Family Office Singapore: MAS Staffing Requirements for Investment Professionals Under 13O and 13U
Setting up a family office in Singapore comes with a hiring obligation many founders underestimate until well into the application process.
The Monetary Authority of Singapore ties its two main tax incentive schemes, Section 13O and Section 13U, directly to how many investment professionals a family office employs.
Get the staffing requirement wrong, and the tax exemption that made a Singapore family office attractive in the first place is at risk.
This guide breaks down exactly who a family office in Singapore must hire under each scheme, what qualifies as an investment professional, and how the 2026 framework changes affect staffing decisions.
The Monetary Authority of Singapore ties its two main tax incentive schemes, Section 13O and Section 13U, directly to how many investment professionals a family office employs.
Get the staffing requirement wrong, and the tax exemption that made a Singapore family office attractive in the first place is at risk.
This guide breaks down exactly who a family office in Singapore must hire under each scheme, what qualifies as an investment professional, and how the 2026 framework changes affect staffing decisions.
What Are the 13O and 13U Tax Incentive Schemes?
Section 13O and Section 13U are MAS-administered tax exemption schemes for qualifying funds managed by Singapore family offices.
Both exempt specified investment income, including gains from equities, bonds, and funds, from Singapore tax, though the schemes target different fund sizes.
Section 13O requires a minimum of S$20 million in designated investments at the point of application, maintained throughout the incentive period.
Section 13U is aimed at larger family offices, requiring a minimum of S$50 million in designated investments, and additionally allows investment into Singapore-incorporated companies without some restrictions that apply under 13O.
A fuller comparison of how these schemes fit into the broader Singapore family office landscape is covered in this guide to family office structure, regulations, and benefits, alongside a dedicated breakdown of tax and regulatory incentives.
Both exempt specified investment income, including gains from equities, bonds, and funds, from Singapore tax, though the schemes target different fund sizes.
Section 13O requires a minimum of S$20 million in designated investments at the point of application, maintained throughout the incentive period.
Section 13U is aimed at larger family offices, requiring a minimum of S$50 million in designated investments, and additionally allows investment into Singapore-incorporated companies without some restrictions that apply under 13O.
A fuller comparison of how these schemes fit into the broader Singapore family office landscape is covered in this guide to family office structure, regulations, and benefits, alongside a dedicated breakdown of tax and regulatory incentives.
Minimum Staffing Requirements Under 13O
A family office applying under Section 13O must employ at least 2 investment professionals, with at least 1 required to be a non-family member.
New applicants typically get a 12-month grace period to complete the second hire, giving newly formed offices some runway to recruit.
Each investment professional must earn a monthly salary above S$3,500, dedicate more than half their working time to qualifying investment activities, and remain a Singapore tax resident throughout the incentive period.
Professionals generally need to hold a CFA, CPA, or MAS-recognised equivalent qualification, or demonstrate relevant portfolio management experience. Qualified family members can count toward this requirement too.
New applicants typically get a 12-month grace period to complete the second hire, giving newly formed offices some runway to recruit.
Each investment professional must earn a monthly salary above S$3,500, dedicate more than half their working time to qualifying investment activities, and remain a Singapore tax resident throughout the incentive period.
Professionals generally need to hold a CFA, CPA, or MAS-recognised equivalent qualification, or demonstrate relevant portfolio management experience. Qualified family members can count toward this requirement too.
Minimum Staffing Requirements Under 13U
Section 13U raises the staffing bar. A family office applying under this scheme must employ at least 3 investment professionals.
At least 1 of the three must be a non-family member, and MAS expects at least one of the professionals to serve as a senior decision-maker for the fund’s investment activities.
The same salary, time-commitment, and tax residency conditions that apply under 13O also apply under 13U.
Because 13U family offices tend to run more complex, globally diversified portfolios, MAS places extra weight on demonstrated investment decision-making experience at this level.
Local business spending obligations also scale with fund size under both schemes, with larger family offices expected to contribute more to the local economy through operating expenditure, philanthropy, or eligible grants.
These spending requirements sit alongside Singapore’s broader suite of industry-specific tax incentives, which family offices should review when planning their overall tax position.
At least 1 of the three must be a non-family member, and MAS expects at least one of the professionals to serve as a senior decision-maker for the fund’s investment activities.
The same salary, time-commitment, and tax residency conditions that apply under 13O also apply under 13U.
Because 13U family offices tend to run more complex, globally diversified portfolios, MAS places extra weight on demonstrated investment decision-making experience at this level.
Local business spending obligations also scale with fund size under both schemes, with larger family offices expected to contribute more to the local economy through operating expenditure, philanthropy, or eligible grants.
These spending requirements sit alongside Singapore’s broader suite of industry-specific tax incentives, which family offices should review when planning their overall tax position.
The 2026 Framework Simplification: What Changed for Staffing
Singapore significantly simplified its family office licensing framework effective 15 June 2026, moving from individual MAS approvals to an automatic class exemption model.
Family offices now qualify automatically by notifying MAS on commencement, banking with a MAS-licensed institution, and filing annual asset and banking disclosures.
Alongside this, MAS introduced a new equity flexibility rule: non-family professionals in key roles like CEO, CFO, or investment head can now hold up to 10% ownership as a performance incentive, something previously blocked under wholly family-owned ownership requirements.
Their personally managed assets are separately capped at 10% of the family office’s total assets under management.
MAS also introduced a five-generation beneficiary cap, requiring all qualifying family beneficiaries to fall within five generations of a common ancestor.
