Setting Up a Fund in Singapore

You need a Capital Markets Services (CMS) licence from MAS for fund management. There are three categories: VCFM (Venture Capital Fund Manager) for pure VC managers, A/I LFMC (Accredited/Institutional Licensed Fund Management Company) for managers serving accredited and institutional investors, and Retail LFMC for managers serving all investor types including retail. The RFMC (Registered Fund Management Company) regime is being phased out - new applicants should not plan around it.

VCFM is faster (4 months vs 6), cheaper (no base capital requirement vs SGD 250,000), and has more flexible experience requirements. But it only authorises venture capital fund management. A/I LFMC covers any strategy - VC, PE, hedge, credit, real estate. If there's any chance you'll run non-VC strategies within 5 years, choose A/I LFMC upfront to avoid a relicensing exercise.

MAS announced in 2024 that the RFMC regime will be repealed. Existing RFMCs must transition to A/I LFMC. The transition takes approximately 1 month if you submit a CMS licence application before the deadline. New fund managers should apply directly for VCFM or A/I LFMC.

VCFM: No minimum base capital. A/I LFMC: SGD 250,000 (must be maintained at all times). Retail LFMC: SGD 500,000 or SGD 1 million if offering CIS products to retail investors. Financial resources must continuously exceed total risk requirements under MAS methodology.

Minimum 2 full-time Singapore-based individuals for each regulated activity (3 for Retail LFMC). For A/I LFMC: directors must have at least 5 years of relevant experience in financial services. For VCFM: MAS is more flexible - sector expertise and entrepreneurial experience count. At least one director must be a full-time Singapore resident.

VCFM: approximately 4 months. A/I LFMC: approximately 6 months. Filing fees: SGD 1,000 (non-refundable). Representative lodgement: SGD 200 each. MAS evaluates fitness and propriety, track record, financial requirements, internal risk management, and compliance systems.

A Variable Capital Company is a corporate structure introduced by Singapore in January 2020, designed specifically for investment funds. It allows fund managers to issue and redeem shares without shareholder approval, operate as an umbrella fund with segregated sub-funds (each sub-fund's assets and liabilities are legally protected from others), and pay dividends from capital - all features that traditional Singapore companies cannot do.

Most Singapore fund managers now use VCC structures. VCCs are strategy-agnostic - used for VC, PE, hedge, family offices, and multi-asset funds. The umbrella structure accelerates adding new sub-funds as your business evolves without incorporating new entities each time. VCC governance expectations are increasing - MAS issued a specific circular on VCC governance in June 2025.

Yes. VCC re-domiciliation allows you to transfer registration of a fund from another jurisdiction (e.g., Cayman Islands, Luxembourg) to Singapore as a VCC. This is a key feature designed to attract offshore funds onshore.

These are MAS-administered schemes that exempt qualifying investment income from Singapore tax (0% rate). 13O (formerly Section 13R) is the base tier for Singapore-incorporated funds. 13U (formerly Section 13X) is the premium tier - the fund can be incorporated anywhere in the world. Both have been extended to 31 December 2029.

SGD 20 million at the time of application. There is no grace period to build up to this threshold.

SGD 50 million at the time of application.

13O: Minimum 2 investment professionals. If only one is hired initially, a one-year grace period is granted for the second. 13U: Minimum 3 investment professionals, and at least one must be a non-family member hired from the open market. IPs must hold relevant qualifications (CFA, CAIA, or finance/economics degree), be based in Singapore, and earn a minimum qualifying salary.

13O requires minimum SGD 200,000 in annual local business spending in Singapore. This includes salaries of Singapore-based employees, office rent, professional fees paid to Singapore firms, and technology subscriptions from Singapore-registered companies. DiligenceWorks is a Singapore Pte. Ltd. (UEN 202622083N) - subscriptions count toward LBS.

Indicative ongoing costs for a Section 13O family office typically run between SGD 300,000 and SGD 700,000 per year. The biggest line items are IP salaries (two IPs at market rates), office rent, audit fees, compliance, and professional services.

Incorporation of management company and fund vehicle (SGD 5,000-15,000), MAS licence application (SGD 1,000 filing fee plus professional fees of SGD 50,000-150,000 for business plan, compliance framework, and regulatory submissions), office setup, and working capital. Total first-year costs typically range from SGD 100,000 to SGD 500,000+ depending on licence type and complexity.

Annual corporate fees (SGD 4,000 fixed + SGD 5 per representative from 101st onward), audit fees, compliance costs, IP salaries, office rent, and technology infrastructure. For 13O/13U family offices, the LBS minimum of SGD 200,000+ sets a floor.

Not always mandatory, but strongly recommended for institutional credibility. Fund administrators handle NAV calculation, investor reporting, KYC/AML, and regulatory reporting. Key Singapore-based fund administrators include ASCENT Fund Services, Apex Group, Citco, and SS&C.

Technology subscriptions from Singapore-registered companies count toward Local Business Spending. This includes deal analysis platforms, compliance software, document management, and operational infrastructure - provided the vendor is a Singapore entity.

DiligenceWorks is a Singapore Pte. Ltd. (UEN 202622083N). Subscriptions count toward 13O/13U Local Business Spending requirements. The platform provides AI-powered deal analysis, document management, and compliance-ready reporting - core operational infrastructure that demonstrates genuine economic substance to MAS.