Setting Up a Singapore Family Office: Conditions, 13O/13U/13D and the 2026 Framework

Start by separating the two regimes

Information about Singapore family offices is confusing largely because two independent regimes are routinely described as one. Separate them and the picture resolves.

Regime one: licensing exemption (Securities and Futures Act) The question it answers is whether the family office needs a Capital Markets Services licence to manage the family's assets. From 15 June 2026, a single family office meeting four conditions qualifies automatically for a class exemption — no case-by-case application, just notification to MAS. This regime carries no minimum AUM.

Regime two: tax incentives (Income Tax Act) The question it answers is whether the fund's income on designated investments is exempt. These are 13O, 13U and 13D. 13O and 13U still require a case-by-case application to and approval from MAS, with minimum asset, headcount and spending conditions.

In one line: the new framework made setting up simpler; it did not make tax exemption simpler.

The 15 June 2026 framework: four conditions

• Incorporation — the family office entity must be incorporated in Singapore;
• Who is served — only members of the same family (including family trusts and wholly-owned family corporations), family-funded charitable vehicles, and key employees (whose assets are capped at 10% of total AUM);
• Funding — exclusively from members of the same family; key employees may hold a non-controlling stake of up to 10%;
• Banking — accounts with MAS-licensed banks; offshore fund vehicles may use regulated banks in FATF-compliant jurisdictions.

Continuing obligations: notify MAS within 14 days of commencing business; file an annual return within 4 months after financial year-end; and appoint a Singapore-resident designated contact directly employed by the family office. Existing offices have a one-year transition and must file by 15 June 2027.

13O, 13U or 13D

The usual logic: below threshold or already holding an offshore structure → 13D as an interim step; S$20–50 million with the fund to sit in Singapore → 13O; above S$50 million with a need for domicile flexibility → 13U.

Full condition-by-condition comparison: 13O vs 13U.

Why Singapore

Tax certainty, more than low rates:

• Corporate income tax of 17%, unchanged since 2010;
• No capital gains tax;
• qualifying new companies receive the Start-Up Tax Exemption for their first three Years of Assessment — 75% of the first S$100,000 of chargeable income and 50% of the next S$100,000 exempt;
• a common-law system, political and currency stability, and dedicated family office incentive schemes.

(Rates per the Inland Revenue Authority of Singapore, current at September 2026.)

The sequence of a typical project

A family office is a multi-track project, not a company registration. A workable order:

1. Feasibility and structuring — fund domicile, which section applies (13D/13O/13U), how family members and assets relate, and the budget basis for local spending and local investment;
2. Entity setup — family office company and fund vehicle, corporate secretarial, registered address;
3. Screening — engage a MAS-prescribed provider (EY, KPMG, PwC, BDO Advisory, Avvanz, Handshakes by DC Frontiers). Screening runs about two weeks; assembling the inputs usually takes longer;
4. Investment professional recruitment — normally the least compressible step, and at least one must be a non-family member;
5. Bank account opening — timing tracks the completeness of source-of-wealth documentation;
6. File the 13O/13U application — MAS indicated in 2025 a target of processing within three months, subject to completeness and due diligence;
7. Licensing notification — within 14 days of commencing business;
8. Ongoing compliance — annual return, maintaining minimum AUM, meeting local spending and local investment.

The three most common pinch points

Treating the asset threshold as a one-time test. Both 13O and 13U require the minimum to be maintained for the entire life of the fund. Families whose AUM sits near a threshold should weigh this when choosing a section.

Underestimating how local spending scales. 13U's spending requirement steps with AUM. A budget built on AUM at application may fall short two years later.

Leaving investment professionals to the end. Recruitment is slow and the roles must be substantive — reasonable pay, real responsibilities, working in Singapore. Starting shortly before filing tends to set the whole timeline.

How residency fits

Family office planning is often considered alongside Singapore residency. The Employment Pass and the Global Investor Programme are different routes with very different thresholds — see Singapore residency: EP vs GIP.

Worth stating plainly: a family office does not by itself confer residency. The two are separate regimes and each must be satisfied on its own terms.

Where CM1 fits

CM1 GROUP is headquartered in Singapore and acts as the coordinating and execution party on family office projects: structuring and feasibility modelling, entity incorporation and corporate secretarial work, document preparation, engaging the screening provider, coordinating investment professional recruitment and bank account opening, and managing the process with MAS and the professional parties involved. Approval rests with MAS. 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 — so that every professional opinion is signed and owned by a licensed practitioner in the relevant jurisdiction.