Who actually counts as a qualifying investment professional?

The definition

For the purposes of the 13O, 13OA and 13U schemes, the circular defines investment professionals (IPs) as portfolio managers, research analysts and traders who are Singapore tax residents, earn more than S$3,500 per month, and are "engaging substantially in the qualifying activity of fund management." All three conditions must hold at once: a trader earning S$3,000 a month does not count; a resident research analyst on a token, part-time allocation to the fund does not count; and a well-paid, resident portfolio manager whose actual job is something else — more on that below — does not count either. The 13D scheme uses the same three job titles but without the S$3,500 threshold spelled out for 13O/13OA/13U, and needs only one qualifying IP, phased in from YA 2028.

How many, on which track

Headcount depends on both the scheme and whether the fund sits on the non-SFO or SFO track:

• 13O/13OA, non-SFO: the FMC must employ at least 2 qualifying IPs throughout each basis period — as a transitional measure, this is only enforced from YA 2028 onward.
• 13U, non-SFO: at least 3 qualifying IPs, with no transitional relief stated in the circular for this headcount.
• 13O/13OA, SFO (awards approved from 1 August 2026): at least 2 qualifying IPs, of whom at least 1 must be a non-family member of the fund's beneficial owner(s). MAS allows the SFO to apply with just 1 qualifying IP (family member or not), but the SFO must reach 2 (including the non-family member) by the end of the first year-of-assessment's basis period.
• 13U, SFO (awards approved from 1 August 2026): at least 3 qualifying IPs, of whom at least 1 must be a non-family member. The SFO may apply with 2 qualifying IPs and must reach 3 (including the non-family member) by the end of the first year-of-assessment's basis period.

On the non-SFO track, a fund's IPs sit inside a licensed or exempt fund management company; on the SFO track, they sit inside the family office itself. Either way, headcount is tested throughout each basis period, not just at application.

What MAS actually expects an SFO's IPs to have done

Annex 11 of the circular carries two FAQs written specifically for single family offices, and they are more concrete than the headline definition. FAQ 10 describes the expected job roles: developing and implementing investment strategies, including building and managing portfolios; performing investment research and market analysis with buy/sell recommendations; and trading financial instruments, including liquidity management and deal structuring. It then lists roles MAS does not treat as qualifying IP work — financial planning and analysis, budgeting or capital account management; cashflow monitoring; legal documentation and fund wiring; tax planning support; and passing on or keying in orders (trade settlement or confirmation). An operations manager or a compliance officer performing any of these, however senior, is not a qualifying IP no matter how the role is titled internally.

FAQ 11 addresses experience and qualifications directly. MAS expects a qualifying IP to have either relevant experience — investment experience, including personal investment, or professional experience in a formal employment capacity in portfolio management, research analysis, trading, or M&A — or relevant academic qualifications: a degree or master's in accountancy, finance, economics, business administration/management or financial engineering (or a specialisation in one of these fields), a relevant diploma from a Singapore institution in the same areas, or a relevant professional certification such as CMFAS or CFA. Either route is sufficient on its own; MAS does not require both.

Common failure modes

The same handful of mistakes recur across SFO applications:

• Counting operations or compliance staff as IPs. FAQ 10's exclusion list exists precisely because families often try to count the people running the office, not the people running the portfolio.
• Part-time or non-resident hires. The definition requires Singapore tax residency and substantial engagement in fund management — a part-time adviser or an overseas-based portfolio manager does not satisfy either limb, whatever the title.
• A family-member-only bench on the SFO track. Both the 13O/13OA and 13U SFO conditions require at least 1 non-family qualifying IP once the fund is past its first-year concession. A family office staffed entirely by relatives never clears that bar, regardless of headcount.
• Assuming the concession removes the requirement rather than delaying it. Applying with 1 (13O/13OA) or 2 (13U) qualifying IPs is a bridge to full headcount by the end of the first year of assessment's basis period — not a permanently lower bar.

The revocation risk

The consequence of missing the first-year deadline is stated plainly: if the SFO fund does not reach the required headcount (including the non-family member) by the end of the basis period of the first YA of the award, "the award will be revoked with effect from the award commencement date" — retrospective revocation from day one, not merely a denial of the exemption going forward. The circular's own example makes the timeline concrete: an award commencing 1 August 2026 with a 31 December year-end requires the second qualifying IP in place by 31 December 2026 — a five-month runway to complete a hire that must also be a non-family member with demonstrable relevant experience or qualifications. In later years, the SFO must keep the required headcount throughout each basis period to avail itself of the exemption for that year; a later lapse costs that year's exemption but does not retrospectively unwind the award.