What you need to know about MAS’s new notification framework for single-family offices

The MAS has issued guidance clarifying the licensing exemption framework for Single Family Offices (SFOs), alongside the introduction of a formal notification and reporting regime, effective 15 June 2026.
 

What has changed?

Under the previous framework, SFOs could operate without a capital markets services licence for fund management, provided they met specific conditions. The MAS has now set out clear criteria that must be met by SFOs in Singapore, and SFOs are required to formally notify MAS of their operations.  The criteria are summarised below: 

1. The SFO can only conduct fund management activities for family members within five generations (including family trusts and corporations wholly owned by and for the sole benefit of the family), charitable organisations funded exclusively by the family, and key employees (up to 10% of total AUM),

2. the SFO must be incorporated in Singapore, and

3. the SFO and any fund vehicles must each open and maintain a bank account with a MAS-licensed bank (funds domiciled overseas can instead open and maintain an account with a regulated bank in a FATF-compliant jurisdiction).

New SFOs must file a Notice of Commencement of Business within 14 days of starting operations, whilst existing SFOs have been given a one-year transitional period (to 15 June 2027) to comply with the above criteria and to submit their notification.

What this means for SFOs

These developments signal MAS’s intent to formalise and oversee the SFO sector, strengthening regulatory visibility and accountability whilst preserving the licensing exemption. More broadly, the framework reflects MAS’s focus on AML/CFT risk management, with increased reliance on regulated financial institutions, particularly banks, to conduct ongoing due diligence. It also marks a shift towards a more standardised regime, with less reliance on case-by-case exemptions, and at the same time retaining flexibility through a structure-agnostic approach.

Practical next steps  

From a practical perspective, SFOs should review their structures, documentation, and processes to ensure alignment with the updated framework.

Key areas to consider include:

• Eligibility: Review whether your SFO structure meets the exemption conditions

• Notification requirement: The need to submit a notification to MAS within the applicable timelines

• Documentation: Ensure appropriate records and declarations are in place to support compliance

• Ongoing obligations: Put processes in place to meet annual reporting requirements, noting that extensions are generally not granted

• Governance and controls: Assess whether existing policies and procedures remain fit for purpose

• Banking arrangements: Check that your SFO’s banking setup aligns with regulatory expectations

While the licensing exemption remains intact, these changes introduce a higher level of compliance discipline for SFOs in Singapore. Early preparation will be important, particularly for existing SFOs working towards the June 2027 deadline.

How Ocorian can help

As a compliance service provider, we can support SFOs in navigating these requirements in a practical and structured manner:

• Eligibility and structuring review: Assess whether your SFO meets the exemption conditions and identify any gaps
• Gap analysis and remediation: Recommend and implement necessary changes to achieve compliance
• Regulatory filings: Assist with preparation and submission of the notification and annual returns
• Documentation support:  Draft and enhance compliance manuals, governance frameworks and supporting records
• Ongoing compliance support: Provide continued advisory to ensure alignment with MAS expectations

If you are an SFO reviewing your structures or preparing to meet the new notification requirements, get in touch with our team to discuss how we can support you.

About the author 

Billie Jo Dixon is the practice lead for Ocorian’s regulatory & compliance team in Singapore. She has over twenty years’ experience in financial services and is a respected expert in regulatory compliance. She helps firms decide if they need to be licensed in Singapore and guides them through the MAS licensing process and all aspects of being a licenced business.