Revised Licensing Exemption Framework for Single Family Offices Commences from 15 June 2026

The Monetary Authority of Singapore (“MAS“) announced that the revised licensing exemption framework for Single Family Offices (“SFOs“) has taken effect from 15 June 2026. Existing SFOs operating in Singapore will have a transitional period of one year until 15 June 2027 to comply with the revised framework.

Existing SFOs that are currently operating under case-by-case exemptions or existing class exemptions will need to assess whether they meet the conditions of the new licensing exemption framework and, if so, file a notification with MAS before the end of the transitional period on 15 June 2027. SFOs that do not meet the conditions of the new framework will need to consider whether to apply for a capital markets services licence (“CMS Licence“) for fund management or restructure their operations to qualify under the revised framework.

By way of background, MAS had launched a public consultation in July 2023 on a revised framework to manage money laundering and terrorism financing risks in Singapore’s SFO sector. Prior to the present regime, if SFOs wished to be exempt from licensing requirements under the Securities and Futures Act 2001 (“SFA“), they would have to rely on an existing class exemption or, depending on the structure, apply to MAS under the case-by-case exemption approach. MAS therefore sought to introduce a harmonised class exemption from licensing under the SFA that would replace the need for case-by-case exemptions to operate as an SFO. In November 2024, the regulator issued its response to the feedback received.

The revised framework now streamlines the process for SFOs to establish operations in Singapore while strengthening MAS’ overall monitoring of SFOs under a unified regulatory regime. The framework is structure-agnostic, thereby facilitating a single harmonised class exemption from licensing for all qualifying SFOs operating in Singapore. While the SFO itself must be incorporated in Singapore, the framework can accommodate a range of ownership and holding structures, including structures involving trusts, foundations and other legal vehicles.

To operate in Singapore under the licensing exemption framework, an SFO must:

1. be incorporated in Singapore;
2. only conduct fund management for, or on behalf of:

• • family members, including family trusts and corporations wholly owned by, and for the sole benefit of, the family;
  • charitable organisation(s) funded exclusively by the family; and/or
  • key employees (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.

3. be funded exclusively by:

• • members of the same family, whether directly or indirectly; and
  • key employees, who are allowed to own a non-controlling stake of up to 10%.

4. open and maintain a bank account with a MAS-licensed bank, with this requirement also applicable to any fund vehicles. Foreign-incorporated fund 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 (AML/CFT) requirements consistent with the standards set by the Financial Action Task Force (FATF).

SFOs that meet the above requirements must notify MAS of their operations and file an annual return. New SFOs commencing business on or after 15 June 2026 must submit a notice of commencement within 14 days after commencing business. Existing SFOs operating before 15 June 2026 that intend to continue operating under the revised framework must submit a notice of continuation by 15 June 2027.

Each exempt SFO must also file an annual return with MAS within four months after the end of its financial year, containing information on the total assets under management and the name of the SFO’s MAS-licensed bank. The SFO must also designate a point of contact directly employed by the SFO and resident in Singapore to liaise with MAS.

Notice on Prohibited Representations

Under Notice SFA 04-N07 Prohibited Representations Made by Exempt Persons Under the 2nd Schedule to the Securities & Futures (Licensing & Conduct of Business) Regulations (“Notice SFA 04-N07“), a person exempt from holding a CMS Licence shall not represent itself as being licensed, regulated, supervised or registered by MAS.

Notice SFA 04-N07 has been updated to similarly prohibit exempt SFOs from making such representations. Exempt SFOs should therefore review their public-facing materials, including websites, pitch decks, email footers and other communications, to ensure that they do not suggest that the SFO is licensed, regulated, supervised or registered by MAS.

Frequently Asked Questions (“FAQs”) on Licensing Exemption for SFOs

MAS has also issued the FAQs on Licensing Exemption Framework for Single Family Offices providing further guidance on the revised framework for SFOs. The FAQs cover key matters, including the following:

1. 1. 1. The definition of a “family member”, which generally applies a five generation limit from a common ancestor and includes spouses, former spouses, adopted children, stepchildren, parents-in-law and siblings-in-law;
      2. How an SFO may obtain a licensing exemption under the SFA, including the notification process and annual return requirements;
      3. Whether an SFO which does not meet the conditions set out under the licensing exemption can apply for a licensing exemption or a CMS Licence for fund management; and
      4. Whether an SFO needs to provide a legal opinion to support its qualification under the licensing exemption framework. MAS has clarified that a legal opinion is not required for the notification, although the SFO remains responsible for assessing and declaring that it satisfies the exemption conditions.

FAQs on Licensing of Fund Management Companies

The FAQs on Licensing of Fund Management Companies have been updated to include the following SFO-related questions:

1. 1. 1. How is an SFO defined for licensing or regulatory purposes? Is an SFO required to be licensed under the SFA and/or the Financial Advisers Act 2001?
      2. Can an SFO which does not meet the conditions under the licensing exemption apply for a case-by-case licensing exemption?

What SFOs Should Do Now

Existing and proposed SFOs should additionally:

1. 1. 1. review their ownership and managed assets against the revised conditions;
      2. confirm that any key employee participation remains within the applicable 10% thresholds;
      3. check the bank account arrangements for the SFO and its fund vehicle(s);
      4. designate a Singapore resident MAS point of contact;
      5. diarise the relevant notification and annual return deadlines; and
      6. update external descriptions to avoid prohibited representations.

Click on the following links for more information:

Available on the MAS website at www.mas.gov.sg:

• MAS Press Release titled “Revised Framework for Single Family Offices to take effect on 15 June 2026”
• FAQs on Licensing Exemption Framework for Single Family Offices
• FAQs on Licensing of Fund Management Companies
• Notice SFA 04-N07 Prohibited Representations Made by Exempt Persons Under the 2nd Schedule to the Securities & Futures (Licensing & Conduct of Business) Regulations

Rajah & Tann Singapore publications:

• November 2024 NewsBytes article titled “Refinements to Proposed Licensing Exemption Framework for Single Family Offices: MAS Responds to Feedback from Public Consultation”
• August 2023 Legal Update titled “MAS Consults on Revised Licensing Exemption Framework, New Notification and Reporting Requirements for Single Family Offices”

Should you have any queries on the revised framework and its implications, please feel free to approach our team set out on this page.

For regional Private Wealth matters, please see Rajah & Tann Asia’s Private Wealth Practice for more information.