MAS Registered Fund Management Company (RFMC) sunset and migration — Eligibility and requirements checklist
Published on: 25 Jul, 2026

MAS Registered Fund Management Company (RFMC) sunset and migration — Eligibility and requirements checklist

A MAS Registered Fund Management Company (RFMC) was a light-touch fund management licence that let managers serve up to 30 qualified investors and hold assets below S$250 million. The Monetary Authority of Singapore has retired the RFMC regime, and every affected manager must migrate to a Capital Markets Services licence before the transition window closes.

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 Registered Fund Management Company sat at the entry level of Singapore’s fund management ladder. Under the Securities and Futures Act 2001, carrying on a business of fund management ordinarily requires a Capital Markets Services (CMS) licence, but the RFMC operated as a registered class that was exempt from the full licensing burden while still being subject to MAS conduct rules.

An RFMC could manage assets for no more than 30 qualified investors, of which no more than 15 could be funds or limited partnership vehicles, and its total assets under management were capped at S$250 million. These ceilings made it popular with boutique managers, family-linked vehicles and first-time fund principals testing a Singapore base.

Section 82 of the Securities and Futures Act 2001 establishes the baseline requirement that a person carrying on fund management must be licensed, while the registered regime was carved out by subsidiary regulation. Because the carve-out has now been withdrawn, the population of registered managers must convert or exit.

Why MAS retired the RFMC framework

MAS moved to a single, clearer licensing structure so that all retail-adjacent and accredited-investor managers sit under a consistent Capital Markets Services regime. The registered tier created supervisory blind spots because registered managers were not held to the same ongoing licensing conditions as licensed managers, despite handling meaningful assets.

The practical result is a sunset: no new RFMC registrations are accepted, and existing RFMCs are directed to apply for an Accredited/Institutional Licensed Fund Management Company (A/I LFMC) licence, which carries no headcount cap and no S$250 million asset ceiling but does impose higher base capital and compliance expectations.

Who must migrate and what the LFMC upgrade requires

Every entity currently holding RFMC status must migrate. The natural destination is the A/I LFMC, which permits an unlimited number of accredited and institutional investors. Retail-facing managers must instead pursue a Retail LFMC, which carries the most demanding requirements.

Core substance expectations for an A/I LFMC include a minimum base capital of S$250,000, at least two directors and two relevant professionals resident in Singapore, a competent risk management function, professional indemnity insurance appropriate to the strategy, and independent annual audit. Managers should map these against their current headcount early, because hiring resident professionals is often the longest lead item.

For managers who also intend to run pooled vehicles, the licensed structure pairs naturally with a Singapore fund vehicle. See our explainer on the VCC Act 2018 — Section 46 Permissible Fund Manager rules — Timeline and processing benchmarks to understand how the manager and the fund fit together.

Cost and timeline benchmarks for the MAS Registered Fund Management Company migration

Budget realistically. MAS application fees for a fund management licence are modest, but the true cost sits in professional advisers, compliance build-out and resident hires. A typical migration budget runs from S$25,000 to S$60,000 in first-year professional and setup costs, plus the S$250,000 base capital that must remain unencumbered.

On timeline, allow 4 to 6 months from decision to approval in a clean case: roughly 2 to 4 weeks to assemble the application pack, 3 to 4 months for MAS review and queries, and a short window to finalise capital and insurance before the licence is granted. Complex ownership or overseas control persons can extend this.

Foreign principals frequently pair the licence application with a fresh Singapore holding entity; our guide to How to Strike Off a Singapore Company: Complete ACRA Guide walks through the incorporation and resident-director steps that sit alongside the MAS filing.

Step-by-step migration process

First, confirm your target licence class (A/I versus Retail) against your investor base. Second, gap-assess your current RFMC substance against LFMC conditions, focusing on resident professionals, capital and risk management. Third, prepare the Form 1 application and supporting documents through MAS’s electronic portal, including business plan, compliance arrangements and fit-and-proper declarations for shareholders and key officers.

Fourth, respond promptly to MAS queries; incomplete compliance manuals and thin risk frameworks are the most common cause of delay. Fifth, on approval, top up base capital, bind professional indemnity cover, and update your offering documents and client agreements to reflect the new licensed status. Our companion piece on the MAS Registered Fund Management Company (RFMC) sunset and migration — Timeline and processing benchmarks tracks the same regulatory arc for managers who prefer to read the timeline view.

Common mistakes to avoid

The most damaging error is treating migration as a paperwork formality. MAS assesses substance, and a manager that cannot evidence two genuinely resident professionals will stall. A second frequent error is leaving base capital in an operating account that dips below S$250,000 mid-review. A third is forgetting that outsourced compliance still requires a named, accountable individual inside the firm.

Managers should also confirm licensing consequences for any parallel activities such as dealing in capital markets products or providing financial advice, which may require additional regulated activity coverage under the Securities and Futures Act 2001. Refer to the Monetary Authority of Singapore at mas.gov.sg and the statute text at sso.agc.gov.sg for the primary sources.

FAQs

Can I keep operating as an RFMC after the sunset date?
No. Once the registered regime is withdrawn, continued fund management without a Capital Markets Services licence would fall foul of section 82 of the Securities and Futures Act 2001. You must either hold an approved LFMC licence or cease regulated fund management.

What is the difference between an A/I LFMC and a Retail LFMC?
An Accredited/Institutional LFMC may serve only accredited and institutional investors but has no cap on their number. A Retail LFMC may serve the general public and carries higher base capital, more directors and stricter conduct requirements.

How much base capital must a migrated manager hold?
An A/I LFMC must maintain a minimum base capital of S$250,000 that remains unencumbered. Retail LFMCs face materially higher thresholds depending on assets and activities.

How long does the migration take?
Plan for 4 to 6 months in a clean case, driven mainly by MAS review time and the lead time to recruit resident professionals and finalise capital.

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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.