The Monetary Authority of Singapore (MAS) has introduced a new Licensing Exemption Framework for Single Family Offices (SFOs), effective 15 June 2026.
The new framework replaces the previous case-by-case licensing exemption approach with a notification-based regime. Qualifying SFOs that satisfy the prescribed conditions may rely on the licensing exemption by notifying MAS, rather than applying for an exemption on a case-by-case basis.
This update outlines the key changes and highlights the actions that existing and newly established SFOs should consider.
Key Takeaways
- MAS’s new Licensing Exemption Framework for Single Family Offices (SFOs) came into effect on 15 June 2026, replacing the old case-by-case approach with a simpler notification-based regime.
- To qualify, an SFO must meet prescribed conditions, including being incorporated in Singapore, managing funds only for eligible family members and related parties, keeping key-employee assets within 10% of total AUM, and maintaining the required banking arrangements.
- Qualifying SFOs must file an annual return with MAS within four months of their financial year end, and MAS has indicated that filing extensions will generally not be granted.
- Existing SFOs have a one-year transitional period until 15 June 2027 to review their structures and bring them into line with the new requirements. Overall, the changes deliver greater certainty and a lighter administrative load, as eligible SFOs simply notify MAS rather than seek individual exemption approvals.
What Was the Previous Framework?
Before the current rules took effect, SFOs in Singapore generally depended on one of two pathways to sidestep the need for a capital markets services licence covering fund management:
- Related Corporation Exemption: This was a class exemption set out in paragraph 5(1)(b) of the Second Schedule to the Securities and Futures (Licensing and Conduct of Business) Regulations. It allowed a corporation to manage funds on behalf of its related corporations without holding a licence if applicable conditions were satisfied.
- Case-by-Case Exemption: When an SFO’s ownership arrangement or organisational structure did not align cleanly with the related-corporation exemption – for instance, where the SFO was held through a trust, a foundation, or another non-corporate vehicle, it could approach MAS for a tailored licensing exemption under section 99(1)(h) of the Securities and Futures Act 2001.
In reality, the earlier framework left several SFO structures – especially those using trusts or foundations as holding vehicles – without access to a clear-cut class exemption. This meant that they had to submit individual applications to MAS, leading to added administrative effort and uncertainty.
What Are the Key Changes Under the New Framework?
Notification to MAS
Qualifying SFOs are required to submit a Notice of Commencement of Business to MAS.
- New SFOs must submit the notification within 14 days of commencing operations in Singapore
- Existing SFOs that commenced operations before 15 June 2026 are granted a one-year transitional period and must comply with the new framework by 15 June 2027
Who Qualifies for the New Licensing Exemption Framework?
To rely on the licensing exemption, an SFO must satisfy the prescribed conditions under the Securities and Futures (Licensing and Conduct of Business) Regulations.
These include:
- Being incorporated in Singapore
- Conducting fund management only for eligible family members, qualifying family trusts, wholly-owned family corporations, family-funded charitable organisations and qualifying key employees
- Ensuring that assets contributed by key employees do not exceed 10% of the SFO’s total assets under management in aggregate
- Maintaining the required banking arrangements with MAS-licensed banks (or qualifying regulated banks for foreign-incorporated fund vehicles)
Expanded Definition of “Family Member”
The framework provides a clearer definition of “family member”, which generally includes lineal descendants of a common ancestor, together with current or former spouses, adopted children, stepchildren, parents-in-law and siblings-in-law.
The common ancestor must not be more than five generations removed from the youngest generation that established the SFO in Singapore. Once established, future generations may continue to be served by the SFO.
Annual Reporting Requirements
Following the submission of the commencement notification, SFOs are required to submit an annual return to MAS.
The annual return must be lodged within four months after the end of the SFO’s financial year. MAS has indicated that extensions to the filing deadline will generally not be granted.
What Do the Changes Mean?
Greater Certainty
There is no longer a need for formal case-by-case applications or pre-approvals for SFOs held through trusts, foundations, or other non-corporate structures as the new framework allows qualifying SFOs to rely on the licensing exemption upon satisfying the prescribed conditions and notifying MAS.
Lower Administrative Complexity
The ongoing obligations described by MAS are relatively straightforward: maintain an account with a MAS-licensed bank and file a simple annual return covering AUM and bank details. SFOs that qualify now also only need to notify MAS rather than seek individual exemption treatment, which should reduce friction, time, and advisory costs.
Heightened Monitoring
MAS has also stated that the framework is intended to strengthen oversight of SFOs in Singapore through its notification and annual return requirements.
What Should Existing SFOs Do?
Existing SFOs should review whether their current structures satisfy the prescribed conditions under the new framework, including:
- Ownership and family structure
- Eligibility of investors and beneficiaries
- Banking arrangements
- Governance framework
- Required declarations and supporting documentation
- Ongoing annual reporting obligations
Given the transitional deadline of 15 June 2027, existing SFOs should assess their structures early to allow sufficient time for any necessary restructuring and compliance measures.
How Can InCorp Help?
Our Private Client Services team advises ultra-high-net-worth families and family offices on the establishment, structuring and ongoing administration of Singapore Single Family Offices, including:
- Singapore Single Family Office establishment
- Assessment of eligibility under the licensing exemption framework
- Family office and investment holding structure design
- Preparation and submission of MAS notifications
- Annual regulatory reporting
- Applications for the Section 13O and Section 13U tax incentive schemes
- Singapore trust and fund structuring
- Ongoing accounting, corporate secretarial, tax and regulatory compliance
Contact our team today to discuss how the new licensing exemption framework may affect your existing or proposed family office structure!
FAQs about Licensing Exemption Framework for Single Family Office in Singapore
Do existing SFOs need to act, and how much time do they have to comply?
- Yes. SFOs already operating in Singapore are given a one-year transitional period, running until 15 June 2027, to bring their arrangements in line with the revised framework.
What happens if an SFO does not meet the qualifying criteria?
- An SFO that does not satisfy the conditions for the class exemption cannot rely on the streamlined notification route. In that situation, the SFO would generally need to consider alternative options, such as holding the relevant licence for fund management or exploring another appropriate arrangement with MAS.
How does the new framework differ from the previous exemption routes?
- Under the previous framework, most SFOs relied on either the related corporation exemption, which allowed a corporation to manage funds for its related corporations without holding a fund management licence, provided the relevant conditions were met, or a case-by-case licensing exemption granted by MAS where an SFO's ownership or structure did not fall within the related corporation exemption.
Find out more about how this new framework benefits you!
About the Author
