Why do guides disagree on Singapore's family-office minimum?

Two rulebooks share one section number

Section 13O of the Income Tax Act 1947 exempts two kinds of fund that MAS treats separately. An SFO fund holds assets that come primarily from members of one family and is managed by a single family office exempt from licensing under the Securities and Futures Act. A non-SFO fund is managed by a licensed fund management company with a bona fide intention to raise capital from third-party investors. MAS's circular of 31 July 2026 publishes the two sets of conditions as separate sections with separate tables, and the numbers differ at almost every line: minimum assets, staffing, spending tiers and how often the tests are applied.

Most online guides collapse the two. A page that quotes a 13O minimum without saying which rulebook it belongs to is quoting from memory. The figure a family needs is the SFO one.

The family-office numbers, dated

18 April 2022: an SFO fund needed S$10 million at application, rising to S$20 million within two years. 5 July 2023: S$20 million at application. From the year of assessment whose basis period ends on or after 1 August 2026, SFO funds approved under those 2023 conditions must show S$20 million of AUM in Designated Investments at the end of each basis period.

New awards approved on or after 1 August 2026: 13O requires at least S$20 million of AUM in Designated Investments at application and at the end of each basis period, reported at those two points only; two qualifying investment professionals, at least one not a family member, with permission to apply with one and hire the second by the end of the first year of assessment. 13U requires S$50 million and three investment professionals. The family's stakes in its own operating businesses do not count toward the minimum.

Minimum local spending runs in three tiers, S$200,000, S$500,000 and S$1 million, by AUM band, and the capital deployment requirement is the lower of 10% of AUM in Designated Investments or S$10 million. The schemes expire on 31 December 2029 unless extended after a Government review; a fund holding an award on that date keeps its exemption.

Where the S$5 million comes from

Non-SFO funds, the licensed-manager kind, with 13O or 13OA awards commencing on or after 1 January 2025 must have S$5 million of AUM in Designated Investments at application, with a grace period to the end of the third basis period, and the condition to maintain that level every year was removed for them with retroactive effect from 1 January 2025. That is a real MAS number. It has never been the floor for a family office.

This page carried the S$5 million figure as the family-office minimum from 27 August to 29 August 2026. The error came from reading the non-SFO entry condition as the general rule. It is corrected here and recorded in the public corrections log, because the point of a reconciler page is that it is the one that admits when it was wrong.

How to read any number you find elsewhere

Ask three questions of the source. Is the figure for an SFO fund or a non-SFO fund? What date does the page carry? Is the number measured on AUM in Designated Investments, the base MAS has used since 1 January 2025? Annex 3 of the circular lists what counts: shares, bonds, units in funds, deposits with any financial institution and property outside Singapore count; Singapore property, and unlisted companies that trade or hold it, do not. A page that answers none of these is not a source. The primary texts are the MAS circular of 31 July 2026 and the MAS family-office FAQ; when this page and MAS ever disagree, MAS is right and the correction goes in the log.

Re-read against the circular on 27 September 2026: every figure above stands. MAS's release of 19 August 2026 on new asset-management measures names the 13O, 13OA and 13U schemes among the funds they cover but changes none of these conditions, and says further details will be announced at Budget 2027. The same re-reading found that this page had described Designated Investments as excluding cash deposits; Annex 3 includes them, and the sentence was corrected on 27 September 2026 and logged.