Reserving a Variable Capital Company name costs $15, is filed on the VCC Portal rather than the main Bizfile system, and is usually approved within three working days. Once approved, the name is held for 120 days, and you must register the VCC within that period or lose it.
Raffles Corporate Services works with a panel of experienced Singapore law firms who offer cost-effective and efficient legal service and advice. This article is general information only and is not legal advice.
The name application is the step that looks trivial and is not. It is where the file first meets a human reviewer at ACRA, where a referral to another regulator can add weeks, and where the $15 is spent whether or not the answer is yes.
It is also sequenced later than most people assume. You reserve the name after you have settled your directors and officers, not before, because the application asks for their details.
Where you file, and who may file it
VCC name applications are made on the VCC Portal, which is a separate system from the Bizfile service used for ordinary companies. If you have been through a private limited incorporation and are expecting the same screens, you are in the wrong place. Our orientation to Bizfile explains what that system does and does not cover.
A Singapore-resident applicant may file the name application themselves. A foreigner must engage a registered corporate service provider to file on their behalf. That is not a recommendation, it is a requirement, and it applies from this first step rather than from the incorporation filing. If you are not sure whether your intended adviser is registered for this purpose, the point is worth checking against our Corporate Service Providers Act 2024 compliance FAQ.
What you need before you start
| What to prepare | Detail |
|---|---|
| Proposed VCC name | Search the VCC Portal first to confirm availability. The general Singapore naming rules apply |
| Details of every proposed director and officer | Residential address, identification number and type, nationality or citizenship |
| In-principle approval from another authority, if applicable | PDF only, maximum 5MB |
| Payment method | Credit card, debit card or online banking |
The second row is the one that reorders your project. You cannot sensibly file this until the board and the officer line-up are fixed, which is why the officer decisions covered in our guide to VCC directors and key officers come first.
If any proposed officer holds a Foreign Identification Number, they should confirm with their pass issuer, the Ministry of Manpower or the Immigration and Checkpoints Authority, that they may accept the role before their name goes on the application.
The fee, and the fact that it is not refundable
The name application fee is $15.
It is not refunded if the application is rejected. It is not refunded if you withdraw. That is a small sum, but it makes the case for doing the availability search properly and for thinking about referral risk before you pay, rather than paying three times for three guesses.
For context, the $15 forms part of the total ACRA set-up cost of $8,015 for a VCC, the balance being the $8,000 incorporation fee. Registering a sub-fund is $400 each. The full cost picture is set out in VCC key features and eligibility requirements.
How long approval takes
Most applications: up to three working days.
Names that require referral to another authority: 14 to 60 days.
That second line is the one that wrecks launch timetables. A referral happens when the proposed name contains a word that another regulator has an interest in. Words suggesting banking, insurance, fund management, education, media, legal or medical activity are the usual triggers, and a fund name is more likely than an ordinary trading name to contain one.
Sixty days is a long time when a first close is scheduled. If your proposed name contains anything that could be read as a regulated activity, assume the long path and file early. If you have already obtained an in-principle approval from the relevant authority, attach it as a PDF, because that is what shortens the exchange.
Names that will be refused
The general Singapore business naming rules apply. A name will not be accepted if it is identical to an existing entity name, if it is undesirable, or if it is of a kind the Minister has directed the Registrar not to accept. Section 21 of the Variable Capital Companies Act 2018 applies sections 27 and 28 of the Companies Act 1967 to VCCs, which is where the substantive naming power and the appeal route come from.
Two practical points that the rules do not spell out:
- “Identical” is narrower than “confusingly similar”. A name may pass ACRA’s identity test and still expose you to a trade mark claim from a fund with a similar brand. ACRA’s clearance is not a trade mark clearance, and nobody at ACRA is checking that for you.
- A name available today may not be available next week. There is no queue. Run the search and file promptly rather than circulating a shortlist for a fortnight.
The steps, in order
- Settle your proposed directors, secretary, fund manager and auditor, and collect their identification details.
- Search the VCC Portal for the proposed name and check it against the general naming rules.
- Obtain in-principle approval from any relevant referral authority if the name touches a regulated activity, and save it as a PDF under 5MB.
- Log in to the VCC Portal, or instruct your corporate service provider to file if you are a foreigner.
- Complete the name application, attaching any approval document, and pay the $15 fee.
- Save the transaction number. You will need it to register the VCC. This is the single most commonly lost item in the whole process.
