MAS Registered Fund Management Company (RFMC) sunset and migration — Costs and fees breakdown
The MAS Registered Fund Management Company regime has been wound down, and every former RFMC must migrate to a Licensed Fund Management Company holding a Capital Markets Services licence. This guide sets out the migration path, the capital and compliance thresholds, and the realistic costs in Singapore dollars as at June 2026.
Raffles Corporate Services works with a panel of corporate and employment law firms; this article is general information, not legal advice.
What the MAS Registered Fund Management Company regime was
The RFMC framework allowed a fund manager to serve up to 30 qualified investors and manage assets capped at S$250 million without holding a full Capital Markets Services (CMS) licence. It was created as a lighter-touch entry point for boutique managers and family-office-adjacent vehicles. The Monetary Authority of Singapore stopped accepting new RFMC applications and set a transition window for existing registrants to convert to a Licensed Fund Management Company serving accredited and institutional investors, commonly called an A/I LFMC.
The licensing backbone is the Securities and Futures Act 2001, with conduct and capital rules in the Securities and Futures (Licensing and Conduct of Business) Regulations. Section 82 of the Securities and Futures Act 2001 establishes the requirement to hold a capital markets services licence for regulated activities such as fund management, and the RFMC carve-out that previously sat alongside it has been removed.
Who the migration affects
Any entity previously registered as an RFMC, its directors, and its representatives must act. In practice this covers boutique discretionary managers, single-manager hedge strategies, and smaller private-equity and venture managers that used the RFMC route to launch. Sponsors planning a VCC with a permissible fund manager should note that the manager appointed to the VCC must hold a current CMS licence or qualify under an exemption, so the RFMC sunset feeds directly into VCC governance.
Eligibility and requirements for the A/I LFMC
To convert, the entity must demonstrate fit-and-proper directors and representatives, at least two directors (one resident in Singapore), a minimum of two relevant professionals, and an approved CEO with at least five years of relevant experience. Base capital for an A/I LFMC is typically S$250,000, with risk-based capital and professional indemnity insurance expected. Independent annual audit and an internal compliance arrangement (in-house or outsourced) are required on an ongoing basis.
MAS Registered Fund Management Company migration costs and timeline
Expect the following indicative figures. MAS application-related fees for a CMS licence are modest (in the region of S$1,000 per regulated activity), but the real cost sits in professional support and capital. Compliance consultancy and licence application support typically run S$15,000 to S$40,000. Base capital of S$250,000 must be funded and maintained. Professional indemnity insurance commonly costs S$5,000 to S$15,000 a year. Annual external audit is usually S$8,000 to S$20,000. The migration assessment by MAS generally takes 3 to 6 months from a complete submission, so managers should not leave it to the final weeks of their transition window.
Step-by-step migration process
First, gap-assess the existing RFMC against A/I LFMC requirements, focusing on capital, headcount and the CEO criterion. Second, top up base capital and arrange professional indemnity cover. Third, prepare the licence application through MAS’s online portal, including the compliance manual, risk management framework and business plan. Fourth, respond to MAS queries promptly. Fifth, on approval, update the entity’s records, client agreements and any LFMC licensing documentation and notify counterparties of the change in status.
Common mistakes and gotchas
The most frequent error is underestimating the CEO and professional-headcount requirements, which are stricter for an LFMC than they were for an RFMC. A second is failing to maintain base capital throughout the application period. A third is treating the migration as administrative when it is, in substance, a fresh licensing assessment. Managers who also hold a Capital Markets Services licence for dealing or advising should confirm that all regulated activities are correctly reflected on the new licence.
Related guides
For the destination licence in detail, see our breakdown of the MAS Licensed Fund Management Company (LFMC). For the underlying licence mechanics across regulated activities, read the MAS Capital Markets Services (CMS) licence guide. Fund sponsors using a Variable Capital Company should also review the VCC permissible fund manager rules.
Authoritative references: the Monetary Authority of Singapore publishes the current fund management licensing requirements, and the Inland Revenue Authority of Singapore sets out the tax treatment of fund management income and any applicable incentives.
FAQs
Has the RFMC regime been abolished?
The RFMC registration route has been closed to new entrants and existing RFMCs are required to migrate to an A/I LFMC within the transition window set by MAS. Confirm the current deadline directly with MAS before filing.
How much base capital does an A/I LFMC need?
Base capital is typically S$250,000, which must be funded before submission and maintained on an ongoing basis, alongside risk-based capital and professional indemnity insurance.
How long does migration take?
A complete CMS licence submission is generally assessed within 3 to 6 months, but incomplete applications or capital shortfalls extend this materially.
Can my existing RFMC representatives continue?
Representatives must be re-notified and meet the fit-and-proper and competency standards applicable to an LFMC; some may require additional examinations or experience evidence.
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.