Singapore VCC insights

Designated Investments 13O: Will MAS Add Digital Payment Tokens and Insurance Policies?

By VCC Editorial Team · Published 18 October 2026

Short answer: Digital payment tokens and insurance policies are not on the designated investments list for the 13O and 13U fund schemes today. On 5 October 2026 the MAS Chairman said single family offices had asked for them, that MAS is reviewing the list, and that an updated list and implementation date will be announced later. Nothing has changed yet.

The designated investments 13O and 13U list decides two things for a family office fund: which income can be exempt, and which assets count towards the minimum assets under management. That is why the remarks by Mr Gan Kim Yong, Deputy Prime Minister and Chairman of the Monetary Authority of Singapore (MAS), at the Wealth Management Institute’s Global-Asia Family Office Summit on 5 October 2026 drew attention. This note sets out what the current list covers, what was and was not said, and what a single family office (SFO) can sensibly prepare before MAS publishes anything.

This article is general information only and is not legal, tax or immigration advice. For matters needing legal advice, we work with a panel of experienced Singapore law firms.

What did MAS actually say on 5 October 2026?

MAS confirmed a request and a review, not a decision. The Chairman said SFOs had asked for greater flexibility in managing portfolios and deploying capital from Singapore, including into digital payment tokens and insurance policies, and that MAS is considering this feedback in its regular review of the tax policy framework.

The published text of the speech links the review to the designated investment list, which it describes as the list setting out the types of investments that can qualify for tax exemption under Singapore’s tax incentive schemes for funds. It closes the point by saying MAS will announce the updated list and implementation date in due course.

Three things follow. First, the speech does not say which assets will be added, on what terms, or with what limits. Second, it gives no effective date, so no current or past income is affected. Third, the same speech dealt with private banking account opening and with family offices investing in Singapore start-ups, which places the review within MAS’s broader push to keep the SFO framework competitive rather than as a stand-alone crypto policy.

What is on the designated investments 13O and 13U list today?

The current list is broad but drafted asset by asset. If an asset class is not named, or does not fit within a named category, it is not a designated investment.

Annex 3 to MAS Circular FDD Cir 05/2026 lists the categories below. MAS states that the list is provided for ease of reference, so the underlying legislation remains the authority.

Group	Examples on the current list (Annex 3)	Notable exclusions or conditions
Securities	Stocks and shares, debt securities, REIT and ETF units, units in unit trusts, registered business trust units, structured products	Securities of unlisted companies trading or holding Singapore immovable property (other than developers)
Derivatives	Exchange-traded futures, interest rate and currency contracts, financial derivatives on DI or a financial index, commodity, emission and freight derivatives	Financial derivatives must relate to a DI or a financial index
Cash and credit	Deposits, foreign exchange transactions, loans, bankers’ acceptances, receivables and letters of credit, liquidation claims	Loans connected with Singapore immovable property
Real assets	Immovable property outside Singapore, physical investment precious metals, physical commodities linked to commodity derivative trading	Singapore immovable property; physical commodities above the 15% trade volume limit
Fund and partnership interests	Private trusts and non-publicly traded partnerships investing wholly in DI, publicly traded partnerships and LLC interests not trading in Singapore, real estate investment fund interests, TK and TMK interests, Islamic equivalents	Vehicles investing in Singapore immovable property

The pattern matters for the current review. MAS widens the list as funds’ investments change; the most recent example is the removal of the precious metals cap. Paragraph 7.1 of the Circular says the DI and specified income lists are regularly reviewed to include new types of investments made by funds.

How are digital payment tokens treated inside a 13O or 13U fund now?

A digital payment token is not a designated investment today, so gains from it are not specified income and fall outside the scheme exemption. Whether they are taxed then depends on Singapore’s general income tax rules.

The IRAS e-Tax Guide on the income tax treatment of digital tokens (current edition published 30 January 2026) treats a payment token as intangible property, not currency. A gain on disposal is taxable if the disposal is a trading activity, which IRAS assesses using the badges of trade. A family office fund that turns over a token book actively therefore faces a real risk of revenue treatment on that book, even though the rest of its portfolio is exempt.

There is a second, quieter effect. Because AUM now means AUM in DI, token holdings do not count towards the S$20 million or S$50 million minimum for a new SFO award, nor towards the AUM figure that sets the local spending tier. A family that has moved a meaningful share of its wealth into tokens can find its fund closer to the threshold than its headline portfolio suggests. The site’s note on family office minimum AUM explains how the different minimums interact.

