The MAS Registered Fund Management Company regime was repealed on 1 August 2024, and every former RFMC has since migrated onto the Licensed Fund Management Company framework. By 2026 there is no active RFMC status left in Singapore, and new managers apply directly for an A/I LFMC licence instead.
Raffles Corporate Services works with a panel of corporate and employment law firms; this article is general information, not legal advice.
What the RFMC sunset involved
Introduced in 2012, the RFMC status let a manager serve up to 30 qualified investors with total assets under management capped at S$250 million without holding a full Capital Markets Services (CMS) licence, registered rather than licensed by the Monetary Authority of Singapore under the Securities and Futures Act 2001. MAS concluded that the business models and risk profiles of RFMCs and Accredited/Institutional Licensed Fund Management Companies (A/I LFMCs) had converged over time, making the lighter-touch registered tier no longer justified, and repealed the regime effective 1 August 2024.
Who this affects now
This affects any manager who previously held RFMC status and has since completed migration, as well as any new manager assessing which licence to apply for today. Fund sponsors evaluating whether to house the manager itself, or the fund vehicle, in a VCC structure should also review key-person readiness testing for a VCC’s fund manager, since MAS licensing conditions and VCC governance obligations are assessed separately but need to be consistent.
What migration required
Existing RFMCs transitioned to A/I LFMC status via a streamlined Form 1AR process rather than a full fresh licence application, and the old S$250 million assets-under-management cap that applied to RFMCs was removed on migration. The transition deadline for existing RFMCs to complete migration was 30 June 2024, ahead of the regime’s formal repeal on 1 August 2024. MAS no longer accepts any RFMC applications; a manager operating without having completed migration by the deadline would have been in breach of the licensing requirement in Section 82 of the Securities and Futures Act 2001, which requires a person to hold a Capital Markets Services licence to carry on a regulated fund management activity.
Cost and timeline
The Form 1AR streamlined migration itself did not attract a separate MAS application fee beyond the standard annual licence fees now payable as an A/I LFMC. A/I LFMCs face ongoing minimum base capital requirements of S$250,000 (for managers not holding client assets) or S$1 million (for managers holding client assets), compared to the lighter RFMC capital expectations previously in place. New managers today applying directly for an A/I LFMC licence should budget 4 to 6 months for MAS review, longer than the RFMC registration process it replaced. Family offices comparing this to their own fund’s tax position should also see our comparison of Section 13O versus Section 13U family office tax incentives, since manager licensing and fund-level tax exemption are assessed separately but often reviewed together.
Frequently asked questions
Fund managers most commonly ask whether any RFMC status survives today (it does not), whether the AUM cap still applies post-migration (it was removed), and whether a new manager can still apply for RFMC-style light-touch treatment (no, the only routes now are A/I LFMC, Retail LFMC, or the simplified Venture Capital Fund Manager route for managers investing solely in venture capital deals, or a genuine single-family office licensing exemption where applicable).
Common mistakes and rejection reasons
The most common mistake now is a manager’s marketing or fund documents still referencing RFMC status from before the 2024 repeal, which MAS and investors will flag as outdated. A second is a new manager assuming the old S$250 million AUM ceiling still constrains their business plan when structuring a fund under Section 13O or Section 13U of the Income Tax Act 1947; that cap no longer applies under the current A/I LFMC framework. Sponsors should also confirm early which licence tier fits their target investor base, since Retail LFMC obligations are materially heavier than A/I LFMC.
Worked example
A boutique manager that held RFMC status until the regime’s 2024 repeal completed its Form 1AR migration to A/I LFMC status on time, but its investor-facing pitch deck and fund offering memorandum, last updated in 2023, still described the manager as “MAS-registered” rather than “MAS-licensed.” A prospective institutional investor’s own compliance team flags the mismatch during due diligence in 2026, delaying the subscription while the manager updates its marketing materials and confirms current licence status directly with MAS. Refreshing all investor-facing materials at the point of migration, not just the internal compliance filings, avoids this kind of due diligence delay.
Regulator references
For the underlying rules referenced above, see MAS, Singapore Statutes Online.
Related guides
For how the current single-licence framework operates in practice, see our note on the MAS streamlined fund manager framework.
FAQs
Can I still register as an RFMC in 2026?
No. MAS repealed the RFMC regime on 1 August 2024 and does not accept new RFMC applications.
What happened to the RFMC S$250 million AUM cap?
It was removed for managers who migrated to A/I LFMC status; A/I LFMCs are not subject to that ceiling.
What licence should a new fund manager apply for today?
Typically an A/I LFMC licence for managers serving accredited and institutional investors, a Retail LFMC licence for managers serving retail investors, or the Venture Capital Fund Manager route for venture-only strategies.
Did migration change base capital requirements?
Yes, A/I LFMCs face minimum base capital of S$250,000 or S$1 million depending on whether they hold client assets, which can be higher than typical RFMC-era capital levels.
Is there any grandfathering left for pre-2024 RFMCs?
No active grandfathering remains; all former RFMCs were required to complete migration by 30 June 2024, ahead of the regime’s repeal.
Need help with this? Call, SMS or WhatsApp +65 8501 7133, or email [email protected]. Raffles Corporate Services works with a panel of corporate and employment law firms; this article is general information, not legal advice.