need for each activity

Most wealth firms anchor on a CMS licence and add exemptions or activities around it.

Activity	Licence or exemption	Statute	Key condition
Discretionary portfolio management for clients, or operating a fund	CMS licence for fund management (A/I or Retail LFMC)	SFA s 82; Second Schedule	Base capital S$250,000 (A/I LFMC) or S$500,000 to S$1,000,000 (Retail LFMC); financial resources at least 120% of total risk requirement
Executing or arranging trades in securities, fund units or derivatives for clients, outside fund mandates	CMS licence for dealing in capital markets products	SFA s 82; Second Schedule	Base capital from S$50,000 to S$5 million depending on products, clients and whether client assets are held; not needed where dealing is incidental to fund management
Holding clients’ securities and settling, collecting income or exercising rights	CMS licence for providing custodial services	SFA s 82; Second Schedule	Annual licence fee S$2,000; services to related corporations excluded in defined cases
Advising clients on investment products, or issuing research	Financial adviser’s licence, or exempt financial adviser status if already a CMS licensee	FAA ss 6 and 20(1)(d)	Licensee: base capital S$500,000 (or S$300,000 plus S$500,000 extra PII); exempt CMS holder: Form 26 and FAA conduct rules
Advice to not more than 30 accredited investors only	Exempt financial adviser	FAA s 20; Financial Advisers Regulations Part VI	Form 20 within 14 days after commencement
Acting as trustee or providing trust services by way of business	Trust business licence	TCA s 3	S$250,000 paid-up capital or qualifying assets; 2 resident managers
Managing assets for one family only	Single family office class exemption	SFA s 99 and MAS framework from 15 June 2026	Notify MAS within 14 days of commencing; MAS-licensed bank account; annual return

Figures come from MAS licensing pages and Guidelines SFA 04-G05 (last revised 3 September 2025). Where a firm holds several SFA activities, the highest base capital requirement applies.

When does a CMS licence for fund management or dealing apply?

A CMS licence for fund management applies whenever the firm manages a portfolio of capital markets products on behalf of a customer, on a discretionary authority or otherwise, or manages or operates a collective investment scheme. Dealing becomes a separate activity once the firm executes or arranges trades outside those mandates.

The Second Schedule definition covers managing a portfolio of capital markets products for a customer, whether or not on a discretionary authority. An EAM that holds a limited power of attorney over a client’s private bank account and makes the investment decisions will generally sit inside it. Since the registered fund management company regime was repealed on 1 August 2024, the routes are the Accredited/Institutional (A/I) licensed fund management company (LFMC), serving accredited and institutional investors only, and the Retail LFMC, serving all investors.

Dealing covers making, offering or inducing agreements to acquire, dispose of, subscribe for or underwrite capital markets products, as principal or agent. MAS’s fund management licensing page states that a manager generally need not add dealing where it is incidental to fund management; a separate dealing desk for related companies needs dealing added to the CMS licence by Form 5, with a non-refundable S$500 fee.

Providing custodial services means holding a customer’s specified products and settling, collecting income or exercising rights for the customer. Many wealth firms leave custody with the client’s Singapore-licensed bank, which is itself exempt under section 99(1)(a) of the SFA, and so never need this activity.

Does a CMS licensee also need a financial adviser’s licence?

No separate licence is needed. Section 20(1)(d) of the FAA exempts a holder of a CMS licence from holding a financial adviser’s licence, but the firm must notify MAS, appoint its advisers as representatives and follow the FAA conduct rules.

Older commentary cites section 23 for this exemption, its number before the 2020 Revised Edition of the FAA (in operation from 31 December 2021). In the current text the exemption list is section 20(1), which also covers banks, merchant banks, insurers and insurance brokers; section 23 now defines an appointed representative.

The exemption is not a free pass on conduct. Section 20(2) applies sections 34 to 38, 41, 42, 43, 45, 47 and 48 of the FAA to an exempt financial adviser, covering product disclosure, misleading statements, a reasonable basis for recommendations, remuneration frameworks and the independent sales audit unit. MAS’s CMS licence page states that a CMS licensee wishing to advise must lodge a notification as an exempt financial adviser using Form 26 under the Financial Advisers Regulations; MAS’s financial advisers page describes Form 26 as due “within 14 days prior to commencing business”.

An advice-only firm may instead seek a financial adviser’s licence. MAS expects at least 2 directors (one resident in Singapore), a Singapore-resident chief executive officer with at least 10 years of relevant experience, of which 5 were managerial, and at least 3 full-time Singapore-based professionals with 5 years’ relevant experience. Base capital is S$500,000, or S$300,000 plus an additional S$500,000 of professional indemnity insurance (PII); a research-only adviser needs S$250,000. Financial resources must be the higher of S$150,000 or a quarter of the previous year’s relevant annual expenditure. The application fee is S$500 and the annual fee S$2,000.

Can a wealth firm act as trustee without a trust business licence?

Generally not. A CMS licensee’s trust exemption under the TCA extends only to its fund management or custodial services, so acting as trustee of client trusts requires a separate trust business licence or a specific exemption.

Section 15(1)(c) of the TCA exempts a CMS licensee, or a person exempt from holding one, for providing fund management or custodial services, “in respect of the provision of fund management or custodial services”. Banks and merchant banks have a narrower exemption under section 15(1)(a) and (b). A wealth firm that wants to act as trustee by way of business therefore looks at a trust business licence.

