Singapore VCC insights

Singapore Family Office Requirements 2026: Licensing, Tax Incentive, Banking and Residency Conditions

By VCC Editorial Team · Published 26 May 2026 · Updated 12 October 2026

Photo: Shawn on Unsplash

Short answer: A Singapore single family office must satisfy four separate regimes. It needs a Singapore-incorporated entity that fits the MAS licensing exemption in force since 15 June 2026, with a 14-day notification and an account at a MAS-licensed bank. Tax exemption needs a 13O or 13U award, and principals and staff need their own passes or residency.

Key facts at a glance

The revised MAS framework for single family offices (SFOs) took effect on 15 June 2026 as a class exemption from licensing under the Securities and Futures Act 2001.
A new SFO must file a Notice of Commencement of Business with MAS within 14 days of starting operations. Existing SFOs have until 15 June 2027 to comply and notify.
The published conditions for the licensing exemption contain no minimum assets under management (AUM). AUM minimums apply only to the tax schemes.
Section 13O and 13OA funds need S$20 million in designated investments (DI), and section 13U funds need S$50 million, under the Income Tax Act 1947. The schemes run until 31 December 2029.
From 1 January 2027, new Employment Pass applications in financial services must meet a qualifying salary of at least S$6,600 a month, up from S$6,200.
Section 46 of the Variable Capital Companies Act 2018 requires a VCC to have a permissible manager at all times. Paragraph 46(2)(b) was deleted with effect from 6 May 2026.

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.

Most summaries of Singapore family office requirements merge four separate regimes into one list. The regulatory licensing exemption, the fund tax incentive, the bank account condition and the immigration position of the people involved each have their own regulator, test and timetable. This guide sets them out separately, adds the corporate basics for a company or a variable capital company (VCC), and gives a decision sequence. All primary sources were checked on 12 October 2026.

What are the Singapore family office requirements in 2026?

There are four legally independent layers. The MAS licensing exemption gives no tax exemption, and a tax award gives no right to live in Singapore.

Regime	Regulator and source	Core test	Mandatory?
Licensing exemption	MAS, Securities and Futures Act 2001 and the Securities and Futures (Licensing and Conduct of Business) Regulations	Single-family clients, family funding, Singapore incorporation, notification, MAS-licensed bank account, annual return	Yes, unless licensed
Fund tax incentive	MAS, under sections 13O, 13OA and 13U of the Income Tax Act 1947	Minimum AUM in DI, investment professionals, local spending, capital deployment, private banking account	Optional
Banking	MAS (both regimes above)	An account with a MAS-licensed bank for the SFO and its fund vehicles, and a private banking account for a 13O or 13U fund	Yes
Immigration	Ministry of Manpower (MOM) for work passes, and the Economic Development Board (EDB) for the Global Investor Programme (GIP)	Employment Pass salary and COMPASS points, or GIP investment conditions	Where a pass is needed

The licensing exemption has no AUM threshold in its published conditions. Our article on family office minimum AUM in Singapore covers that point and is not repeated here.

Which entity do you need: a Singapore company or a VCC?

The SFO itself must be incorporated in Singapore. In practice that means a private company limited by shares under the Companies Act 1967. The fund vehicle it manages can be another company, a VCC under the Variable Capital Companies Act 2018, or a foreign vehicle.

A Singapore company must have at least one director who is ordinarily resident in Singapore (section 145 of the Companies Act 1967). It must also have a resident company secretary who is a natural person (section 171) and a registered office in Singapore from incorporation (section 142). A sole director cannot also act as secretary.

A VCC adds further requirements. The Accounting and Corporate Regulatory Authority (ACRA) requires at least one ordinarily resident director. That director must be a qualified representative or a director of the VCC’s fund manager. The VCC must appoint a company secretary within six months of incorporation and an auditor within three months, and the audit exemptions do not apply. An Employment Pass holder needs a Letter of Consent before acting as a director. Our sister firm Singapore Secretary Services handles company secretary and registered office appointments.

Can a single family office manage its own VCC?

Not on the face of the current statute, unless the SFO holds a licence or falls within a listed exemption. Under section 46(2) of the Variable Capital Companies Act 2018, as in force on 12 October 2026, a VCC manager must be one of three things:

a holder of a capital markets services licence for fund management;
a person mentioned in section 99(1)(a) to (d) of the Securities and Futures Act 2001, such as banks and certain other financial institutions; or
a person prescribed by regulation.

