How to Set Up an External Asset Manager (EAM) in Singapore
The CMS / LFMC licence, base capital, headcount, custody onboarding, timeline and costs to launch your own independent asset-management firm.
Setting up an external asset manager (EAM) in Singapore means establishing a MAS-regulated fund-management company that can manage client portfolios held at custodian banks. In practice that requires a Capital Markets Services (CMS) licence to carry on fund management, almost always held as a Licensed Fund Management Company (LFMC) for accredited and institutional investors. The core requirements are a S$250,000 base capital, at least two Singapore-based professionals, risk-based capital of at least 120%, and a credible compliance and risk framework. Custody relationships with private banks are arranged separately and run on their own onboarding timeline.
The establishment plan should cover licensing, staff, capital and custody relationships, together with the time and continuing cost involved. The final section considers a VCC with an appointed manager as a distinct operating arrangement.
Which licence does an EAM need?
The licence depends on who your clients are:
- A/I LFMC — serves only accredited and institutional investors. Base capital S$250,000. This is the standard route for an EAM serving high-net-worth families and is what most independent shops hold.
- Retail LFMC — needed to serve retail investors. Base capital S$500,000 (S$1m if managing retail collective investment schemes), with heavier compliance. Most EAMs do not need this.
- VCFM — the Venture Capital Fund Manager regime, for managers running qualifying VC funds only, with no regulatory minimum capital and a lighter review.
Since the RFMC regime was repealed on 1 August 2024, the old "registered" tier no longer exists for new entrants — the A/I LFMC is the baseline.
What people and capital do you need?
Prepare evidence of the proposed staff, capital and operating arrangements:
- At least two full-time, Singapore-based professionals — directors and appointed representatives — with relevant fund-management experience and fit-and-proper standing.
- S$250,000 base capital maintained on an ongoing basis, plus risk-based capital of at least 120%.
- A compliance and risk framework: a compliance function (in-house or outsourced to a specialist), AML/CFT procedures, and independent annual audit.
- Professional indemnity insurance and proper books, records and custody arrangements.
How does custody-account onboarding work?
An EAM does not hold client money — the assets sit at a custodian private bank in the client's name, with the EAM trading under a Limited Power of Attorney. You therefore need to be onboarded as an approved EAM by one or more custodian banks, each of which runs its own due diligence on your firm, principals and compliance. This can take weeks to months and is worth starting early. Which banks actively support EAMs, and how onboarding differs between them, is covered in our guide to custody account opening for EAMs.
How long does it take and what does it cost?
Allow for company incorporation, recruitment, compliance preparation and custody onboarding as well as the licensing review. The indicative MAS review period below assumes a complete application. Budget separately for capital held by the firm, professional fees, systems, staffing, premises, audit and continuing compliance.
Discuss an EAM establishment plan
Describe the proposed activities, client base and team to request an introduction for fund management or establishment support.
Discuss your requirements →A VCC with an appointed fund manager
A VCC platform can have an existing permissible fund manager. That appointment does not authorise a separate EAM to perform regulated activities without the required licence or exemption. Assess the intended role before choosing between establishing a licensed firm and using a sub-fund platform. Consider 13O/13U eligibility separately.
Frequently asked questions
What licence do you need to set up an EAM in Singapore?
An external asset manager in Singapore generally needs a Capital Markets Services (CMS) licence to conduct fund management, held as a Licensed Fund Management Company (LFMC) for accredited and institutional investors (A/I LFMC). The A/I LFMC carries a base capital requirement of S$250,000 and must maintain risk-based capital of at least 120%.
How long does it take to set up an EAM in Singapore?
Expect roughly six months for an A/I LFMC application from a complete submission to MAS approval, plus time to incorporate the company, hire staff and open custody accounts. Custody-account onboarding at private banks can run in parallel but adds its own due-diligence timeline.
How many staff does an EAM need in Singapore?
MAS expects an LFMC to have at least two full-time, Singapore-based professionals (directors and representatives) with relevant experience, plus appropriate compliance and risk arrangements. Many new EAMs also outsource compliance support to a specialist firm to meet expectations.
Does appointing a fund manager extend its licence to the EAM?
No. The appointed fund manager retains responsibility for its regulated activities. A separate EAM must assess its own activities and licensing requirements; a VCC platform appointment is not a transfer of the manager’s licence.
VCC Singapore is an independent informational resource and is not a regulator, law firm or tax adviser. Licensing capital, headcount and timelines are set by MAS and change periodically — confirm current figures before applying. This page is general information, not legal, tax or financial advice.