One Family, One Framework: Monetary Authority Of Singapore's New Structure-agnostic SFA Licensing Exemption Regime For SFOs
| Published date | 19 June 2026 |
| Subject Matter | Finance and Banking, Corporate/Commercial Law, Wealth Management, Financial Services, Compliance, Wealth & Asset Management |
| Law Firm | Withers LLP |
| Author | Ms Stacy Choong, Lian Chuan Yeoh, Leon Kwong Wing and Yong Sheng Hon |
Singapore has established itself as one of the leading jurisdictions for single family offices ("SFOs"), supported by a regulatory framework that has historically accommodated a wide range of family wealth structures. Against the backdrop of continued growth in the family office sector, the Monetary Authority of Singapore ("MAS") has announced significant changes to the regulatory framework governing SFOs in Singapore. These changes will be relevant not only to newly established SFOs, but also to existing family office structures currently relying on existing licensing exemptions.
On 12 June 2026, the MAS announced a new structure-agnostic framework for exempting SFOs from the requirement to hold a capital markets services licence for fund management under the Securities and Futures Act 2001 (the "New SFO Exemption Framework").
The New SFO Exemption Framework takes effect on 15 June 2026. Existing SFOs currently operating in Singapore in reliance on either:
- the related corporation exemption; or
- an ad hoc case-by-case exemption granted by the MAS,
will benefit from a one-year transition period.
The introduction of the New SFO Exemption Framework represents a significant update in Singapore's regulatory approach to SFOs, replacing the previous reliance on a corporate group-based exemption coupled with case-by-case further reliefs with a dedicated notification-based licensing exemption framework tailored to a broad range of single family office arrangements.
This update provides a high-level overview of the New SFO Exemption Framework. Our team would be pleased to discuss your particular circumstances and advise on the implications of the new framework for your SFO structure.
I. Impact on the related corporation exemption
Under the New SFO Exemption Framework, an SFO will no longer be able to rely on the related corporation exemption where more than 50% of the assets under its management originate from a single family. Such SFOs will instead be expected to rely on, and satisfy the requirements of, the New SFO Exemption Framework.
II. The New SFO Exemption Framework
The new framework applies to SFOs which satisfy the following requirements:
- a business commencement requirement (described below);
- a shareholding requirement for the SFO (described below);
- the SFO manage funds for or on behalf of:
3.1 family member(s) of a single family ("Family Member(s)");
3.2 key employee(s) (i.e. the CEO, CFO, executive directors and investment professionals) of the SFO...
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