Paragraph 46(2)(b) was deleted by Act 24 of 2025 with effect from 6 May 2026, and section 46(3) says a VCC cannot be its own manager.

The SFO class exemption sits in the Second Schedule to the Securities and Futures (Licensing and Conduct of Business) Regulations, not in section 99(1)(a) to (d). The MAS SFO FAQs that we were able to check do not say that an exempt SFO counts as a permissible VCC manager. We have not found a regulation prescribing SFOs for that purpose. A family that wants a VCC should therefore plan on appointing a licensed fund management company, or take specific advice on any prescribed class. Our analysis of section 46 after 6 May 2026 sets out the statutory text.

What does the MAS licensing exemption require?

An SFO that meets the conditions in the MAS FAQs is exempt from holding a fund management licence. It does not need a case-by-case exemption. MAS describes the framework as structure-agnostic and as a “straight through class exemption” in its media release of 12 June 2026.

The MAS FAQs on the licensing exemption framework, issued on 12 June 2026, set these conditions:

Clients: fund management only for family members, family trusts and corporations wholly owned by and for the sole benefit of the family, charities funded exclusively by the family, and key employees.
Family: all lineal descendants of a common ancestor, living or deceased. This includes current or former spouses, adopted children, stepchildren, parents-in-law and siblings-in-law. The common ancestor must be no more than five generations removed from the youngest generation that set up the SFO in Singapore.
Key employees: executive directors, the chief executive officer, the chief financial officer and investment professionals. Their assets must not exceed 10% of total AUM in aggregate, and they may hold a non-controlling stake of up to 10% in the SFO.
Ownership: the SFO may be held through a trust, foundation or other structure, but its funding must come only from the family and key employees.
Notification: a new SFO files a Notice of Commencement of Business within 14 days of starting operations in Singapore.
Annual return: the first return is due within four months of the financial year end and covers total AUM and the name of the bank.

MAS will generally not grant case-by-case exemptions without exceptional reasons, and no legal opinion is required with the notification. Our step-by-step note on filing the 2026 SFO licensing-exemption notice covers the filing itself.

If an office takes in a second unrelated family or any third-party money, it falls outside the exemption. See when an SFO crosses the licensing line into multi-family office territory.

What changed on 15 June 2026?

The exemption moved from a mix of existing routes to a single class exemption with filing and reporting duties.

Item	Position from 15 June 2026
Legal basis	Class exemption in paragraph 5(1)(ba) of the Second Schedule to the Securities and Futures (Licensing and Conduct of Business) Regulations
Filing	Notice of Commencement of Business within 14 days of starting operations
Bank account	The SFO and each fund vehicle must hold an account with a MAS-licensed bank
Reporting	Annual return within four months of financial year end, with no further extensions
Legal opinion	Not required
Existing SFOs	One year to comply and notify, ending 15 June 2027

For offices formed before 15 June 2026 that cannot meet the new conditions, our article on the single family office transition to 15 June 2027 sets out restructuring options.

What are the 13O and 13U tax incentive conditions?

The tax schemes exempt qualifying fund income in a fund vehicle managed by the SFO. They are optional and carry their own economic conditions. MAS set out the current conditions for SFO funds in its circular on tax incentive schemes for funds (FDD Cir 05/2026, dated 31 July 2026). They apply to new awards approved on or after 1 August 2026.

Condition	Section 13O / 13OA	Section 13U
Minimum AUM in DI	S$20 million	S$50 million
Qualifying investment professionals	2, at least 1 not a family member	3, at least 1 not a family member
Minimum local spending	S$200,000 where AUM in DI is below S$250 million; S$500,000 (with at least S$300,000 local business spending) from S$250 million to below S$2 billion; S$1,000,000 (with at least S$500,000 local business spending) at S$2 billion and above
Capital deployment	The lower of 10% of AUM in DI or S$10 million, invested in DI listed on approved exchanges, distributed by MAS-licensed institutions in Singapore, or in non-listed Singapore operating companies. Some categories count at 2x
Banking	A private banking account with a MAS-licensed financial institution

The MAS fund tax schemes page defines a qualifying investment professional as a portfolio manager, research analyst or trader. That person must earn more than S$3,500 a month, spend more than 50% of their time on the qualifying activity and be a Singapore tax resident. Under the circular, a 13O fund may apply with one investment professional and a 13U fund with two. The full number must be in place by the end of the first basis period, or the award is revoked from its start date.