Existing family offices have until 15 June 2027 to comply with the new framework, while offices formed after 15 June 2026 must comply immediately.
These structural changes are explored in more depth in this guide to setting up a family office in Singapore, and the ownership flexibility is particularly relevant when deciding between a single-family office and a multi-family office structure.
Family offices now qualify automatically by notifying MAS on commencement, banking with a MAS-licensed institution, and filing annual asset and banking disclosures.
Alongside this, MAS introduced a new equity flexibility rule: non-family professionals in key roles like CEO, CFO, or investment head can now hold up to 10% ownership as a performance incentive, something previously blocked under wholly family-owned ownership requirements.
Their personally managed assets are separately capped at 10% of the family office’s total assets under management.
MAS also introduced a five-generation beneficiary cap, requiring all qualifying family beneficiaries to fall within five generations of a common ancestor.
Existing family offices have until 15 June 2027 to comply with the new framework, while offices formed after 15 June 2026 must comply immediately.
These structural changes are explored in more depth in this guide to setting up a family office in Singapore, and the ownership flexibility is particularly relevant when deciding between a single-family office and a multi-family office structure.
Hiring Investment Professionals: Employment Pass Considerations
Non-family investment professionals who aren’t Singapore citizens or permanent residents typically need an Employment Pass to work at the family office.
Every Employment Pass application must clear MOM’s COMPASS framework, requiring a minimum score of 40 points across salary, qualifications, diversity, and local employment support criteria.
Financial services roles face higher qualifying salary thresholds than general Employment Pass categories, reflecting the sector’s typically higher compensation benchmarks.
Holding a CFA, CPA, or equivalent qualification strengthens an applicant’s COMPASS score under the qualifications criterion, on top of satisfying the 13O or 13U professional requirement itself.
Family offices should also factor in Employment Pass processing time when planning their hiring timeline, since approval can take several weeks and delays can push back the fund’s application deadline.
Given how the immigration and tax incentive requirements interact, many family offices bring in specialist family office and private client advisory support to align hiring plans with both MAS and MOM requirements from the outset.
Every Employment Pass application must clear MOM’s COMPASS framework, requiring a minimum score of 40 points across salary, qualifications, diversity, and local employment support criteria.
Financial services roles face higher qualifying salary thresholds than general Employment Pass categories, reflecting the sector’s typically higher compensation benchmarks.
Holding a CFA, CPA, or equivalent qualification strengthens an applicant’s COMPASS score under the qualifications criterion, on top of satisfying the 13O or 13U professional requirement itself.
Family offices should also factor in Employment Pass processing time when planning their hiring timeline, since approval can take several weeks and delays can push back the fund’s application deadline.
Given how the immigration and tax incentive requirements interact, many family offices bring in specialist family office and private client advisory support to align hiring plans with both MAS and MOM requirements from the outset.
Structuring Your Family Office Team Around These Rules
Staffing decisions shouldn’t be made in isolation from the family’s longer-term succession plans.
A senior investment professional hired today may eventually need to hand over decision-making authority as the next generation becomes involved in the office.
Thinking through how succession planning works within a Singapore family office early helps avoid restructuring the investment team later simply to satisfy governance or incentive scheme conditions.
A senior investment professional hired today may eventually need to hand over decision-making authority as the next generation becomes involved in the office.
Thinking through how succession planning works within a Singapore family office early helps avoid restructuring the investment team later simply to satisfy governance or incentive scheme conditions.
Frequently Asked Questions
1. How many investment professionals does a Section 13O family office need?
At least 2, with at least 1 required to be a non-family member, though new applicants typically get a 12-month grace period for the second hire.
2. How many investment professionals does a Section 13U family office need?
At least 3, including at least 1 non-family member, with MAS expecting one professional to act as a senior investment decision-maker.
3. What qualifications do family office investment professionals need in Singapore?
Most need a CFA, CPA, or MAS-recognised equivalent qualification, or demonstrated relevant investment or portfolio management experience.
4. Do foreign investment professionals need an Employment Pass to work at a Singapore family office?
Yes, unless they’re Singapore citizens or permanent residents, and their application must clear MOM’s COMPASS framework with a minimum score of 40 points.
Yes, unless they’re Singapore citizens or permanent residents, and their application must clear MOM’s COMPASS framework with a minimum score of 40 points.
5. What changed in Singapore's family office framework in 2026?
MAS moved to an automatic class exemption model from 15 June 2026, introduced a 10% equity allowance for non-family key executives, and added a five-generation beneficiary cap.
Conclusion
Staffing is not a formality when setting up a family office in Singapore; it’s a binding condition tied directly to the 13O and 13U tax exemptions.
The 2026 framework changes have added flexibility around equity ownership, but the core investment professional headcounts under both schemes remain firmly in place.
Family offices weighing these requirements alongside immigration considerations for foreign hires should seek advice early, since misaligned staffing and hiring plans are costly to unwind after an application is submitted.
Reviewing the broader benefits of setting up a family office in Singapore alongside these staffing rules helps ensure the structure remains worthwhile once compliance costs are factored in.
The 2026 framework changes have added flexibility around equity ownership, but the core investment professional headcounts under both schemes remain firmly in place.
Family offices weighing these requirements alongside immigration considerations for foreign hires should seek advice early, since misaligned staffing and hiring plans are costly to unwind after an application is submitted.
Reviewing the broader benefits of setting up a family office in Singapore alongside these staffing rules helps ensure the structure remains worthwhile once compliance costs are factored in.
