The RFMC regime in Singapore was repealed in August 2024. Learn what it was, its eligibility rules, and the A/I LFMC pathway that replaced it.

If you have been researching fund management licensing in Singapore, you have likely encountered references to the Registered Fund Management Company (RFMC). For years, the RFMC was the entry-level registration category for smaller fund managers serving accredited and institutional investors — a lighter-touch alternative to a full Capital Markets Services (CMS) licence.

That framework no longer exists. MAS repealed the RFMC regime on 1 August 2024. No new RFMC applications have been accepted since 1 January 2024, and every former RFMC that wished to continue managing assets was required to transition to a Licensed Fund Management Company (LFMC) structure by 30 June 2024.

This article explains what the RFMC was, the eligibility criteria and limits that defined it, why MAS discontinued it, and — most importantly for anyone planning to set up a fund manager in Singapore today — what the current licensing options are and which one applies to your situation.

What Was a Registered Fund Management Company (RFMC)?

MAS introduced the RFMC framework in 2012 under the Securities and Futures Act (SFA). Rather than requiring a full CMS licence, qualifying fund managers could register with MAS, operating under an exemption from the standard licensing requirements applied to other fund management companies.

The RFMC category was intended for smaller operators: boutique managers, family office structures, and early-stage fund businesses that managed assets only for accredited investors and institutional investors. It was never available to managers serving retail investors.

Despite operating under a registration rather than a licence, RFMCs still had to meet substantive admission criteria set by MAS — including fit-and-proper requirements for directors and representatives, minimum capital, and conduct-of-business obligations. The exemption from licensing did not mean exemption from regulatory oversight.

RFMC Eligibility Criteria

To register as an RFMC, a company had to satisfy all of the following conditions at the point of application and on an ongoing basis:

• AUM cap: Assets under management must not exceed SGD 250 million.
• Investor limit: The firm could serve no more than 30 qualified investors (accredited investors and institutional investors combined).
• Base capital: A minimum of SGD 250,000 in base capital had to be maintained at all times.
• Staffing: At least two directors, each with a minimum of five years of relevant experience in fund management or a related regulated activity.
• Singapore incorporation: The entity had to be incorporated in Singapore with a permanent physical office accessible only to its staff.
• Fit and proper: All directors, shareholders, and representatives had to satisfy MAS’s fit-and-proper criteria under Guidelines FSG-G01.
• Investor eligibility: The RFMC could only manage funds on behalf of accredited investors and institutional investors — retail clients were out of scope entirely.

The RFMC framework did not impose any risk-based capital (RBC) adequacy requirement. This was one of the practical advantages over a full LFMC, where financial resources must remain at or above 120% of the total operational risk requirement at all times.

Key Limits and Restrictions Under the RFMC Regime

Beyond the eligibility thresholds, the RFMC structure carried several structural constraints that shaped how these businesses operated.

No retail distribution. RFMCs could not solicit or accept investments from retail investors under any circumstances. All client-facing activity had to be directed exclusively at accredited or institutional investors as defined under the SFA.

Hard AUM ceiling. The SGD 250 million AUM cap was a firm limit — not a soft guideline. A manager that grew beyond this threshold was required to either cease taking on new assets or apply for a full CMS licence as an A/I LFMC.

Investor count restriction. Serving more than 30 qualified investors was not permitted. This constraint was particularly limiting for managers seeking to build a broader institutional client base.

Lower regulatory obligations (with trade-offs). RFMCs had fewer reporting obligations and lower application and annual fees than LFMCs. However, they were still subject to AML/CFT requirements, business conduct obligations under the SFA, and MAS’s guidelines on outsourcing and risk management.

No RBC requirement. Unlike LFMCs, RFMCs were not required to maintain financial resources at 120% of operational risk requirements. This reduced the ongoing capital burden for smaller managers.

RFMC vs. A/I LFMC: How They Compared

For decision-makers who encountered both categories, the differences came down to scale, reporting burden, and cost. The table below summarises the key distinctions that existed before the RFMC regime was repealed.

The base capital requirement was the same under both structures. The primary practical differences were the AUM ceiling, the investor count cap, and the additional RBC and reporting obligations that came with the LFMC licence.

The 2024 Repeal: What Happened and Why

In October 2023, MAS published a consultation paper proposing to abolish the RFMC regime. The rationale was straightforward: the business models and risk profiles of RFMCs and A/I LFMCs had converged over time, making the separate registration tier redundant. Most new entrants were already choosing the A/I LFMC route, and the majority of existing RFMCs had grown into it as well.

The timeline proceeded as follows:

• 1 January 2024: MAS stopped accepting new RFMC applications.
• 1 April to 30 June 2024: Existing RFMCs submitted Form 1AR to apply for a CMS licence as an A/I LFMC.
• End of July 2024: MAS issued CMS licences to successful applicants.
• 1 August 2024: The RFMC regime was formally repealed. Any manager without a CMS licence from this date was no longer authorised to manage funds.

Managers that transitioned via Form 1AR received their A/I LFMC licence through a simplified process rather than a full fresh application. Importantly, the old SGD 250 million AUM cap was removed upon migration — former RFMCs operating as A/I LFMCs are not subject to that ceiling going forward.

As of 2026, no active RFMC status remains in Singapore. The registration tier no longer exists in any form.

Current Fund Management Licensing Pathways in Singapore

Anyone planning to set up a fund management company in Singapore today applies under the CMS licensing framework. There are three active pathways, and the right choice depends on your investor base and asset class.

