Singapore Has a New Licensing Exemption Framework for Family Offices, Here Is What Changed

The class exemption from fund management licensing for Single Family Offices now comes with a clearer set of rules on family perimeter, ownership, employee participation, banking and ongoing reporting, plus a hard transition deadline for offices already operating in Singapore.

Singapore has changed the way Single Family Offices, generally shortened to SFOs, qualify for an exemption from fund management licensing. The new framework took effect on 15 June 2026. It gives qualifying SFOs a specific class exemption from the requirement to hold a Capital Markets Services licence for fund management, provided they meet the prescribed conditions.

For new family offices, the practical difference is that the exemption now comes with a clearer set of rules around who the SFO can manage money for, who can own it, how key employees can participate, where accounts must be maintained, and what needs to be reported to the Monetary Authority of Singapore. For SFOs already operating in Singapore, there is another date to pay attention to, 15 June 2027, when the transitional period for moving from the previous exemption arrangements comes to an end.

What Just Changed

The new exemption sits under paragraph 5(1)(ba) of the Second Schedule to the Securities and Futures (Licensing and Conduct of Business) Regulations, made under the Securities and Futures Act 2001. The important point is that this is still an exemption from licensing. A qualifying SFO does not apply for and obtain an SFO licence. Instead, it can carry on fund management without holding a Capital Markets Services licence if it falls within the class exemption and continues to meet the relevant conditions.

What has changed is that those conditions are now much more clearly defined. The rules spell out the family perimeter, eligible entities, key employee participation, banking arrangements, and ongoing regulatory obligations.

Who Actually Counts as Family

This matters more than it might first appear. The exemption is designed for a single family, so the Regulations need to establish where that family begins and ends. The rules do this by reference to a common ancestor and the prescribed generational limits, together with specific categories of family relationships. These include relevant lineal descendants, as well as current and former spouses, current and former stepchildren, adopted children, parents in law, and siblings in law, subject to the detailed definitions in the Regulations.

That precision is important. Someone being regarded informally as part of the wider family does not automatically mean that person falls within the regulatory definition. For a straightforward family structure this may not create much difficulty. For a large family spanning several generations, marriages, and jurisdictions, working out exactly who falls inside the permitted family perimeter can require more attention.

Trusts, Foundations and Family Companies

Family wealth is rarely held entirely in the personal names of family members. It may sit in trusts, holding companies, foundations, investment vehicles, and other structures. The new framework recognises this by allowing an SFO to conduct fund management for qualifying entities as well as individual family members, provided those entities satisfy the conditions set out in the Regulations. That makes the framework capable of accommodating different family wealth structures without requiring every family to organise its assets in exactly the same way.

But it does not mean every trust, foundation, or family company automatically qualifies. The ownership, beneficiaries, and sources of assets still need to fit within the permitted framework. For families with existing cross border structures, this is one of the areas worth mapping carefully before relying on the exemption.

Can Employees Invest Alongside the Family

Yes, but there are limits. The framework allows certain key employees to participate alongside the family, while putting boundaries around how much non family involvement the SFO can have. Two figures are particularly important.

This gives family offices some flexibility to align senior employees economically with the family without changing the basic character of the structure into something closer to a commercial multi client fund manager. For SFOs already using employee co-investment or ownership arrangements, these limits are worth checking against the existing structure.

Banking Arrangements Now Matter to the Exemption

The SFO must maintain at least one account in its own name with a bank licensed under Singapore’s Banking Act. Singapore investment vehicles managed by the SFO are also subject to prescribed banking requirements. Foreign investment vehicles have more flexibility, and depending on the circumstances, the relevant account can be maintained with a Singapore licensed bank or an overseas bank meeting the regulatory and anti money laundering requirements specified in the Regulations.

For families operating investment structures across several jurisdictions, this is an important practical point. The question is no longer simply where it is commercially convenient for each vehicle to bank. The banking structure also needs to work with the conditions of the licensing exemption.