The schemes are due to expire on 31 December 2029. Funds already awarded by then keep the exemption for the life of the fund, as long as they continue to meet the conditions.

Why does the MAS-licensed bank condition matter twice?

The account condition appears in both regimes with different wording, and each must be met.

Under the licensing exemption, the SFO and each of its fund vehicles must open and keep an account with a MAS-licensed bank. A foreign-incorporated fund vehicle may instead bank in Singapore or with a regulated bank in a jurisdiction whose anti-money laundering standards are consistent with those of the Financial Action Task Force. Under the tax schemes, the fund needs a private banking account with a MAS-licensed financial institution at application and throughout each basis period.

Start bank onboarding early: the 14-day notification clock runs from the start of operations, not from account opening.

What immigration route do principals and staff need?

Immigration is separate from both MAS regimes. Employees, including any non-Singaporean investment professionals counted for 13O or 13U, need a work pass. A principal who wants permanent residence through investment looks to the GIP.

Employment Pass: under the MOM eligibility rules, candidates must clear two stages. Stage 1 is the qualifying salary, benchmarked to the top third of local professional, manager, executive and technician (PMET) salaries by age. Stage 2 is the Complementarity Assessment Framework (COMPASS), which requires 40 points.

Financial services: the current minimum is S$6,200 a month, rising with age to S$11,800 at 45 and above.
From 1 January 2027 (new applications) and for renewals of passes expiring from 1 January 2028: S$6,600, rising to S$12,700.
Other sectors: S$5,600, moving to S$6,000 on the same dates.
COMPASS exemption: candidates on a fixed monthly salary of at least S$22,500 are exempt.
Small firms: an employer with fewer than 25 PMETs scores 10 points by default on each of the diversity and local employment criteria.

The S$3,500 tax-scheme floor for an investment professional is far below the Employment Pass qualifying salary, so the pass is usually the binding constraint for foreign hires. Our sister firm Singapore Employment Agency handles Employment Pass applications.

Global Investor Programme: Option C applies to a Singapore SFO with AUM of at least S$200 million, of which at least S$50 million must be transferred into Singapore and deployed in EDB-specified investments. The Family Office Principal profile requires at least five years of entrepreneurial, investment or management track record and net investible assets of at least S$200 million. The EDB factsheet gives a S$20,000 application fee and a processing time of about 12 months. Confirm the current list of specified investments with EDB.

In what order should a family work through the requirements?

Run the four regimes as one sequence.

Confirm that every source of money is the family, a family-funded charity or key employees within the 10% limits. If not, the office needs a licence.
Incorporate the SFO in Singapore with a resident director, a company secretary and a registered office.
Choose the fund vehicle. For a VCC, appoint a manager that satisfies section 46(2), which in most cases means a licensed fund management company.
Open accounts with a MAS-licensed bank for the SFO and each fund vehicle.
Start operations and file the Notice of Commencement of Business within 14 days.
If you want tax exemption, check AUM in DI against S$20 million (13O) or S$50 million (13U), hire the investment professionals and apply to MAS.
Run Employment Pass applications for foreign staff alongside, and consider the GIP separately for principals.
Diarise the annual return, which is due within four months of financial year end, and each basis-period test for the tax award.

Frequently asked questions

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

Not for the licensing exemption, whose published conditions contain no AUM figure. The S$20 million and S$50 million minimums apply only to 13O and 13U funds, and the S$200 million figure applies to GIP Option C.

Does a family office need MAS approval before it starts?

No. A qualifying SFO notifies MAS within 14 days of starting operations, and the system issues an acknowledgement. A tax award, by contrast, needs MAS approval of an application.

Can family members count as investment professionals for 13O?

Yes, but not all of them. A 13O fund needs at least one non-family investment professional out of two, and a 13U fund needs at least one out of three. Each must be a Singapore tax resident earning more than S$3,500 a month.

What happens to an SFO set up before 15 June 2026?

It has until 15 June 2027 to meet the conditions and file its notification. After that date it must qualify for the exemption, hold a licence or stop fund management activity in Singapore.

Sources

Raffles Corporate Services helps families take a Singapore family office through incorporation, VCC set-up, the MAS notification and annual compliance in one sequence. Email hello@rafflescorporateservices.com or Call/SMS/WhatsApp +65 8501 7133, or visit Raffles Corporate Services.

Last reviewed: 12 October 2026. The Editorial Team, Variable Capital Companies Act.