MAS Financial Adviser (FA) and FA Rep licensing — Documents required and templates
MAS Financial Adviser (FA) licensing is the approval a firm needs from the Monetary Authority of Singapore before it can advise clients on investment products, and FA Representative notification is how the individuals who give that advice are authorised. This guide explains the licence and representative regimes, the documents required, costs and the templates a wealth manager should prepare in 2026.
This article is general information and not legal advice. Raffles Corporate Services works with a panel of corporate and employment law firms.
What MAS Financial Adviser licensing regulates
Under the Financial Advisers Act 2001, a person must hold a financial adviser’s licence, or qualify for an exemption, to carry on a business of providing financial advisory services in respect of investment products. Section 6 of the Financial Advisers Act 2001 addresses the licensing requirement, and the Second Schedule sets out the investment products that bring an activity within scope, including securities, collective investment schemes and life policies.
Advisory services covered include advising on investment products, issuing analyses or reports, marketing collective investment schemes and arranging life policies. If your business only advises on a single product type you still need to be licensed unless a clear exemption applies.
FA firm licence versus FA Representative notification
There are two layers. The firm holds the financial adviser’s licence; the individuals who deal with clients are FA Representatives whose appointment is lodged with MAS through the Representative Notification Framework. A representative may only conduct the regulated activities that the principal firm is licensed for, and must meet minimum entry and examination requirements administered through the Institute of Banking and Finance.
Exempt financial advisers, such as banks, insurers and licensed fund managers advising incidentally, still appoint representatives under the same notification framework. Getting the interaction right between the firm licence and the representative layer is where most applicants need help.
Documents required for an FA licence application
MAS expects: the application form via the corporate portal; ACRA business profile and constitution; a three-year business plan and financial projections; shareholding and group structure charts to ultimate beneficial owners; fit-and-proper declarations for directors, the CEO, key management and substantial shareholders; the compliance and risk-management framework; professional indemnity insurance details; and evidence of base capital.
Templates to prepare in advance include a compliance manual, a conflicts-of-interest and remuneration policy, a client suitability and fact-find procedure, an AML/CFT programme, and a representative register. For the statutory backdrop to advising on specific product classes, our explainer on the Financial Advisers Act chapter provisions is a useful companion.
Cost, capital and timeline benchmarks
The base capital requirement for a licensed financial adviser is S$150,000 (higher where the firm also holds client money or conducts fund management). Professional indemnity insurance is required and priced by scope. Monetary Authority of Singapore application fees apply per regulated activity. First-year set-up including legal, compliance build and PI cover commonly runs S$60,000 to S$180,000.
On timing, a complete FA licence application typically takes about 4 to 6 months to approval-in-principle. Representative notifications, once the firm is licensed, are considerably faster. A new wealth firm should not begin advising clients until the firm licence is granted and its representatives are lodged.
Common mistakes and eligibility gotchas
The recurring problems are: appointing representatives who have not cleared the required IBF examinations; understating the compliance function; unclear ownership or unverifiable source of capital; and confusing the FA regime with the Capital Markets Services regime under the Securities and Futures Act. A firm advising on funds and dealing in securities may need both licences.
Foreign founders should incorporate the Singapore entity first; our guide on Singapore Pte Ltd registration for foreigners covers that step. Where the firm advises fund clients, the interaction with fund structures such as the VCC is set out in our note on the VCC permissible fund manager rules.
Step-by-step process
- Decide the regulated activities and confirm whether you need the FA licence, a Capital Markets Services licence, or both.
- Incorporate the Singapore entity and fund the S$150,000 base capital; arrange professional indemnity insurance.
- Draft the compliance manual, suitability and fact-find procedure, conflicts and remuneration policy, and AML/CFT programme.
- Identify representatives and ensure they clear the required IBF examinations and fit-and-proper checks.
- Lodge the FA licence application via the corporate portal with the business plan and supporting documents.
- Work through MAS review (about 4 to 6 months) and satisfy any conditions to approval.
- After the firm is licensed, lodge representative notifications and begin advising clients.
FAQs
Is an FA licence the same as a Capital Markets Services licence?
No. The FA licence under the Financial Advisers Act 2001 covers advising on investment products; the Capital Markets Services licence under the Securities and Futures Act 2001 covers activities such as fund management and dealing in capital markets products. Some firms need both.
What are the entry requirements for an FA Representative?
Representatives must be fit and proper, meet minimum academic requirements, and pass the relevant Capital Markets and Financial Advisory Services examinations administered through the Institute of Banking and Finance before their appointment is lodged with MAS.
What is the base capital for a licensed financial adviser?
The base capital requirement is S$150,000 for a standalone licensed financial adviser, with higher requirements where the firm also holds client monies or conducts additional regulated activities.
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.