If an SFO fund receives a new 13O award late in its financial year, review the investment-professional hiring deadline immediately. Do not assume that the first hiring concession always gives the office a full year after approval.
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For new 13O or 13OA SFO awards approved from 1 August 2026, the MAS circular permits one qualifying investment professional at application, but requires two, including at least one non-family member, by the end of the first award YA’s basis period.
Identify the actual award and first basis period
Retrieve the approval, commencement date, fund financial year-end and any specific written conditions. The approval date, award commencement and first reporting period can be different. Map them before giving recruitment a deadline.
Review the applicable version of the conditions. An older award or separately notified condition should not be assessed automatically under a new-award example.
Example: a short first period
An award begins during a year that ends in December. The office should calculate the relevant first-period deadline from the applicable conditions, not schedule hiring for the following anniversary by default. A short period can require recruitment and documentation well before an anniversary-based plan would suggest.
Review qualification as well as headcount
- The proposed employee and actual investment role.
- Employment by the relevant SFO.
- Required professional experience and qualifications.
- Salary, residence and activity evidence.
- Relevant family relationship.
- Actual employment commencement and supporting documents.
A signed future offer does not prove the person already meets the condition. Check the actual official definitions and award requirements rather than counting every finance employee.
Work backwards from the deadline
Allow time for recruitment, notice periods, contract review and any required work authorisation. Confirm that the candidate can genuinely begin the relevant employment in time. A preferred hire whose start date remains uncertain should not be the only unqualified assumption in the plan.
Assign responsibility for obtaining and checking the evidence. HR may have the employment documents while the tax adviser needs the information supporting incentive qualification.
Escalate a possible shortfall early
If the office may miss the condition, seek advice and official clarification where appropriate. Do not assume a general extension is available or that paying a recruitment agency fee satisfies an employment requirement.
Give the family decision-makers the actual gap and consequences for assessment. Avoid making a declaration based on a plan to hire later or backdating employment to fit the period.
Keep the continuing-condition calendar
After the initial deadline, review the continuing requirements separately. A concession at the start of an award should not be assumed to cover a later departure, secondment or change in duties. Preserve the assessment and tell advisers when staffing facts change.
Is the concession automatically twelve months?
Use the applicable award and basis-period rule. Do not substitute an anniversary for the stated deadline.
Does a job title alone make someone a qualifying professional?
No. Review the role, employment and other applicable criteria.
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For family-office administration, accounting or tax advisory support, email [email protected] or WhatsApp +65 8501 7133. Legal advisers from our associated law firms can assist with structuring, contracts and regulatory advice where needed. Any incentive or regulatory application remains subject to the applicable official requirements and assessment.