One family, one framework: Monetary Authority of Singapore's new structure-agnostic SFA licensing exemption regime for SFOs

Singapore has established itself as one of the leading jurisdictions for single family offices ("SFOs"), supported by a regulatory framework that has historically accommodated a wide range of family wealth structures. Against the backdrop of continued growth in the family office sector, the Monetary Authority of Singapore ("MAS") has announced significant changes to the regulatory framework governing SFOs in Singapore. These changes will be relevant not only to newly established SFOs, but also to existing family office structures currently relying on existing licensing exemptions.

On 12 June 2026, the MAS announced a new structure-agnostic framework for exempting SFOs from the requirement to hold a capital markets services licence for fund management under the Securities and Futures Act 2001 (the "New SFO Exemption Framework").

The New SFO Exemption Framework takes effect on 15 June 2026. Existing SFOs currently operating in Singapore in reliance on either:

1. the related corporation exemption; or
2. an ad hoc case-by-case exemption granted by the MAS,

will benefit from a one-year transition period.

The introduction of the New SFO Exemption Framework represents a significant update in Singapore's regulatory approach to SFOs, replacing the previous reliance on a corporate group-based exemption coupled with case-by-case further reliefs with a dedicated notification-based licensing exemption framework tailored to a broad range of single family office arrangements.

This update provides a high-level overview of the New SFO Exemption Framework. Our team would be pleased to discuss your particular circumstances and advise on the implications of the new framework for your SFO structure.

I. Impact on the related corporation exemption

Under the New SFO Exemption Framework, an SFO will no longer be able to rely on the related corporation exemption where more than 50% of the assets under its management originate from a single family. Such SFOs will instead be expected to rely on, and satisfy the requirements of, the New SFO Exemption Framework.

II. The New SFO Exemption Framework

The new framework applies to SFOs which satisfy the following requirements:

1. a business commencement requirement (described below);
2. a shareholding requirement for the SFO (described below);
3. the SFO manage funds for or on behalf of:
1. family member(s) of a single family ("Family Member(s)");
2. key employee(s) (i.e. the CEO, CFO, executive directors and investment professionals) of the SFO, provided that no more than 10% of the SFO's assets under management originate from the key employee(s); and/or
3. eligible entities.

A person qualifies as a "Family Member" if he or she shares a common ancestor with the founding member(s) (as defined below), where that common ancestor is five generations removed from the generation (or, where there is more than one founding member, the youngest generation) to which the founding member(s) belong.

The definition of Family Member is extended to include the spouses and former spouses, parents-in-law and former parents-in-law, and siblings-in-law and former siblings-in-law of Family Member(s), as well as the spouse or former spouse of the common ancestor.

Importantly, once a person qualifies as a Family Member by reference to the common ancestor, his or her descendants will continue to qualify as Family Members without any generational limit. Accordingly, family members who are six or more generations removed from the common ancestor may still fall within the definition.

An "eligible entity" includes a body corporate, body unincorporate (including a corporation, partnership, limited liability partnership, charitable organisation or foundation) or trust incorporated or otherwise formed inside or outside Singapore, where:

1. all the assets originate from Family Member(s) or key employee(s) of the SFO;
2. the person(s) who benefit from the management of the eligible entity's assets consist of:
1. Family Member(s);
2. key employee(s) of the SFO;
3. charitable organization(s); or
4. eligible entities.

III. The business commencement requirement

At the commencement of business of the SFO under the New SFO Exemption Framework, it must manage funds for or on behalf of:

1. one or more Family Member(s) (founding members); or
2. an eligible entity whose assets originate from one or more Family Member(s) (also founding members).

IV. The shareholding requirement for the SFO

The SFO's shares may be:

1. directly held by:
1. Family Member(s);
2. key employee(s) of the SFO (where the total direct and indirect shareholding of the key employee(s) who are not also Family Member(s) does not exceed 10%);
3. a trustee where the settlor(s) are Family Member(s) and the beneficiar(ies) are Family Member(s) or charitable organisation(s);
4. a foundation where the assets originate from Family Member(s) and where the assets are managed for the benefit of Family Member(s) or charitable organisation(s); or
5. an entity the shares of which are held by one or more of the person(s) mentioned in sub-paragraph (1.1) to (1.4) above.
2. indirectly held by an entity mentioned in sub-paragraph (1)(1.5) above.

