MAS licensing for a Singapore family office: when an exemption applies

Does a Singapore family office need MAS licensing?

Fund management for third-party customers falls under licensing in the Securities and Futures Act, and MAS describes licensed fund managers as firms that generally manage money for third-party customers. A single family office manages the money of one family, so MAS states that it is not its intention to license these offices (MAS FAQ, 2026).

The exemption is a rule written for the whole category. The revised framework took effect on 15 June 2026, and MAS calls it a straight through class exemption from licensing for qualifying offices (MAS media release, 2026). In practice the office notifies MAS and files returns, and the licence application drops out.

Which conditions must a family office meet to use the exemption?

The office conducts fund management only for family members, including family trusts and corporations wholly owned by and for the sole benefit of the family, for charities funded exclusively by the family, and for key employees. Key employees are executive directors, the chief executive, the chief financial officer and investment professionals. Each category has a clear owner, so the family can check every client of the office against the list.

Assets that come from key employees stay at or below 10% of the total assets under management. The office is incorporated in Singapore, and the office and its fund vehicles each keep a bank account with a MAS-licensed bank, with a variation for foreign fund vehicles (MAS FAQ, 2026).

Who counts as a family member for a Singapore family office?

The term covers all lineal descendants of a common ancestor, living or deceased. It includes current or former spouses, adopted children, stepchildren, parents-in-law and siblings-in-law. This broad wording lets one office serve a branch of cousins and in-laws as well as parents and children. A family with several branches can therefore list each branch before it decides which entities the office will serve.

The common ancestor sits no more than 5 generations above the youngest generation that established the office in Singapore. All family members within those 5 generations can be served, and later generations can be served after that. A family can map its tree against this rule before it signs the notification.

Can a family office sit inside a trust or foundation and still qualify?

Yes. The office can be held via a trust, a foundation or any other legal structure, so long as the funding originates exclusively from members of the same family, directly or indirectly, and from key employees. Key employees may own a non-controlling stake of up to 10%.

MAS designed the framework to be structure agnostic, so that it caters to a wide range of ownership and investment structures (MAS FAQ, 2026). The licensing question therefore follows the funding source and the clients served, and the family keeps its freedom to choose the vehicle that matches its goals on control and succession.

How does a family office notify MAS under the exemption?

A new office files a Notice of Commencement of Business with MAS within 14 days of starting operations in Singapore. In the notice, the office confirms that it can comply with the conditions. A copy of a declaration signed by a family member who provided the assets, and by a director of the office, accompanies the notice.

A service provider may submit the notice and the annual returns through its Corppass account, while the declaration remains the signature of the family and the director. MAS accepts a notice without a legal opinion and without the name of a legal adviser. Existing offices have a transition of one year, until 15 June 2027, to comply and file.

What annual return does a Singapore family office file with MAS?

Qualifying offices file an annual return that states their total assets under management and the name of their bank (MAS media release, 2026). The first return is due within 4 months from the end of the office’s current financial year, for that financial year.

MAS gives no further extension beyond the 4 months. A family can therefore choose its financial year end with the filing calendar in view, and keep the asset records that support the figure. The return becomes a fixed date in the office calendar, next to its other yearly filings. Accurate figures at the end of each year also give the family a clean record to review with its advisers.

What happens when a family office falls outside the exemption?

MAS states that it grants case-by-case exemptions only for exceptional reasons. An office that manages the assets of unrelated families, or takes outside investors beyond the key employee allowance, sits outside the listed conditions, and its adviser can review whether a capital markets services licence is the route.

The EQOS Asia method helps a family weigh such a choice before it signs. A pre-diagnostic scores the decision and ranks the options, such as a single family office, a joint arrangement or an outsourced service (EQOS Asia private page, 2026). The licensing check itself stays with your lawyers.

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About the author

Stéphane Jambu

President, EQOS Forecast Asia

Stéphane Jambu leads EQOS Forecast Asia and works as a consultant in e-commerce, search visibility, and AI. LinkedIn profile