MAS issued Revised Guidelines on Licensing and Conduct of Business for Fund Management Companies on 03 September 2025.

Difference in Old & Amended Guidelines are presented here in tabular form:

Old Guidelines (13 Jan 2025)

Amended Guidelines (3 Sep 2025)

2.3 Managed Assets: In determining the value of the assets being managed, an FMC should take note of the following:
2.3.1 An FMC providing advice or research to other investment managers should
report, as assets under the FMC’s non-discretionary management, the
moneys and assets contracted to the investment manager in respect of
which the FMC has an agreement to provide the fund management services.
In reporting these assets, the FMC should only include the portion that is attributable to it based on appropriate proxies such as the geographical or sectoral focus of the FMC; and
2.3.2 Moneys committed by investors but not drawn down should be excluded from the FMC’s managed assets.

2.3 Managed Assets: Assets under an FMC’s management means all of the following:
2.3.1 moneys and assets contracted to, or drawn down by the FMC, and are under the discretionary authority granted by the customer to the FMC, and in respect of which the FMC is carrying out fund management;
2.3.2 moneys and assets contracted to the FMC, and are under the non-discretionary authority granted by the customer to the FMC, and in respect of which the FMC is carrying out fund management;
2.3.3 moneys and assets contracted to the FMC, but which have been sub-contracted to another party and for which the other party is carrying out fund management, whether on a discretionary authority granted by the customer or otherwise.

A1 Minimum Staffing and Competency Requirements
(ii) Number of Directors:
Of these directors,
 • Number of Executive Directors: Executive Directors are involved full-time in the day-to-day operations of the company and should be resident in Singapore. There should be at least one Executive Director who has 5 years of experience in portfolio management that is relevant to the investment activities of the FMC and the asset classes and markets that it will invest in.

A1 Minimum Staffing and Competency Requirements
(ii) Number of Directors:
Of these directors,
 • Number of Executive Directors: Each Executive Director should:
i be involved full-time in the day-to-day operations of the FMC; and
ii be resident in Singapore.
While an FMC may have multiple Executive Directors, there should be at least one Executive Director who has 5 years of experience in portfolio management that is relevant to the investment activities of the FMC and the asset classes and markets that it will invest in. Every Executive Director must possess sufficient managerial and relevant experience for his/her intended role and responsibilities in the FMC.

A4 Requirements for Venture Capital Fund Managers
4.2 Admission & Ongoing Requirements –
(iii) Key personnel – Have at least two directors, at least one of whom should be full-time and resident in Singapore; and at least two full-time professionals and representatives resident in Singapore, who may include the directors. Nominee directors such as legal advisers or corporate secretaries will not count towards meeting this requirement.

A4 Requirements for Venture Capital Fund Managers
4.3 Admission & Ongoing Requirements –
(iii) Key personnel – A VCFM must have:
(d) a CEO, who should be employed full-time in the day-to-day operations of the company and be resident in Singapore;
(e) at least two directors, at least one of whom should be an Executive Director. Nominee directors such as legal advisers or corporate secretaries will not count towards meeting this requirement;.and
(f) at least two full-time professionals and representatives who are resident in Singapore.

There is no restriction on an individual to take on multiple appointments within a VCFM if there are synergies, e.g., the CEO can also be appointed as an Executive Director, professional and representative.

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