V. Requirements to open and maintain bank account

The SFO and any Singapore-incorporated investment vehicle which the SFO manages must open and maintain a bank account with a Singapore licensed bank. Where the investment vehicle is incorporated or formed outside Singapore, the bank account may be opened and maintained with either a Singapore licensed bank or a foreign bank that is supervised for money laundering and terrorism financing consistent with FATF standards.

The bank accounts must be opened before the SFO commences business.

VI. Definition of charitable organisations for the purposes of the New SFO Exemption Framework

For the purposes of the New SFO Exemption Framework, "charitable organisations" include charities as defined in the Charities Act 1994 (i.e. Singapore charities) and also any "group of persons which conducts its activities under a common name", where the group:

1. is formed outside Singapore for purposes that are exclusively charitable under the law of the place of formation, and which is subject to control by a court of that place with equivalent jurisdiction to that of the General Division of the High Court in Singapore with respect to charities; or
2. is established by or as an international organisation or supranational agency for charitable, benevolent or philanthropic purposes.

If your SFO structure involves non-Singapore-registered charities, our team would be pleased to advise on how the above definition may apply to the facts of your situation.

VII. Who are the person(s) from whom assets originate?

The relevant legislation for the New SFO Exemption Framework provides that assets "originate" from an individual if, according to any register of members, trust deed or other records of the relevant entity, those assets are attributable to that individual.

As a matter of drafting, this legislative definition is not without ambiguity and uncertainties, and may give rise to interpretative questions in certain circumstances. Nevertheless, the MAS’s underlying broad policy intention would appear tolerably clear: namely, to identify the individual or individuals who are the effective ultimate contributors or transferors of the capital or assets managed by the SFO.

There may be situations where, in practice, SFOs will need to exercise a degree of judgment in determining the asset originator(s), particularly where assets have been transferred through multiple entities, trusts or other holding structures. Our team would be pleased to advise on the application of this concept to your specific circumstances and to assist in identifying, or forming a view as to, the appropriate asset originator(s) under the New SFO Exemption Framework.

VIII. Notice of Commencement of Business, Annual Return and Designated Contact Person

An SFO operating under the New SFO Exemption Framework must file a notice of commencement of business ("Commencement Notice") within 14 days of its commencing business and an annual return within 4 months of the end of its financial year. 

These forms are simple, but include information about the total AUM managed by the SFO and a listing of the MAS-licensed bank accounts opened and maintained by the SFO and the investment vehicle(s) which it manages.

Samples of the forms can be accessed from MAS' Frequently Asked Questions on Licensing Exemption Framework for Single Family Offices ("New FAQs") here.

IX. Transitional arrangements

Existing SFOs in Singapore operating under the related corporation exemption or the case-by-case licensing exemption have until 15 June 2027 to file the Commencement Notice. Once the Commencement Notice is filed, the previous exemption ceases to apply.

X. Will case-by-case licensing exemptions remain available for intending applicants or existing SFOs that do not satisfy the requirements of the New SFO Exemption Framework?

In its previous November 2024 response to public consultation, the MAS indicated that it would cease granting licensing exemptions on a case-by-case basis. The New FAQs adopt a slightly less categorical position, stating that the MAS would generally no longer grant such exemptions, while preserving the possibility of doing so where there are "exceptional reasons".

While it remains to be seen how the MAS will exercise this residual discretion in practice, the threshold for obtaining an exemption is likely to remain quite high. Existing SFOs that currently rely on a case-by-case exemption and may face challenges in satisfying the requirements of the New SFO Exemption Framework should consider engaging with the MAS at an early stage to discuss their position. Our team would be pleased to assist in assessing available options and facilitating such engagement.

XI. No longer any mandatory legal opinion requirement

In its earlier consultation response, the MAS had indicated that applicants seeking to rely on the New SFO Exemption Framework would be required to obtain a legal opinion. This requirement has not been carried through into the final framework, which would be welcomed by SFOs. 

Preparing for the New SFO Exemption Framework

The New SFO Exemption Framework represents a significant shift towards a dedicated and more transparent licensing exemption regime for single family offices in Singapore. While many SFOs are expected to fall within the new framework, the detailed requirements relating to family relationships, asset originators, ownership structures, banking arrangements and ongoing filing obligations may require careful consideration in practice, particularly for more complex family office arrangements.

If you would like to discuss how the New SFO Exemption Framework may apply to your family office structure, or require assistance with assessing eligibility, transition planning, regulatory filings or engagement with the MAS, please feel free to approach Stacy Choong, Yeoh Lian Chuan, Leon Kwong Wing, Hon Yong Sheng or your usual contact at Withers. We would be pleased to assist.