Which SFO rulebook binds your award? The four condition vintages

The short answer

Every single family office fund holding an S13O, S13OA or S13U award sits in one of four condition "vintages," fixed by the date the SFO first submitted a preliminary submission, an S13O/U Eligibility Form, or a formal application form to MAS — whichever came first. The vintage decides your fund's AUM in DI minimum, its qualifying investment professional ("IP") headcount, and how local spending, the Capital Deployment Requirement ("CDR") and the banking-account condition apply. From 1 August 2026, MAS has layered modified conditions on top of all four vintages, but not identically — some elements are grandfathered, others are not. Pull your original submission date and your letter of award and match them against the table below; the rest of this article, and your compliance calendar, follows from that one fact.

The four vintages, precisely defined

Since 2022, MAS has revised the economic conditions attached to 13O, 13OA and 13U awards for SFO funds three times, and each time grandfathered the core entry conditions — AUM in DI minimum and IP headcount — that applied when a fund first qualified. The circular and its annexes name the resulting vintages by the date of the SFO fund's earliest submission to MAS — a preliminary submission, an S13O/U Eligibility Form, or a formal application form, whichever was lodged first:

• Pre-18Apr22 conditions — earliest submission before 18 April 2022.
• 18Apr22 conditions — earliest submission on/after 18 April 2022 but before 5 July 2023.
• 5Jul23 conditions — earliest submission on/after 5 July 2023, award approved before 1 August 2026.
• New awards — approved on/after 1 August 2026, covered in our August 2026 overview of FDD Cir 05/2026. The circular notes these are, in substance, the same as the revised 5Jul23 conditions, with one difference: a new applicant must clear the AUM in DI bar at application itself, whereas an existing 5Jul23-vintage fund is only re-tested at each year-end.

The vintage is fixed at the moment MAS first received a submission and does not move even if formal approval came much later — it has nothing to do with your financial year-end or incorporation date.

What each vintage actually requires from the YA ending on or after 1 August 2026

SFO funds with existing awards under any of the first three vintages become subject to a modified set of conditions from the Year of Assessment ("YA") whose basis period ends on or after 1 August 2026, unless MAS notifies the fund otherwise in writing — but per Annexes 6B and 7B, the modification is not uniform:

The practical surprise is in the middle two rows: an SFO fund that applied before 5 July 2023 does not suddenly need S$20 million or S$50 million of AUM in Designated Investments just because 1 August 2026 has arrived — that threshold binds only the 5Jul23 and new-award vintages (well above the non-SFO track's S$5 million and S$50 million entry points, so never assume the numbers are interchangeable). What every fund from the 18Apr22 vintage onward does pick up is the tiered local spending table and the CDR — new obligations for a fund that may never have had to meet them before. That spending condition can be partly met at the two upper tiers through eligible donations to Singapore-registered charities, exempt charities or Institutions of Public Character (excluding MCCY Grantmakers), and grants to blended-finance instruments distributed by MAS-licensed financial institutions, counted at twice their value, provided a minimum local business spending ("LBS") floor is still met in cash.

The banking-account condition: old awards versus new

Banking is the one condition that splits by what your specific letter of award says, not just by vintage, per Annexes 6B and 7B. If your existing letter of award already requires a private banking account with an MAS-licensed financial institution throughout each basis period, nothing changes. If it does not, your fund must now maintain a banking account, or private banking account, with an MAS-licensed financial institution throughout the basis period, with a three-month grace period from 1 August 2026 to open one — failing which the award may be revoked from the end of that grace period. Where a fund's first basis period ending on/after 1 August 2026 itself falls within that window, it still gets the full three months, running from the grace period's expiry. A new award carries the condition from the point of application, with no grace period. For 13U structures, it is met if at least one approved entity within the structure holds the requisite account.

Falling below the AUM in DI floor: lose the year, not the award

For 5Jul23-vintage and new SFO funds, dipping below S$20 million (13O/OA) or S$50 million (13U) of AUM in DI at year-end has a narrower consequence than many families assume. Per Annex 11's FAQ on this point, the fund simply cannot avail itself of the exemption for the basis period of the shortfall — it does not, on its own, trigger revocation. The fund can requalify in any later basis period where its AUM in DI is back at or above the minimum and all other conditions are separately met. Each year is tested on its own terms: no cumulative catch-up, but also no recovering the year that was missed.

Finding your vintage: what to pull from the file

Locate two documents. First, the earliest dated correspondence with MAS on the incentive application — preliminary submission, Eligibility Form, or formal application, whichever is earliest — fixes the vintage regardless of when the award was approved. Second, the letter of award itself, specifically whether it already contains a banking-account condition, since that clause decides whether the grace period applies at all. Between those two documents and the table above, a family office should be able to state with confidence which minimums, spending tiers and banking rule govern its award. For edge cases MAS has not spelled out in full — a mid-vintage change of fund manager, or a switch between the S13O/OA and S13U schemes — confirm directly with MAS or a licensed adviser, and revisit your fund's broader family office requirements at the same time, since IP headcount and banking-account conditions interact with the SFO's licensing exemption position.