01 · THE LICENSING CHANGE
A class exemption replaces the earlier routes, with notification and annual reporting.
Singapore's revised Single Family Office (SFO) licensing framework took effect on 15 June 2026. It provides a structure-agnostic exemption for qualifying SFOs under paragraph 5(1)(ba) of the Second Schedule to the Securities and Futures (Licensing and Conduct of Business) Regulations. Existing offices have until 15 June 2027 to meet the conditions and notify the Monetary Authority of Singapore (MAS).
The MAS licensing FAQ, updated on 31 July 2026, describes a conditional exemption, not an individual approval process. New SFOs must notify MAS within 14 days of starting operations, having satisfied the conditions and opened the relevant accounts. Annual returns are due within four months of the financial year-end and include year-end assets under management and information about the banks used by the SFO and its investment vehicles.
THE CHANGE IN ONE SENTENCE
Qualifying SFOs use a dedicated licensing exemption, but must meet its conditions, notify MAS and file annual returns.
Previously, some SFOs used individual exemptions and others the related-corporation exemption. FAQ 13 says SFOs cannot continue to use the latter instead of the new framework. MAS will generally grant individual exemptions only for exceptional reasons.
The SFO must be incorporated in Singapore. Permitted family and ownership arrangements are defined in the FAQ. Limited participation by qualifying non-family key employees is allowed, subject to separate 10% limits on their aggregate managed assets and non-controlling ownership; not every non-family interest is prohibited.
02 · LICENSING AND TAX STATUS
The manager's exemption does not confer the fund's tax treatment.
The licensing exemption concerns the SFO's fund-management activity. The 13O and 13U incentives concern qualifying fund vehicles and exempt specified income derived from designated investments, subject to conditions. They do not exempt every receipt of the family, manager or bank account.
FAQ 8 expressly distinguishes the regimes. An SFO can qualify for the licensing exemption without a fund tax award. A tax award does not excuse an SFO from the licensing requirements. Tax-incentivised funds can also use qualifying licensed fund managers; such a fund need not be an SFO fund.
THE DISTINCTION IN ONE SENTENCE
Licensing status, fund tax status and bank acceptance require separate examination.
Circular FDD Cir 05/2026, issued on 31 July 2026, covers 13D, 13O, 13OA and 13U. Section 3 addresses non-SFO funds, typically managed by licensed fund management companies; section 4 addresses SFO funds. Removal of the annual minimum designated-investment AUM test for non-SFO funds does not apply correspondingly to SFO funds, which retain a test at application and each basis-period end.
03 · THE VERIFIED 13O AND 13U CONDITIONS
New SFO awards use S$20 million for 13O and S$50 million for 13U.
Paragraphs 4.2–4.4 and Annexes 6B and 7B set out these conditions for new SFO awards approved on or after 1 August 2026, unless MAS notifies otherwise in writing. A basis period is the financial year or period preceding the relevant Year of Assessment (YA).
| Condition | 13O SFO fund | 13U SFO fund or structure |
|---|---|---|
| Minimum AUM in designated investments | S$20 million | S$50 million |
| When the minimum is tested | At application and each basis-period end | At application and each basis-period end |
| Qualifying investment professionals at application | At least 1 | At least 2 |
| Team required by the end of the first YA's basis period | At least 2, including 1 non-family professional | At least 3, including 1 non-family professional |
The required team must then be maintained throughout subsequent basis periods. The recruitment concession is not necessarily a full year: MAS gives an award commencing on 1 August 2026 with a 31 December year-end as an example where the additional professional must be hired by 31 December 2026. Failure results in revocation from the award's commencement date.
THE THRESHOLDS IN ONE SENTENCE
New-award minimums are S$20 million under 13O and S$50 million under 13U, with phased recruitment rather than lower final staffing requirements.
The S$10 million figure belongs to an older 13O arrangement. Annex 6B, footnote 97, records a two-year grace period to reach S$20 million for the relevant 18 April 2022 cohort. It is not the August 2026 new-award minimum. The circular imposes no general 13O step-up to S$50 million or automatic conversion to 13U.
Investments in the family's operating businesses do not count toward the minimum AUM condition, although they can count for other conditions if they qualify as designated investments. Qualifying professionals must meet MAS's role, tax-residence, remuneration and experience or qualification requirements; a nominal appointment is insufficient.
04 · LOCAL SPENDING AND CAPITAL DEPLOYMENT
The revised spending bands separate total local spending from its business-cost component.
Table C and Annexes 6B and 7B apply the same local-spending structure to the new 13O/13OA and 13U SFO awards described above. The band depends on designated-investment AUM at the basis-period end.
| AUM in designated investments | Minimum local spending per basis period | Minimum local business spending within that amount |
|---|---|---|
| Below S$250 million | S$200,000 | S$200,000 |
| S$250 million to below S$2 billion | S$500,000 | S$300,000 |
| S$2 billion or more | S$1 million | S$500,000 |
Eligible donations and grants to qualifying blended-finance instruments may meet the balance above the business-spending floor. Eligible grants count at twice their value; the circular does not give donations that same blanket multiplier. Local business spending covers accounting-recognised operating expenses paid to contracting parties in Singapore.