Why would insurance policies matter to a family office?

Families use life policies for liquidity on death, estate equalisation and long-horizon savings, and some prefer to hold them inside the family structure. A policy is not on the current list, so a fund holding one gains no exemption and no AUM credit for it.

The speech names “insurance policies” without further detail. It does not say whether MAS has in mind traditional whole-of-life cover, investment-linked policies or bespoke wrappers, or whether any addition would be limited by size, as precious metals were until 1 August 2026. Until MAS publishes, any family office paper that assumes a particular design should be treated as speculative.

What could change, and what is still unknown?

If MAS adds either asset, income from it would become capable of being specified income and the asset would count towards AUM in DI. Everything else, including timing and conditions, is open.

Question	Position at 18 October 2026
Will digital payment tokens be added?	Under review. No decision announced.
Will insurance policies be added?	Under review. Type of policy not specified.
Effective date	To be announced with the updated list.
Caps or conditions	Not stated. The precious metals precedent shows MAS has used percentage caps before.
Retrospective effect	Not indicated. Plan on the basis that only income from the announced date would qualify.
Which schemes	The speech refers to the tax incentive schemes for funds generally. The current list sits in the Circular covering 13D, 13O, 13OA and 13U.

The review sits beside other changes this year. MAS’s 19 August 2026 package announced a tax exemption for qualifying profit-related returns of fund managers, covered in our note on carried interest tax exemption in Singapore. The two are separate: one concerns what a fund holds, the other how its manager is paid.

What can a single family office prepare now?

Prepare the facts that any rule will need, without restructuring on a guess. The useful work is classification, valuation and custody evidence.

1. Inventory non-DI assets. List every holding that is not on Annex 3, including tokens, policies, art and operating company interests, and record which entity owns each one.
2. Reconcile AUM in DI. Recompute the fund’s AUM using DI only at the last basis period end and test it against the S$20 million or S$50 million minimum and the local spending tiers.
3. Document the token strategy. Record whether tokens are held long term or traded, the expected holding period and the decision process. This is the evidence IRAS will look at under the badges of trade.
4. Fix valuation and custody. Agree a written valuation source and cut-off for each token, and confirm who holds the keys or the custody account. Our digital-asset wallet recovery drill sets out the custody controls a board should test.
5. Map policy ownership. For each insurance policy, record the owner, the life assured, the beneficiary and the surrender value, so the family can move quickly if the list changes.
6. Gate new trades. Keep a pre-trade check so that the fund does not buy non-DI assets by accident. A worked control is in our note on building a designated-investment pre-trade gate.

Keep these papers in the annual evidence file the fund already maintains for MAS and IRAS, described in building the annual evidence file for 13O and 13U.

Should a family office move tokens or policies into its fund before MAS decides?

Generally, no. Transferring assets into an incentivised fund today brings no exemption and no AUM credit, and may create a taxable event or a valuation dispute.

The safer course is to keep non-DI assets where they are, usually in a separate holding company or trust outside the incentivised fund, and to revisit the structure once MAS publishes the list and any conditions. If the fund already holds such assets, the priority is accurate reporting of AUM in DI and a clear record of how gains on those assets are being treated for tax.

Frequently asked questions

Are digital payment tokens designated investments for 13O and 13U funds?

No. They are not on the list in Annex 3 of FDD Cir 05/2026. MAS said on 5 October 2026 that it is reviewing a request to include them, with any change to be announced together with an implementation date.

Has MAS published the updated designated investment list?

Not as at 18 October 2026. The speech said MAS will announce the updated list and implementation date in due course.

Do tokens count towards the S$20 million minimum AUM for a 13O SFO fund?

No. Since 1 January 2025 the minimum is measured as AUM in designated investments, and tokens are not designated investments today.

How are gains on payment tokens taxed if they fall outside the exemption?

IRAS treats a payment token as intangible property. A gain on disposal is taxable if the disposal is a trading activity, judged by the badges of trade; where the disposal is not a trading activity, the gain is capital and Singapore does not tax capital gains.

Did the 2026 Circular change anything else on the list?

Yes. From 1 August 2026 MAS removed the 5% cap on physical investment precious metals, so they now qualify without that limit.

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.

Last reviewed: 18 October 2026. The Editorial Team, variablecapitalcompaniesact.com.