MAS revises Singapore licensing exemption framework for single family offices

The Monetary Authority of Singapore (MAS) has introduced a revised licensing exemption framework for single family offices (SFOs), which took effect on 15 June 2026. The revised framework replaces the previous case-by-case exemption approach with a structure-agnostic class exemption for qualifying SFOs operating in Singapore.

All SFOs operating in Singapore should review whether they satisfy the conditions under the revised framework. Those looking to set up SFOs in Singapore must ensure that they satisfy the conditions under the revised framework.

Qualifying SFOs no longer need to rely on a case-by-case licensing exemption. Instead, they may operate under an automatic class exemption, provided the relevant conditions are met and the required notification is filed with the MAS.

A new SFO must file a Notice of Commencement of Business within 14 days of commencing operations in Singapore.

An existing SFO that commenced business before 15 June 2026 has a one-year transitional period, and should file its notice by 15 June 2027 if it intends to continue operating in Singapore.

Thereafter, qualifying SFOs must file an annual return within 4 months after the end of each financial year, disclosing, among other things, the SFO’s total assets under management, the name of its bank and the name of the bank(s) at which its fund vehicle maintains account(s) with.

To rely on the revised licensing exemption framework, an SFO must satisfy conditions including the following:

The revised framework is intended to be structure-agnostic. MAS has clarified that an SFO may be held through a trust, foundation or other structure, provided the funding originates exclusively from the family (subject to the permitted participation by key employees).

“Family member” is defined broadly, but is subject to a five-generation limit at the point the SFO commenced business in Singapore.

The framework also allows SFOs to serve certain key employees (including executive directors, the CEO, CFO and investment professionals), but assets originating from key employees must not exceed 10% of the SFO’s total assets under management in aggregate, and key employees may hold only a non-controlling stake of up to 10% in the SFO.

A service provider may submit the notification and annual returns on behalf of an SFO using the service provider’s Corppass account. However, the notification must be accompanied by a declaration signed by the relevant family member(s) and director(s) of the SFO. Electronic signatures are accepted.

Those looking to set up new SFOs should be aware of the requirements and notification process under the revised framework, and make preparations accordingly.

Existing SFOs should start their review early. In our experience, the main workstreams are usually not the filing itself, but confirming that the SFO’s ownership, managed asset base, banking arrangements and supporting declaration align with the revised framework before the notice is lodged. The filing for existing SFOs must be completed by 15 June 2027, and MAS has indicated that the annual return filing timeline will be 4 months after each financial year-end, with no further extension for annual returns.

We are currently assisting a number of SFOs in relation to the revised framework, including:

If you would like to discuss how the revised framework applies to your SFO, or require assistance with the notification process, please feel free to get in touch with our team.

Email me

edmund.leow@dentons.com

Email me

lingyi.quek@dentons.com

© 2026 Dentons Rodyk & Davidson LLP, a limited liability partnership registered in Singapore with Registration No. T07LL0439G. Attorney advertising.

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MAS revises Singapore licensing exemption framework for single family offices

it must be incorporated in Singapore;

the SFO and its fund vehicles must maintain the required banking relationships — including, for Singapore-incorporated fund vehicles, accounts with MAS-licensed banks; foreign-incorporated fund vehicles may use a MAS-licensed bank in Singapore or a regulated bank in a jurisdiction with AML/CFT standards consistent with the FATF standards; and

it can only manage assets for family members, related family structures, charitable organisations funded exclusively by the family, and certain key employees of the SFO (subject to applicable limits).

reviewing whether an SFO meets the qualifying criteria;

identifying any structural or documentation gaps;

preparing and reviewing the required declaration and supporting information; and

assisting with the filing of the Notice of Commencement of Business or Notice of Continuation of Business.

Edmund Leow, SC Edmund Leow, SC Senior Partner, SingaporeSingaporeD +65 6885 3613 Email me edmund.leow@dentons.com

Ling Yi Quek Ling Yi Quek Partner, YangonYangonD +951 860 1018 (Ext. 118)M +959 407 387 892SingaporeSingaporeD +65 6885 3766M +65 9017 1923 Email me lingyi.quek@dentons.com

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