Singapore's Revised Single Family Office Framework (effective 15 June 2026): Class Exemption, Notification and Transition

What actually changed: licensing, not tax

The starting point is that a Singapore family office sits under two separate regimes. A great deal of published material conflates them, which leads families to misjudge both timeline and cost.

In short: the revision makes setting up and running a single family office faster and more predictable. It does not remove the application process or the thresholds for tax exemption. Reading the change as "the family office threshold has come down" is inaccurate.

The four qualifying conditions

MAS designed the exemption to be structure-agnostic — it no longer prescribes a particular shareholding or entity form, and instead asks whether all four of the following hold:

1. Incorporated in Singapore

The family office entity itself must be a Singapore-incorporated company.

2. Manages assets only for a single family

Permitted beneficiaries are:

• members of the same family, including family trusts and corporations wholly owned by the family;
• charitable vehicles funded by that family;
• key employees of the family office — but employee assets must not exceed 10% of total assets under management.

3. Funded exclusively by the same family

Funding must come exclusively from members of the same family, whether held directly or indirectly. Key employees may hold a non-controlling stake of up to 10%.

4. Banks with MAS-licensed institutions

The family office must maintain accounts with MAS-licensed banks. Offshore fund vehicles may use regulated banks in FATF-compliant jurisdictions.

Notification and ongoing obligations

A class exemption is not a filing that ends the matter. Once it applies, the family office carries continuing duties:

• New SFOs — notify MAS within 14 days of commencing business in Singapore;
• Existing SFOs — file a notice of continuation by 15 June 2027;
• Annual return — within 4 months after financial year-end, disclosing total AUM and the MAS-licensed banks used;
• Designated contact — appoint a Singapore-resident point of contact who is directly employed by the family office.

What existing family offices should do now

The transition runs a year, but the work is rarely the form itself — it is the structural check that precedes it. A workable sequence:

1. Confirm the route. Existing offices may operate under a case-by-case exemption or an older class exemption; establish first whether the four new conditions are met.
2. Test who is served and who funds it. The two most common gaps in practice are the boundary of "the same family" (collateral relatives, corporations that are not wholly owned) and key employee stakes above 10%.
3. Put the designated contact in place. They must be Singapore-resident and directly employed — an outsourced corporate secretary does not satisfy this.
4. Review banking. Confirm principal accounts sit with MAS-licensed banks.
5. File before 15 June 2027, and settle the data basis for the first annual return at the same time.

How this meets a 13O / 13U application

Where a family office is also preparing a tax incentive application, the two tracks should run in parallel rather than in sequence:

• the licensing exemption runs on notification, so its timing is within your control;
• 13O/13U remains a case-by-case application to MAS, and since 1 October 2024 every new application must be accompanied by a screening report from a MAS-prescribed screening service provider;
• MAS indicated in 2025 a target of processing tax incentive applications within three months, subject to completeness and due diligence.

Considering both regimes at the structuring stage avoids rework later — key employee equity arrangements and the timing of investment professional hires bear on both tracks at once.

Where CM1 fits

CM1 GROUP is headquartered in Singapore and acts as the coordinating and execution party on family office projects: structuring, entity incorporation and corporate secretarial work, document preparation, coordination of investment professional recruitment, bank account opening, and liaison with MAS and the professional parties involved. Where a matter calls for jurisdiction-specific tax advice, legal opinions or audit work, we coordinate licensed local accountants, lawyers and auditors to issue it.