Robo-Advisers in Singapore: Which MAS Licence Applies?

Section 13O can require S$5 million in assets under management in designated investments (AUM in DI) for a non-single-family-office fund, but S$20 million for a new single family office (SFO) award. The applicable threshold depends on who manages the fund and when MAS approved the award. Section 13U generally starts at S$50 million.

These tax incentives also carry conditions on staffing, local spending and qualifying investments. MAS Circular FDD Cir 05/2026, issued on 31 July 2026, changed several of those conditions. Some apply from 1 August 2026; others apply retrospectively from 1 January 2025. This guide separates the non-SFO and SFO rules so fund managers can identify the tests relevant to their awards.

Section 13O vs 13U: Key Differences

Section 13O applies to an approved Singapore-incorporated and tax-resident company. Section 13OA covers an approved Singapore limited partnership. Section 13U permits a wider range of approved structures, including master-feeder arrangements. The Income Tax Act 1947 establishes the schemes. MAS approval and the applicable award conditions determine the income, investment and management tests for a particular fund.

About the S$5 million figure: For relevant non-SFO 13O/13OA awards, the fund may have until the end of the basis period for the third year of assessment (YA) to meet the entry condition. This grace period does not apply to the closed-end fund election. The SFO figures in the table concern new awards approved from 1 August 2026. Check the conditions of earlier awards separately.

Section 13D covers qualifying offshore funds managed in Singapore. It has no equivalent minimum AUM or local business spending requirement, but other eligibility and investor rules apply. From YA 2028, the Singapore manager must employ at least one qualifying investment professional.

2026 Changes for Non-SFO Funds

For non-SFO funds managed by a Singapore fund management company, the 2026 circular changes the annual AUM test and clarifies the third-party capital requirement. The local spending condition remains. Check the circular and the fund’s MAS award letter for the conditions that apply to its award.

The Annual Minimum AUM Test Was Removed

From 1 January 2025, non-SFO funds no longer have to maintain the S$5 million minimum for 13O/13OA or the S$50 million minimum for 13U at every financial year-end. The relevant minimum remains an entry condition, subject to the 13O/13OA grace period. Year-end AUM in designated investments still determines the local business spending tier.

Third-Party Capital Must Be Evidenced

A non-SFO fund under 13O, 13OA or 13U must have capital from third-party investors or a bona fide intention to raise it. A third-party investor must not be a related party of the fund management company. If the fund relies on an intention to raise capital, retain evidence of genuine fundraising. MAS may revoke the award if that intention cannot later be substantiated.

Local Spending Still Applies Each Year

Annual local business spending (LBS) is based on the fund’s AUM in designated investments at the relevant year-end. Transitional arrangements mean the tiered figures below may start in different YAs for existing awards. Check the award date and applicable conditions before applying them.

2026 Changes for Single Family Office Funds

New SFO awards approved from 1 August 2026 have revised staffing, AUM, spending and banking conditions. Earlier awards do not all move onto the same set of rules. MAS provides general guidance on the fund tax schemes for family offices. For the 2026 changes, review the current circular and the conditions attached to the fund’s MAS approval before changing its annual compliance tests.

• Investment professionals: A new 13O/13OA SFO applicant may apply with one qualifying professional and hire a second by the end of the first YA basis period. A new 13U applicant may apply with two and hire a third by that point. In either case, at least one qualifying professional must be a non-family member.
• AUM in designated investments: For new SFO awards, the applicable minimum is tested at application and at the end of each relevant financial year, rather than continuously: S$20m for 13O/13OA and S$50m for 13U.
• Local business spending: Revised SFO spending tiers depend on AUM in DI at year-end. The treatment of existing awards depends on their award conditions.

Qualifying local spending may include management fees paid to the Singapore manager, remuneration and other eligible Singapore expenses. For the higher SFO tiers, certain donations and blended-finance grants may also count under separate rules. Keep a running schedule and the supporting invoices throughout the year.

Capital deployment: A new SFO fund must invest at least the lower of 10% of its AUM in designated investments or S$10 million in qualifying assets. The revised categories cover designated investments listed on MAS Approved Exchanges; designated investments distributed by MAS-licensed financial institutions in Singapore, subject to an exclusion for equities listed outside Approved Exchanges; and qualifying unlisted Singapore-incorporated operating companies. Some investments receive a 2× weighting. Check when the test first applies under the award.

Banking account: Check the precise condition in the SFO fund’s award letter. Certain existing awards without a stated Singapore banking-account condition had three months from 1 August 2026 to establish a banking account or private banking account with an MAS-licensed financial institution. The requirement is specific to the award.

Changes to Designated Investments

From 1 August 2026, the previous 5% cap on physical investment precious metals as designated investments was removed. A tokenised interest in an existing designated investment may also qualify if it gives the holder the same interests, rights and obligations as direct ownership. The fund and the investment must still meet all applicable conditions.

Annual Compliance Checklist for 13O and 13U Funds

1. Identify whether the fund is SFO or non-SFO, its scheme, award date and applicable letter-of-award conditions. For new funds, document the relevant AUM entry test and any grace period.
2. For SFO awards subject to a continuing AUM minimum, test AUM in DI at the prescribed period-end. For non-SFO awards, use year-end AUM in DI to determine the LBS tier, even though the annual minimum AUM test has been removed.
3. Reconcile local business spending against the applicable tier and transition period, with supporting invoices and eligibility notes.
4. Verify qualifying investment professional headcount and status; document non-family-member status where required for an SFO.
5. For non-SFO funds, evidence third-party investor capital or progress against a genuine fundraising plan.
6. For SFO funds, check capital deployment and banking-account conditions against the award letter. Escalate a breach or near-breach promptly.

The correct annual checks depend on fund type, scheme, award date and the letter of award. Assign an owner to each test, then keep the calculations and supporting documents in the compliance file. Alder’s guide to an annual compliance review explains how to organise a broader review of MAS obligations.

Frequently Asked Questions

This article provides general information and is not legal, tax or regulatory advice. Review the conditions of your own MAS award with qualified advisers before acting.