MAS Registered Fund Management Company (RFMC) sunset and migration — Documents required and templates
The MAS Registered Fund Management Company (RFMC) regime was repealed on 1 August 2024, and every former RFMC that wished to keep managing assets had to migrate to a Licensed Fund Management Company (LFMC) holding a Capital Markets Services (CMS) licence. If you are still holding legacy RFMC paperwork in 2026, this guide sets out exactly what the sunset means, the documents you now need, and the templates that keep your fund manager compliant under the licensed framework.
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 actually means
Before the repeal, an RFMC could serve up to 30 qualified investors and manage up to S$250 million in assets under management (AUM) without a full licence. The Monetary Authority of Singapore concluded that the business models and risk profiles of RFMCs and Accredited/Institutional (A/I) LFMCs had converged, so the separate registration tier no longer added value. The transition window ran from 1 April to 30 June 2024, and RFMCs that did not secure a CMS licence by 1 August 2024 lost their authorisation to manage funds. In practical terms there is no longer any “register and go” fund management category in Singapore.
Who this affects in 2026
Three groups still feel the effect of the sunset: former RFMCs now operating as A/I LFMCs that must maintain licensed-entity obligations; new fund managers who assumed the old shortcut still exists and need to be redirected to the LFMC route; and family offices that used an RFMC as their investment vehicle and now rely on the section 13O or 13U exemptions instead. If you fall into any of these groups, the compliance baseline is the licensed regime, not the old registration one.
Eligibility and the licensed baseline
An A/I LFMC may only serve accredited and institutional investors. The core requirements carried over from the transition include a minimum base capital of S$250,000, at least two directors and two relevant professionals resident in Singapore, key individuals meeting the fit-and-proper criteria, professional indemnity insurance appropriate to the business, and an independent annual audit. Section 82 of the Securities and Futures Act 2001 establishes that a person must not carry on a business in any regulated activity, including fund management, unless licensed or exempt, which is the statutory hook that ended the RFMC shortcut.
Documents required for migration and ongoing compliance
For a former RFMC regularising its position, or a new applicant on the A/I LFMC route, MAS expects a complete pack: the Form 1 application through the CoRE portal, the corporate structure chart and shareholding details, CVs and fit-and-proper declarations (Form 3) for each director and key representative, the compliance manual and risk management framework, the business plan with projected AUM, audited financials or opening balance sheet, evidence of base capital, and the professional indemnity policy. Retain your board resolution authorising the application and your outsourcing register.
Cost and timeline benchmarks
Budget a MAS application fee of S$1,000 per regulated activity, plus professional fees that typically run from S$18,000 to S$45,000 depending on complexity. The base capital of S$250,000 must be funded and maintained. Realistic timelines from a complete submission to approval are around four to six months, longer where key individuals need additional track-record substantiation. Annual running costs, including compliance support, audit and directors, commonly sit between S$60,000 and S$150,000.
Common mistakes and gotchas
The most frequent error is assuming a dormant former RFMC can simply be reactivated; once authorisation lapsed on 1 August 2024, a fresh CMS application is required. Others under-capitalise, treat the two-resident-professionals rule as optional, or forget that the annual audited return and Form 25A submissions continue every year. If your fund invests through a Variable Capital Company, confirm your manager satisfies the permissible fund manager rules before onboarding sub-funds — see our companion guide on the VCC permissible fund manager rules. Foreign founders standing up a new manager should also read how a Singapore Pte Ltd is registered for foreigners, because the operating entity must exist before the licence is granted. For the full licensed-entity checklist, review our note on the MAS Licensed Fund Management Company (LFMC) documents and templates.
FAQs
Can I still register a new RFMC in Singapore? No. The MAS registered fund management company regime was repealed on 1 August 2024. New managers apply for a CMS licence as an A/I LFMC or a Retail LFMC.
What happened to RFMCs that did not transition? They ceased to be authorised to manage funds from 1 August 2024 and must either wind down or make a fresh licence application.
Is the base capital still S$250,000? Yes, an A/I LFMC must maintain base capital of at least S$250,000.
How long does an A/I LFMC application take? Around four to six months from a complete submission, subject to MAS queries on the key individuals’ track record.
Where can I read the primary sources? The regime and transition are documented by the Monetary Authority of Singapore, and the underlying licensing law sits in the Securities and Futures Act 2001 on Singapore Statutes Online.
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.