1. Accredited/Institutional LFMC (A/I LFMC)

This is the standard licence for fund managers serving accredited investors and institutional investors. It replaced the RFMC as the default entry point for boutique and mid-sized managers. There is no cap on AUM or investor numbers. The A/I LFMC carries a full CMS licence with higher reporting obligations than the former RFMC, but also removes the scale constraints that the RFMC imposed.

2. Retail LFMC

A Retail LFMC may serve retail investors in addition to accredited and institutional investors. It operates under the same CMS framework but with significantly higher capital and compliance requirements. Base capital starts at SGD 500,000, rising to SGD 1 million if the manager runs a retail Collective Investment Scheme (CIS). Professional Indemnity Insurance (PII) is required, and an independent compliance function is generally expected in-house.

3. Venture Capital Fund Manager (VCFM)

The VCFM is a simplified sub-regime within the CMS framework, available only to managers of qualifying venture capital funds. It requires no minimum base capital and no risk-based capital requirement — the lightest regulatory footprint of the three options. To qualify, at least 80% of the fund’s committed capital must be invested in unlisted business ventures incorporated no more than ten years at the time of initial investment. VCFMs may only serve accredited and institutional investors.

The VCFM route processes faster than the A/I LFMC (approximately four months versus six months), but if your investment strategy may expand beyond pure venture capital, applying for an A/I LFMC from the outset avoids the cost and delay of a full relicensing exercise later.

A/I LFMC Requirements: What You Need to Know

For most fund managers seeking to operate in Singapore today, the A/I LFMC is the relevant licence. The core requirements under MAS guidelines are:

• Legal structure: The entity must be a company incorporated in Singapore with a permanent physical office accessible only to its staff and directors.
• Base capital: Minimum SGD 250,000, maintained at all times with a sufficient buffer above the floor.
• Risk-based capital: Financial resources must remain at or above 120% of total operational risk requirements. A fall below this threshold requires immediate notification to MAS.
• Key personnel: A CEO resident in Singapore with at least five years of relevant experience in a managerial or supervisory capacity in fund management or a related regulated activity. At least two Singapore-based full-time professionals.
• Fit and proper: All directors, shareholders, and representatives must satisfy MAS’s fit-and-proper criteria (Guidelines FSG-G01).
• Compliance arrangements: A compliance function appropriate to the scale and complexity of the business. Independent compliance becomes mandatory once AUM exceeds SGD 1 billion.
• Risk management framework: A documented framework for identifying, monitoring, and managing risks associated with assets under management.
• Internal and external audit: Internal audit arrangements and independent annual audits as required under the SFA.
• AML/CFT compliance: Full compliance with SFA04-N02, including customer due diligence, transaction monitoring, and suspicious transaction reporting obligations.
• Substantive activity: MAS requires genuine fund management activity to be conducted from Singapore — portfolio management, trade execution, or investment research. A conduit structure or purely administrative presence does not qualify.

Professional Indemnity Insurance (PII) is not mandatory for A/I LFMCs, though MAS requires disclosure to investors regarding PII arrangements or the absence of them. Many managers obtain PII as a matter of market practice.

The application processing time for an A/I LFMC is currently up to six months. MAS issues an in-principle approval at the end of the review, following which the applicant has a further six months to satisfy remaining conditions — including formalising appointments of key personnel and topping up share capital.

Choosing the Right Fund Management Licence

The decision between A/I LFMC and VCFM comes down to investment scope and investor access requirements. The decision to pursue a Retail LFMC involves a substantially higher compliance and capital commitment that is only justified if retail distribution is genuinely part of your business model.

Key questions to work through before applying:

• Will you ever manage assets in strategies other than venture capital? If yes, the A/I LFMC is the appropriate route.
• Do you need to serve retail investors? If yes, a Retail LFMC is required — and the compliance step-up is significant.
• Do you have the SGD 250,000 base capital plus a working buffer available from day one? This is a minimum, not a target.
• Can you demonstrate substantive fund management activity conducted from Singapore? MAS will scrutinise this.
• Are your CEO and key directors able to document the relevant regulated-activity experience MAS requires? Experience in non-regulated industries, regardless of seniority, does not count.

Singapore’s fund management licensing framework sits within a broader regulatory and corporate setup that includes corporate formation, banking and payment account setup, and ongoing AML and compliance obligations. Getting the licence is one milestone; maintaining full operational compliance across all these dimensions is the ongoing requirement.

For firms coming from adjacent regulated sectors — forex and FX, crypto and VASP, or iGaming — Singapore’s capital markets framework operates under a different regulatory authority and a distinct compliance architecture. A jurisdiction advisory exercise that maps your existing regulatory footprint to the Singapore CMS requirements is usually a sensible starting point.

Summary

The RFMC was a registration-based framework that allowed smaller fund managers to serve up to 30 qualified investors with a maximum of SGD 250 million in AUM, without holding a full CMS licence. It offered lighter reporting obligations and lower fees, at the cost of hard scale restrictions.

MAS repealed the RFMC regime on 1 August 2024. New fund managers in Singapore now apply directly for a CMS licence under one of three frameworks: the A/I LFMC for accredited and institutional investor-focused managers, the Retail LFMC for those serving retail investors, or the VCFM for pure venture capital strategies.

If you are reviewing this because a service provider or document still references RFMC registration as an available option, that information is out of date. The correct entry point for most new fund managers in Singapore is the A/I LFMC, with the VCFM available where the investment scope is strictly venture capital.