THE SPENDING RULE IN ONE SENTENCE
Total local-spending tiers are S$200,000, S$500,000 and S$1 million, with separate minimum business-spending amounts.
Capital deployment is a separate condition. Paragraph 4.5(b) requires the lower of 10% of AUM in designated investments or S$10 million in specified eligible investments. The revised categories cover investments listed on MAS-approved exchanges; those distributed by MAS-licensed financial institutions in Singapore, excluding equities listed outside approved exchanges; and unlisted Singapore operating companies with substantive local presence. Certain categories receive double recognition under the circular's definitions.
The first deployment test falls at the end of the basis period for the first full YA after commencement, then at each subsequent basis-period end. In MAS's August-start, December-year-end example, recruitment is due by December 2026, but the first deployment test is December 2027. These are different deadlines.
05 · EXISTING AWARDS AND THE 2029 HORIZON
Existing awards need their own conditions checked and do not all expire in 2029.
Paragraph 4.6 and Annexes 6B and 7B distinguish awards subject to pre-18 April 2022, 18 April 2022 and 5 July 2023 conditions. Cohorts depend on the submission history defined in the footnotes, not simply the office's establishment date. Revised annual conditions apply from the YA whose basis period ends on or after 1 August 2026, unless MAS specifies otherwise in writing.
Older awards are not all moved wholesale onto new-award conditions. For example, the earliest 13O cohort retains its specified total-business-spending condition, while later cohorts use the revised local-spending and capital-deployment requirements. The applicable table and award terms remain essential.
THE TRANSITION IN ONE SENTENCE
An existing award's cohort determines its conditions, while end-2029 is not a universal expiry date for approved funds.
Where an award already requires a private banking account, that condition continues. Where it contains no banking-account condition, the annexes require a banking or private banking account with a MAS-licensed financial institution and allow three months from 1 August 2026 to obtain it. MAS may revoke the award from the end of that grace period for non-compliance. This tax deadline is separate from the licensing transition to 15 June 2027.
Paragraph 2.3 confirms that the schemes run to 31 December 2029 and will be reviewed before then. Funds awarded exemption by that date can continue to enjoy it for the life of the fund, provided they satisfy the conditions in each basis period. Any further extension or refinement remains subject to review.
06 · OWNERSHIP AND DISCLOSURES
ACRA's register and MAS's reporting requirements should not be conflated.
ACRA's guidance covers registrable controllers who may be individuals or legal entities. Affected entities must update the private register within seven days after the controller reports a change, then file with ACRA's Central RORC within two business days after that update. The underlying register obligation dates to 2017. This is not a new, SFO-only natural-person register introduced in early 2026.
THE DISCLOSURE RULE IN ONE SENTENCE
ACRA's two-business-day filing clock runs from the private-register update, while separate MAS tax obligations require their own analysis.
Licensing FAQ 8 says shareholding or operational changes need not be notified under the licensing framework. That is not a general reporting waiver: the same answer directs SFO funds to their tax-award conditions, circulars and legislation. The bank's due diligence is a further, separate process.
07 · WHAT THIS MEANS FOR CLIENTS
The account requirement attaches to specified entities and does not guarantee onboarding.
Licensing FAQs 1 and 11 require the SFO and its Singapore-incorporated investment vehicles each to maintain an account with a MAS-licensed bank in Singapore. Foreign-incorporated vehicles may instead use a regulated bank in a jurisdiction with AML/CFT requirements consistent with FATF standards. A family member's personal account is not the same as an account held by the manager or investment vehicle.
The tax requirement is narrower in product terms: for new SFO awards, paragraph 4.5(c) requires a private banking account with a MAS-licensed financial institution at application and throughout each basis period. For an approved 13U structure, at least one approved entity must hold that account. The foreign-vehicle option under the licensing FAQ should not be assumed to satisfy the tax condition.
THE CLIENT IMPLICATION IN ONE SENTENCE
A family office needs the correct entity and account arrangement for each regime, alongside the bank's independent customer checks.
For a relationship involving Bank of Singapore, DBS Bank or Standard Chartered Singapore, offbnk's practical reading is to distinguish the SFO manager, fund vehicle and contracting bank, then identify which account satisfies which requirement. MAS expressly states that banks conduct risk-based customer due diligence and ongoing monitoring of SFOs and their investment vehicles. An exemption or tax award does not replace that process.
The sources do not establish a resulting change to these banks' fees, minimum relationship balances or customer contracts. Nor do the fund AUM thresholds describe a bank's commercial minimum. The directory links provide institutional context, without implying guaranteed account opening or an offbnk partnership.
FROM THE DIRECTORY
The Singapore bank profiles relevant to this report, in alphabetical order:
OFFICIAL SOURCES
Legal texts and publications from the responsible authorities.
- 01Monetary Authority of Singapore — MAS — Licensing Exemption Framework for Single Family Offices: FAQs (updated 31 July 2026) ↗
- 02Monetary Authority of Singapore — MAS — FDD Cir 05/2026: Tax Incentive Schemes for Funds (sections 2–4; Annexes 6B, 7B and 11) ↗
- 03Accounting and Corporate Regulatory Authority — ACRA — Setting up & maintaining a Register of Registrable Controllers ↗