MAS Registered Fund Management Company (RFMC) sunset and migration — Timeline and processing benchmarks
Published on: 11 Jul, 2026

MAS Registered Fund Management Company (RFMC) sunset and migration — Timeline and processing benchmarks

The MAS Registered Fund Management Company (RFMC) regime is being sunset, and existing RFMCs are migrating into the Licensed Fund Management Company (LFMC) framework. In practice this means every RFMC must transition to an Accredited/Institutional Investor LFMC licence within the transition window set by the Monetary Authority of Singapore, or wind down its regulated fund management activity in an orderly manner.

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 means

The RFMC category historically allowed a fund manager to serve up to 30 qualified investors and manage assets below S$250 million without holding a full capital markets services (CMS) licence. Under the streamlined framework, MAS is retiring this lighter-touch registration and consolidating fund managers into the LFMC licensing tiers so that supervision, conduct rules and capital requirements apply consistently across the industry. See our related guide, VCC Act 2018 — Section 46 Permissible Fund Manager rules — Step-by-step walkthrough, for more detail.

For a firm currently operating as an RFMC, the migration is not automatic. The manager must submit a licence application, demonstrate that its compliance arrangements meet LFMC standards, and satisfy MAS on the fitness and propriety of its directors, representatives and substantial shareholders before the transition deadline lapses.

Who this affects

Boutique fund managers, single-family and multi-family offices that outsourced portfolio management to an RFMC, and fintech-adjacent asset managers relying on the RFMC threshold are the groups most affected. Any RFMC that intends to continue managing assets for accredited or institutional investors will need to hold an A/I LFMC licence. See our related guide, Setting Up a Variable Capital Company Sub-Fund in 2026: What’s Changed and Why Asset Managers Are Taking Notice, for more detail.

Managers that only advise, or that have wound down their Singapore book, may exit the regime rather than migrate. The right path depends on assets under management, investor base and the firm’s forward business plan.

Eligibility and requirements

An A/I LFMC applicant must maintain a minimum base capital of S$250,000, employ at least two directors and two full-time resident professionals with the relevant experience, and appoint at least two representatives for the regulated activity of fund management. Risk-based capital, professional indemnity insurance and independent annual audit are ongoing conditions.

MAS also expects a documented compliance framework, a business continuity plan, and clear segregation between the firm’s own assets and customer monies. Applicants should prepare their compliance manual, risk register and outsourcing arrangements before filing.

Refer to the official guidance. Refer to the official guidance.

Cost and timeline benchmarks

Budget realistically for both regulatory review time and professional fees. The MAS review clock for a fund management licence typically runs several months from a complete submission, and incomplete applications restart the effective queue.

Mas registered fund management company — costs, timelines and thresholds

  • A/I LFMC minimum base capital: S$250,000
  • Full-time resident professionals: 2 or more
  • Appointed representatives: 2 or more
  • Indicative MAS review: 3 to 6 months from a complete application
  • Professional advisory fees for a migration: typically S$15,000 to S$40,000 depending on complexity

Step-by-step migration process

First, confirm the firm’s target licence tier and AUM trajectory. Second, close any gaps in base capital and staffing. Third, prepare Form 1 and the supporting compliance, risk and business-plan documents. Fourth, submit through the MAS online portal and respond promptly to queries. Finally, complete post-approval conditions such as PII and the appointment of an external auditor.

Running the migration in parallel with existing operations avoids a gap in your ability to manage client assets. Firms that leave the application to the final weeks of the transition window carry the most execution risk.

Common mistakes and gotchas

The most frequent errors are under-budgeting for base capital, assuming representatives automatically carry over from the RFMC registration, and treating the compliance manual as a template rather than a tailored document. MAS scrutinises the substance of the manager’s Singapore presence, not just the paperwork. See our related guide, MAS Licensed Fund Management Company (LFMC) — Timeline and processing benchmarks, for more detail.

A second common trap is fund-vehicle mismatch. Managers migrating their strategies often review whether a Variable Capital Company is the more efficient vehicle for their sub-funds at the same time.

Relevant legislation

The Securities and Futures Act 2001 establishes fund management as a regulated activity requiring a capital markets services licence unless an exemption applies.

The Securities and Futures (Licensing and Conduct of Business) Regulations set out the base capital, staffing and conduct conditions that Licensed Fund Management Companies observe on an ongoing basis.

FAQs

Is the RFMC regime being abolished?
MAS has moved to streamline fund manager licensing and retire the RFMC registration, with existing RFMCs expected to migrate to an LFMC licence or exit within the transition period.

How much base capital does an A/I LFMC need?
A minimum base capital of S$250,000 applies, alongside risk-based capital, professional indemnity insurance and an annual independent audit.

Can I keep managing client assets during migration?
Yes, provided you file within the transition window and continue to meet your existing obligations while the application is assessed.

Should I review my fund vehicle at the same time?
Many managers pair the migration with a review of whether a Variable Capital Company is a more efficient structure for their strategies.

Related guides

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.