MAS streamlined fund manager framework 2026 — Documents required and templates
The MAS streamlined fund manager framework 2026 is the single, licensed regime that now governs every fund manager in Singapore after the Registered Fund Management Company (RFMC) tier was repealed on 1 August 2024. In place of the old two-track system there is one Capital Markets Services (CMS) licence for fund management, calibrated by the type of investors served. This guide explains the framework, the documents you need, and the templates that keep an application moving.
Raffles Corporate Services works with a panel of corporate and employment law firms; this article is general information, not legal advice.
What the streamlined framework is
Following the repeal of the RFMC regime, the Monetary Authority of Singapore consolidated fund management into the licensed structure under the Securities and Futures Act 2001. Managers now hold a CMS licence in one of three shapes: an Accredited/Institutional (A/I) LFMC serving up to accredited and institutional investors; a Retail LFMC able to serve retail clients; or a Venture Capital Fund Manager (VCFM) on a lighter-touch, registration-style track for genuine venture capital. The streamlining removed the registered tier so that firms of comparable risk face comparable rules.
Who the framework is for
It applies to boutique managers, single- and multi-family offices that manage third-party or externally-facing capital, private equity and venture firms, and former RFMCs now operating as A/I LFMCs. Family offices managing only their own related capital may still rely on the section 13O and 13U tax exemptions rather than a licence, but the moment external capital or third-party mandates enter the picture, the licensed framework governs.
Eligibility and requirements
An A/I LFMC must maintain base capital of at least S$250,000, appoint at least two directors and two full-time resident relevant professionals, and satisfy the fit-and-proper test for all key individuals. A Retail LFMC faces a higher base capital of S$1,000,000 and enhanced governance. A VCFM has no prescribed minimum capital and a faster review but is confined to qualifying venture capital funds. Section 82 of the Securities and Futures Act 2001 provides that a person must not carry on a business in a regulated activity unless licensed or exempt, and section 86 addresses the ongoing conditions attached to a licence.
Documents required
Prepare the Form 1 CMS application, a corporate structure and shareholding chart, Form 3 fit-and-proper declarations and CVs for each director and representative, a business plan with an AUM forecast, the compliance and risk management framework, an outsourcing register, evidence of base capital, professional indemnity insurance, and either audited accounts or an opening balance sheet. Keep board resolutions authorising the filing and the appointment of your compliance officer as supporting templates.
Cost and timeline benchmarks
The MAS application fee is S$1,000 per regulated activity, with the annual fee payable thereafter. Professional fees for an A/I LFMC application typically range from S$18,000 to S$45,000; a Retail LFMC is materially more. Expect four to six months for an A/I LFMC from a complete submission, and around two to four months for a VCFM. Ongoing annual costs for compliance, audit and resident professionals commonly run from S$60,000 to well over S$150,000 depending on scale.
Common mistakes and gotchas
Firms often mis-classify themselves — a “family office” that manages a friend’s capital is no longer purely internal and may need a licence. Others under-resource the two-resident-professionals requirement, or assume a VCFM can drift into non-venture strategies without re-licensing. If you are structuring the underlying fund as a VCC, confirm the manager clears the VCC permissible fund manager rules first. Where a foreign director is appointed, plan the immigration angle early — our colleagues explain the process in nominee director services for foreigners. For the licensed-entity document set in full, see the MAS LFMC documents and templates guide.
FAQs
Is there still a “registered” fund manager option? No. Since 1 August 2024 there is a single licensed framework; the registered tier was removed.
What is the difference between A/I and Retail LFMCs? Investor scope and capital. A/I LFMCs serve accredited and institutional investors with S$250,000 base capital; Retail LFMCs may serve retail investors and hold S$1,000,000 base capital.
Do family offices need a licence? Not if they manage only their own related capital and meet the exemption conditions; managing external capital typically triggers licensing.
How fast is the VCFM route? Commonly two to four months, but it is confined to genuine venture capital funds.
Where are the rules published? The framework is set out by the Monetary Authority of Singapore and grounded in the Securities and Futures Act 2001 at 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.