Starting a New SFO, the 14 Day Notification

For an SFO commencing the relevant fund management business on or after 15 June 2026, relying on the exemption does not involve applying for a Capital Markets Services licence and waiting for MAS approval. Instead, the SFO must satisfy the conditions of the class exemption and lodge the prescribed notice of commencement of business with MAS no later than fourteen days after commencing business.

That distinction is important. The new regime is notification based, not an application and approval licensing process. But notification should not be confused with automatic eligibility. The SFO still needs to make sure that its structure falls within the exemption before relying on it.

Already Running an SFO, 15 June 2027 Is the Date to Watch

Existing SFOs operating under the previous exemption arrangements have a transitional period ending on 15 June 2027. An eligible existing SFO that wants to continue relying on the new class exemption must lodge the prescribed notice of continuation with MAS within the transitional period.

There is an important detail here. The previous exemption does not simply continue alongside the new framework indefinitely. Under the transitional provisions, it ceases to apply upon the relevant event prescribed by the Regulations, including when the SFO transitions by filing its notice of continuation or when the transitional period expires, as applicable.

So the exercise is not simply about remembering to submit a form by June 2027. Before transitioning, an existing family office should be comfortable that its family perimeter, ownership structure, managed entities, employee participation, and banking arrangements satisfy the new requirements. That makes 15 June 2027 a transition deadline, not just a filing deadline.

There Is Now an Annual MAS Filing Too

The regulatory relationship does not end after the initial notification. An SFO relying on the exemption must lodge an annual return with MAS within four months after the end of each financial year. The SFO must also have an employee ordinarily resident in Singapore who acts as its point of contact with MAS for matters relating to the exemption.

In other words, this is not a qualify once and forget about it exemption. The family office needs to continue meeting the exemption conditions and have a process for its ongoing regulatory obligations.

What Should Existing Family Offices Check Now

For an SFO already operating in Singapore, there are a few areas worth reviewing before making the transition.

• Who is currently within the family structure, and does each relevant person fall within the regulatory definition of the single family?
• Which trusts, foundations, companies, and investment vehicles are managed by the SFO, and do they fall within the permitted categories?
• Is any money originating from key employees within the 10% AUM limit?
• Is any ownership held by non family key employees within the 10% shareholding limit?
• Do the SFO and relevant investment vehicles have the required banking arrangements?
• Is there an employee ordinarily resident in Singapore who can act as the MAS point of contact?
• Is the information required for the MAS notification available and properly documented?
• Is there a process for the annual return and ongoing monitoring of the exemption conditions?

For simple family structures, much of this may be straightforward. For multigenerational families with trusts, foundations, employee participation, or investment vehicles spread across jurisdictions, the transition may require considerably more mapping.

One Important Distinction, This Is Not the 13O or 13U Framework

This is probably the easiest point to confuse. The SFO licensing exemption and Singapore’s fund tax incentives are separate frameworks. The class exemption under the Securities and Futures regulations determines whether the SFO can conduct fund management without holding a Capital Markets Services licence. Sections 13O and 13U deal with tax incentives for qualifying fund structures and come with their own requirements.

What This Means in Practice

The new framework does not mean Singapore is suddenly requiring every family office to obtain a fund management licence. Qualifying SFOs can still operate without a Capital Markets Services licence. What has changed is the framework around that exemption. The boundaries are now more expressly defined, there is a notification requirement, banking arrangements form part of the conditions, and annual reporting creates an ongoing compliance obligation.

For families setting up a new SFO, these requirements should be considered while designing the structure rather than after everything has already been put in place. For existing SFOs, the immediate priority is different. 15 June 2027 is the key date. There is still time to transition, but the useful question is not simply when the filing is due.

Does our existing family office actually fit the new exemption. That is the question worth answering before the transition takes place.

This article is for general informational purposes only and does not constitute legal, regulatory, tax, or investment advice. Whether an SFO qualifies for the class exemption depends on its particular circumstances and the applicable requirements under the Securities and Futures Act 2001 and the Securities and Futures (Licensing and Conduct of Business) Regulations. Family offices should refer to the applicable legislation and MAS requirements and obtain appropriate professional advice before relying on the exemption.