- Watch for ACRA’s notification of the outcome, and check your alerts rather than waiting for an email that may be filtered. Our note on the ACRA alerts companies miss explains why that matters.
The 120 days, and what they are for
Once approved, the name is reserved for 120 days. You must apply to register the VCC within that window. If you do not, the reservation lapses and the name is released for anyone else to take. Getting it back means paying again and hoping nobody else moved first.
One hundred and twenty days sounds generous. For a VCC it frequently is not, because the work that has to be completed in that window is substantial: finalising the constitution, completing the fund manager arrangements, appointing the custodian, agreeing the offering documents, and satisfying the manager’s onboarding and anti-money laundering checks on the initial investors. That last item has its own rhythm, as our MAS AML and CFT explainer makes clear.
Work backwards from day 120 as soon as the approval lands, and treat day 90 as your internal deadline.
Withdrawing an approved name
If the name is approved and your plans change, you may withdraw the application at any time during the 120-day reservation period, provided you have not yet applied to incorporate or transfer the VCC. You do it on the VCC Portal under eServices, by starting a new VCC or sub-fund transaction and selecting the withdrawal of name application option.
The $15 does not come back. What withdrawal does is release the name cleanly and close the transaction, which is tidier than letting it lapse silently, particularly if the name has been used in draft offering materials.
What goes wrong
The transaction number is lost. It is generated at the point of application and needed at the point of registration, and in between it sits in an email nobody filed. Put it in the deal folder the day it is issued.
The referral is discovered after filing. A sponsor files a name containing a regulated-sounding word on the assumption of three working days, then finds the answer is 45. Everything downstream slips. Identify referral risk before you pay.
Officers change after the name is reserved. The application captured a particular set of proposed directors and officers. If the board changes materially before registration, expect the registration filing to have to reflect the new position, and allow time for it.
The 120 days are treated as a deadline rather than a schedule. Teams file the name, turn to the constitution and the manager arrangements, and rediscover the expiry date at day 110. At that point there is no realistic recovery except paying again.
The name clears ACRA but not the market. A fund that launches under a name close to an established manager’s brand can face a trade mark complaint after the offering documents have been printed. If the brand matters, get it checked independently before you build materials around it. The same due diligence instinct that applies to counterparties, covered in our note on using Bizfile’s search functions before you sign anything, applies to your own name.
Frequently asked questions
How much does it cost to reserve a VCC name?
The application fee is $15, payable by credit card, debit card or online banking. It is not refunded if the application is rejected or if you withdraw it. The $15 is part of the total ACRA set-up cost of $8,015 for a VCC, the rest being the $8,000 incorporation fee.
How long is a reserved VCC name held?
120 days from approval. You must apply to register the VCC within that period. If you do not, the reservation lapses, the name is released to anyone else, and you have to pay to reserve it again with no guarantee it is still free.
Can a foreigner reserve a VCC name themselves?
No. A foreigner must engage a registered corporate service provider to make the name application on their behalf. The requirement applies at the name stage, not just at incorporation, so plan for it before you assume you can file directly from overseas.
Why is my VCC name application taking weeks instead of days?
Most applications are decided within three working days. If the proposed name touches an activity another authority regulates, it is referred to that authority and the timeline becomes 14 to 60 days. Attaching an in-principle approval from that authority, as a PDF under 5MB, is what shortens it.
Can I change my mind after the name is approved?
Yes. You can withdraw the name application on the VCC Portal at any point in the 120-day window, as long as you have not already applied to incorporate or transfer the VCC. The $15 fee is not refunded, but the withdrawal closes the transaction cleanly.
Do I reserve the name before or after choosing my directors?
After. The name application asks for the address, identification number and type, and nationality of every proposed director and officer. Settle the officer line-up first, then file, or you will be holding a name you cannot yet use.
Sequencing this properly
The name reservation is a small filing sitting in the middle of a much larger project. Treated as an afterthought it becomes the thing that expires. Treated as the start of a 120-day countdown, it keeps the rest of the launch honest.
If you have not yet decided whether the structure is right, read what a VCC is and who it suits first. If the officers are not settled, that comes before the name. Once the name is approved, how to register a VCC takes you through the filing that has to happen inside the window.
Raffles Corporate Services files VCC name applications and registrations for fund sponsors, holds the transaction number so you do not have to, and tracks the 120-day expiry against your launch plan. You can also read more on Singapore corporate secretarial practice at Singapore Secretary Services.
The Editorial Team, Raffles Corporate Services
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