MAS’s trust business licence page sets the admission bar: fit and proper shareholders, resident managers and directors; minimum paid-up capital or qualifying assets of S$250,000; adequate PII; and at least 2 resident managers, one with 5 years of relevant experience and the others with 3. Section 13 of the TCA requires MAS approval before appointing a resident manager or a Singapore-resident director. Families who only need a trustee for their own trusts often use a private trust company instead, discussed in our note on the private trust company exemption and its licensed-trustee condition.

How do an MFO and an EAM differ from an exempt single family office?

A single family office (SFO) managing only one family’s assets can rely on MAS’s class exemption. An MFO or EAM serving unrelated clients is carrying on business in a regulated activity and needs a licence for it.

MAS’s media release of 12 June 2026 confirmed the revised SFO framework from 15 June 2026 as a “straight through class exemption from licensing for all qualifying SFOs”. A qualifying SFO notifies MAS, banks with a MAS-licensed bank and files an annual return of its assets under management and bank. MAS’s FAQs on the framework require the notification within 14 days of commencing operations; existing SFOs have until 15 June 2027.

The exemption stops at the family boundary: managing money for a second unrelated family is third-party fund management, and the LFMC route applies. Where that line falls for in-laws, family branches or co-investors is analysed in our piece on when an SFO crosses the licensing line, and existing SFOs that fail the new conditions are covered in our guide to restructuring options before 15 June 2027.

“External asset manager” is a market term, not a licence category. An EAM running discretionary mandates over private bank accounts is usually an LFMC that relies on section 20(1)(d) for advisory mandates; MFOs often add a trust business licence or a licensed trustee partner.

What do the fit and proper rules and the representative notification framework require?

Every route applies MAS’s Guidelines on Fit and Proper Criteria (FSG-G01), and every individual performing a regulated activity or advisory service must be notified to MAS as a representative before acting.

FSG-G01, last revised on 30 May 2025 (effective 30 June 2025), applies across fund managers, dealers, custodians, financial advisers and trust companies, and expects each relevant person to be “competent, honest, to have integrity and to be of sound financial standing”.

Under the representative notification framework (RNF), section 99B of the SFA and section 22 of the FAA bar individuals from acting as representatives unless appointed, provisional or (under the SFA) temporary representatives. The firm lodges Form 3A, 3B or 3C and certifies fitness and propriety through the Corporations and Representatives (CoRe) system. Name entry on the public register of representatives is a condition of appointed status under section 99D of the SFA and section 23 of the FAA.

• Representatives must be at least 21 and meet the entry and examination requirements in Notice SFA 04-N09 (SFA activities) or Notice FAA-N26 (financial advisory services).
• A provisional representative relocating to Singapore needs at least 3 years’ relevant experience and has 3 months to pass the examinations, confirmed by a one-time Form 3D.
• Each new lodgement costs S$200. Annual representative fees are S$700 or S$200 for CMS activities and S$100 for financial advisory services.

Senior hires relocating from London, Zurich or Hong Kong also need a work pass; our sister site covers work pass applications.

In what order should a wealth firm sequence its applications?

Lead with the licence carrying the heaviest admission criteria, usually fund management, and layer exemptions once in-principle approval (IPA) is in hand.

1. Map every service in the client agreement to an SFA activity, a financial advisory service or trust business.
2. Choose the anchor licence and category, and settle the entity, office, key persons and capital.
3. Submit Form 1 through eLicensing, listing any additional SFA activity. MAS expects up to 6 months to review a complete application.
4. On IPA, satisfy the conditions within up to 6 months (MAS may extend by a further 3 months), then receive the licence.
5. Before advising, lodge Form 26 as an exempt financial adviser and appoint advisers as FAA representatives.
6. Lodge Forms 3A, 3B or 3C for each representative and certify fitness and propriety in CoRe.
7. If trustee services are planned, apply separately for a trust business licence using Form 1 under the Trust Companies Regulations.

Incorporation, banking and corporate secretarial work can run in parallel through Raffles Corporate Services; for family-side conditions see our family office requirements map.

Frequently asked questions

Does a licensed fund management company need a financial adviser’s licence to give advice?

No. Section 20(1)(d) of the Financial Advisers Act 2001 exempts CMS licence holders. The firm must still lodge Form 26 with MAS, appoint its advisers as representatives and comply with the FAA conduct provisions listed in section 20(2).

Can a single family office manage money for a second family?

Not under the single family office class exemption. Managing assets for an unrelated family is fund management for third parties, which requires a CMS licence as an A/I or Retail LFMC.

Can a portfolio manager relocating from overseas start work immediately?

The firm can appoint the individual as a provisional representative if they have at least 3 years’ relevant experience and are relocating to Singapore. They then have 3 months to meet the examination requirements, confirmed by Form 3D.

Is an external asset manager a separate licence category?

No. MAS licenses activities. An EAM with discretionary mandates over client bank accounts needs a CMS licence for fund management, and its advisory work is covered by the section 20(1)(d) exemption once Form 26 is lodged.

Sources

• Securities and Futures Act 2001 (Singapore Statutes Online)
• Financial Advisers Act 2001 (Singapore Statutes Online)
• Trust Companies Act 2005 (Singapore Statutes Online)
• MAS: Financial Adviser’s Licence
• MAS: Revised Framework for Single Family Offices to take effect on 15 June 2026

Raffles Corporate Services helps wealth management firms, multi-family offices and fund managers with company set-up, licensing preparation and ongoing compliance in Singapore. Email hello@rafflescorporateservices.com or Call/SMS/WhatsApp +65 8501 7133, or visit Raffles Corporate Services.

Last reviewed: 16 October 2026. The Editorial Team, Variable Capital Companies Act.