Single family office in Singapore: 13O vs 13U rules for 2026

A single family office in Singapore needs two things in 2026. The first is a Singapore-incorporated single family office (SFO) that files a Notice of Commencement of Business with MAS within 14 days of starting operations, under the framework in force from 15 June 2026. The second applies only if you want fund tax exemption: either a 13O/13OA award, which requires S$20 million in Designated Investments at application and two investment professionals, or a 13U award, which requires S$50 million and three investment professionals. These conditions come from MAS FDD Circular 05/2026, dated 31 July 2026.

That is the core answer. The detail matters, though, because the 2026 changes moved several thresholds that families had relied on for years. If you are a family principal or CFO comparing structures, the choice between schemes affects more than tax. It shapes your hiring plan, your fund vehicle and how much capital you need to commit in Singapore each year.

What Singapore requires of a single family office in 2026

The rules work in two layers. Many families treat them as one process, but they are separate. You can satisfy the first and skip the second.

Layer one is the licensing exemption and MAS notification. Under the MAS FAQs issued on 12 June 2026, an SFO does not need a capital markets licence, provided it meets these conditions:

• Incorporation: The SFO must be incorporated in Singapore.

• Who it serves: It may manage money only for family members, family-funded charities and key employees.

• Key-employee limits: Key-employee assets are capped at 10% of AUM, and key employees may hold a non-controlling stake of up to 10%.

• Notification: You file through go.gov.sg/sfo-commencement-of-business within 14 days of starting operations. Existing SFOs have until 15 June 2027.

• Annual return: This is due within 4 months of financial year end. No extensions are given.

Layer two is the fund tax incentive under section 13O or 13U. This is optional, but most families with meaningful assets want it, because it exempts specified income in the fund vehicle. If you are new to how the SFO company, fund and holding entities fit together, our guide to family office structures and their building blocks is a useful primer.

13O vs 13U: the side-by-side comparison

The biggest practical difference is the vehicle each scheme accepts. Section 13O covers Singapore-incorporated, Singapore tax-resident companies. Section 13OA extends this to Singapore-registered limited partnerships from 1 January 2025. Section 13U accepts almost any vehicle, including offshore funds, and it can bring master-feeder and SPV structures under one award.

The 30/50 investor rule is the trap for 13O. Under this rule, a Singapore-resident company or other non-individual investor that, alone or with its associates, owns more than 30% of the fund (if the fund has fewer than 10 investors) or more than 50% (if it has 10 or more) on the last day of the fund's financial year becomes a non-qualifying investor. The fund keeps its tax exemption, but that investor must pay IRAS a penalty equal to its percentage stake, multiplied by the fund's income for the year, multiplied by the corporate tax rate. Individuals, non-resident entities and other tax-exempt funds are not caught. A family that holds the fund through a Singapore holding company should check this before applying and again at every year end. Section 13U does not carry this rule, which is one reason larger families prefer it.

The conditions for awards approved from 1 August 2026

These conditions apply to new SFO awards approved on or after 1 August 2026, under FDD Cir 05/2026.

Minimum assets come first. A 13O or 13OA award needs S$20 million AUM in Designated Investments, both at application and at each basis period end. A 13U award needs S$50 million. Investments in the family's operating businesses do not count towards the minimum, so a family whose wealth sits mostly in its own company must hold separate investable assets.

Investment professionals are the next condition. A 13O fund needs two IPs, one of whom is not a family member, and you may apply with one. A 13U fund needs three, again with one non-family member, and you may apply with two. This first-year hiring concession has a hard edge: the full count must be in place by the end of the basis period of the first year of assessment, or the award is revoked from the start. Qualifying IPs are portfolio managers, research analysts or traders who are Singapore tax resident and earn more than S$3,500 a month.

Local spending is assessed per basis period:

In the upper tiers, the balance can come from donations to Singapore charities or IPCs, or from grants to blended finance. Grants count double.

The capital deployment requirement replaced the old 10% or S$10 million local investment list from 1 January 2025. You must invest the lower of 10% of AUM in Designated Investments or S$10 million in Designated Investments that fall into one of three groups:

1. Investments listed on MAS-approved exchanges.

2. Investments distributed by MAS-licensed financial institutions in Singapore, excluding equities listed outside approved exchanges.

3. Non-listed Singapore-incorporated operating companies with substantive presence.

Four categories earn a 2x credit: equities on approved exchanges, funds investing mainly in Singapore equities, blended finance, and non-listed Singapore operating companies with substantive presence.

