13O / 13U Eligibility Checker: which track, which scheme, which floor
Answer nine questions and see the scheme your fund fits, the minimum you must hold in designated investments on your track, the spending tier, the headcount — and every gap between you and the award.
Your fund
Your result
Non-SFO track: S$5 million (13O/13OA) or S$50 million (13U) at application, no annual re-test; two qualifying professionals at the manager for 13O (enforced from YA 2028), three for 13U; LBS tiers S$200k / 300k / 500k by AUM band. SFO track: S$20 million (13O/13OA) or S$50 million (13U) at application and every basis-period end; at least one non-family professional; spending tiers S$200k / 500k / 1M; capital deployment of the lower of 10% of AUM or S$10 million; private-banking account throughout.
How the two tracks compare
| Condition | Non-SFO track (licensed manager) | SFO track (family-managed) |
|---|---|---|
| 13O / 13OA minimum | S$5 million in designated investments at application; no annual re-test | S$20 million at application and every basis-period end |
| 13U minimum | S$50 million for the whole structure; no annual re-test | S$50 million at application and every basis-period end |
| Investment professionals | 2 at the manager for 13O/13OA (enforced from YA 2028); 3 for 13U | 2 for 13O/13OA, 3 for 13U, at least one non-family |
| Local spending | S$200k / 300k / 500k by AUM band (transitional S$200k total-spending test until YA 2028) | S$200k / 500k / 1M by AUM band, donation top-ups above hard floors |
| Capital deployment | None | Lower of 10% of AUM or S$10 million a year into Singapore-linked assets |
| Private-banking account | Not a condition | Required with an MAS-licensed bank throughout |
Read the full demarcation in one statute, two tracks, the floors in what is the minimum AUM to run a VCC, and the asset list in designated investments and specified income. Estimate what compliance costs with the family office cost calculator or the VCC cost calculator.
Get the application filed on the right track
Send us your result. We will confirm the scheme, the floor and the conditions for your structure, and connect you with MAS-licensed fund managers or a family-office specialist where it fits.
Speak to a specialist →Frequently asked questions
Is the 13O minimum S$5 million or S$20 million?
It depends on the track. A fund managed by a licensed or registered fund management company needs S$5 million in designated investments at application, with no annual re-test. A fund managed by the family’s own exempt single family office needs S$20 million at application and at the end of every basis period. Section 13U is S$50 million on both tracks.
What counts toward the minimum?
The gross value of designated investments — listed and unlisted shares, bonds, fund units, derivatives, deposits with banks and approved financial institutions, non-Singapore real estate and certain commodities. Loans taken to finance those investments need not be deducted. Singapore property does not count, and for family offices the Singapore-linked assets used for the capital deployment requirement sit outside the minimum.
Can a drawdown fund apply before its capital is called?
Yes, under the closed-end fund election in FDD Cir 05/2026: total committed capital, called and undrawn, counts toward the entry floor, and there is no ongoing size test afterwards. The election is irrevocable and carries its own conditions, so read the election guide before relying on it.
What if my fund is below the floor?
Three routes: run the strategy as a sub-fund of an umbrella VCC whose combined assets clear the floor; launch under a licensed manager’s platform and apply once the book grows; or, for families below S$20 million, use a multi-family office on the non-SFO track, which qualifies from S$5 million.
Does this checker replace advice from MAS?
No. It applies the published thresholds to your answers to show the likely scheme and the gaps. MAS assesses each application on its facts, conditions change by circular, and awards granted before July 2023 keep their vintage conditions. Confirm the current position with MAS and a qualified adviser before applying.
VCC Singapore is an independent informational resource and is not a regulator, law firm or tax adviser. This checker gives general guidance based on published MAS thresholds and is not legal, tax or financial advice.