SINGAPORE’S NEW SFO REGIME: A GAME CHANGER?
Summary: This blog outlines key changes introduced in Singapore through a revised framework governing Single Family Offices (SFOs). We examine the impact of the newly introduced changes on existing and future SFOs in Singapore.
INTRODUCTION
The provision of capital markets services, fund management, and corporate finance advisory in Singapore typically requires procuring a license from the Monetary Authority of Singapore (“MAS”). The Securities and Futures Act 2001 of Singapore and the Securities and Futures (Licensing and Conduct of Business) Regulations (collectively, “Licensing Regulations”) stipulate these requirements and/or exemptions available to various entities for the licensing of fund management activities. Until recently, the Single Family Offices (“SFOs”) established in Singapore availed one such exemption.
On June 12, 2026, the MAS introduced its new licensing exemption requirements[1] for SFOs, effective June 15, 2026 (“Effective Date”). This revision ensures a simpler, more streamlined process for establishing SFOs while also strengthening regulatory oversight of their operations.
THE EDITS
Under the Licensing Regulations, certain fund management entities qualify for licensing exemptions. Previously, a Singapore SFO could avail such an exemption only where it held or managed a family’s assets through a “related corporation” structure. SFOs with other ownership structures, or those using non-corporate entities for holding or managing a family’s assets, typically sought a case-by-case licensing exemption from the MAS.[2]
The revised regime will recognise qualifying SFOs as a distinct category of fund management entities who can avail licensing exemptions. The qualifying criteria are as follows:
- The SFO must conduct fund management for or on behalf of family members, certain eligible entities (including charitable organisations funded exclusively by the family) and/or key employees;[3]
- The SFO could be held by any legal structure as long as the funding originates exclusively from members of the same family and key employees (holding a non-controlling stake of less than 10 per cent);
- The SFO must be incorporated as a company in Singapore; and
- The SFO and its investment vehicle(s) must open and maintain a bank account with a MAS-licensed bank.[4]
An entity that meets these qualifying criteria is required to submit one of the following notifications, as applicable, to the MAS (“Notification”):
- where business in fund management commences post the Effective Date, a notice of commencement of business within 14 days after commencement of the business; and
- where the entity was exempt immediately before the Effective Date, a notice of continuation of business within one year from the Effective Date.
Significantly, this new regime is structure-agnostic, in that as long as the SFO meets these specified conditions, it will not be excluded from exemption merely by virtue of being held by a non-corporate entity. As a result, unless there are exceptional reasons, the MAS may not grant case-by-case exemptions to SFOs going forward.[5] Importantly, SFOs must ensure they satisfy all eligibility preconditions for exemption before submitting the Notification to the MAS. However, the process does not require seeking or furnishing a legal opinion, or naming legal advisers as part of the Notification for confirming their eligibility for the exemption. Therefore, this new Notification-based exemption approach saves time and compliance costs by eliminating the need to apply for a case-by-case exemption or procuring a legal opinion for an exemption.
NEW WINE IN A NEW BOTTLE?
The revised SFO regime marks a significant shift from the old one, which limited exemptions to only those SFOs held through corporate entities. However, this structure-agnostic approach indicates regulatory acknowledgment for SFOs held by natural persons, trusts, partnerships, and other non-corporate entities. This will enhance ease of operation for SFOs. Previously, exemptions SFOs were granted licensing exemptions on a case-by-case basis, resulting in a lengthier administrative process. Moreover, the exemption provided to related corporations only applied where 50 per cent or less of the assets under management in the related corporation originated from a single family. However, the new regime has a clearer approach, where the assets under management need to be held exclusively for the family and/or key employees and/or eligible entities. This ensures that the structure availing the licensing exemption solely benefits a single family.
Accordingly, global families considering establishment of their SFOs in Singapore may benefit from the new regime. Overall, this is a timely relaxation from the MAS, more so amid ongoing global uncertainty.
[1] www.mas.gov.sg/news/media-releases/2026/revised-framework-for-single-family-offices-to-take-effect-on-15-june-2026.
[2] A common example is where the SFO and the investment vehicle are both owned directly by one or more natural persons rather than through a corporate entity or common holding company. In such a structure, the SFO is not considered a “related corporation” (as defined under the Singapore Companies Act, 1967) of the investment vehicle.
[3] Key employees include Executive Directors, Chief Executive Officer, Chief Financial Officer and investment professionals. Assets originating from key employees must not exceed 10% of the total value of the SFO’s assets under management in aggregate.
[4] Foreign-incorporated investment vehicle(s) may open and maintain an account with a MAS-licensed bank in Singapore, or with a regulated bank in a jurisdiction that complies with anti-money laundering and countering of financing of terrorism requirements consistent with the standards set by the Financial Action Task Force.
[5] Question 5, faqs-on-licensing-exemption-framework-for-single-family-offices.pdf.