You also need a private banking account with a MAS-licensed institution, and an annual declaration filed within 4 months of year end.

How to apply, step by step

Applications go to MAS through the Tax Schemes Portal (taxschemes.mas.gov.sg). The order of steps matters, because each one depends on the one before it:

1. Incorporate the SFO in Singapore. Non-residents should read up on setting up a Singapore company as a foreigner first.

2. File the MAS notification within 14 days of starting operations.

3. Set up the fund vehicle, whether a company, LP or offshore structure.

4. Open the private banking account with a MAS-licensed institution. You need this at application.

5. Hire your first IP or IPs.

6. Apply through the portal.

After the award, any changes to owners, directors, key staff or IPs are notified to FO_13OU@mas.gov.sg.

Cosmos coordinates the corporate side of this sequence. That covers incorporating the Singapore company and the fund vehicle, plus company secretary work and ongoing filings. We work alongside licensed Singapore legal, tax and fund administration advisers on the MAS application itself, so the structure and the application stay aligned.

Choosing between 13O and 13U for your family

If your investable assets sit between S$20 million and S$50 million, the decision is made for you: only 13O or 13OA is open. The real question is whether a company or an LP suits you better. LPs under 13OA give flexibility for families who want partnership-style economics between generations.

Above S$50 million, 13U usually wins for families with assets already held offshore. Bringing a master-feeder structure and its SPVs under one award avoids repatriating everything into a Singapore company. It also removes the 30/50 headache. The cost is the third investment professional, which means a third salaried hire in Singapore.

Compare two families with S$60 million each. The first holds everything in a single Singapore company, has no Singapore corporate shareholders and wants lean staffing. For that family, 13O makes sense. The second has a Cayman fund with two SPVs and a Singapore holding company owning 40%. A Cayman fund cannot use 13O without moving into a Singapore vehicle, and with fewer than 10 investors a 40% Singapore corporate holder would be a non-qualifying investor under the 30/50 rule, so 13U fits better. Families weighing other jurisdictions can compare a DIFC VCC for a family office, see how DIFC VCC vs Singapore VCC stack up, or look at Cayman foundation companies for the ownership layer above the fund.

Why older guides quote different numbers

If you have read guides on Singapore family office requirements written before August 2026, you will have seen figures that no longer apply to new awards. Some quote a S$10 million entry point for 13O, with two years to grow to S$20 million. That applied only to awards approved before 1 August 2026. Others list the old local investment rule with its specific categories of Singapore assets.

Two things changed. From 1 January 2025, the capital deployment requirement replaced the local investment list, and Singapore-registered LPs became eligible under 13OA. Then, for awards approved from 1 August 2026, FDD Cir 05/2026 required the full S$20 million for 13O and 13OA at application, with no grace period (13U needs S$50 million). The same circular sets the IP hiring rules and excludes family operating-business investments from the minimum.

When a source does not say which circular it relies on, assume it is out of date. Check the effective date of the award you are applying for, not the date you started planning. Confirm the current conditions with MAS before you apply.

Frequently asked questions

Is there still a grace period to grow from S$10 million to S$20 million? No. For awards approved from 1 August 2026, a 13O or 13OA fund needs S$20 million in Designated Investments at application, and 13U needs S$50 million. You must also keep the minimum at each basis period end.

Does a Singapore single family office need an MAS licence? No, provided it is incorporated in Singapore and manages money only for family members, family-funded charities and key employees within the 10% limits. It must still file the Notice of Commencement of Business within 14 days and lodge an annual return within 4 months of year end.

Can the family's operating businesses sit inside the fund? They can be held, but those investments do not count towards the minimum AUM. You need enough separate Designated Investments to meet the S$20 million or S$50 million threshold on their own.

What happens if assets fall below the minimum at year end? The minimum applies at each basis period end, so a shortfall means you fail that condition for the year. Speak to your tax adviser before year end if markets move against you, rather than after.

How long does the 13O and 13U incentive last? The schemes expire on 31 December 2029. Awards held by then continue for the life of the fund, as long as the conditions keep being met.

For most families, the sequencing is where things go wrong, more often than the thresholds. Get the company, notification, fund vehicle and bank account in the right order, plan your IP hires around the first-year deadline, and pick the scheme your current holding structure supports. If you want help setting up the Singapore company and fund vehicle while your licensed advisers handle the MAS application, talk to Cosmos about getting the corporate groundwork right from day one.