13O and 13U eligibility checker
Compare your fund’s inputs with the stated tax-track requirements for assets, spending and staffing. The result highlights matters for further assessment; it is not an approval decision.
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 |
Existing SFO awards
Four vintages sit under the same three sections. A pre-18Apr22 award keeps a flat S$200,000 spending condition and no floor; an 18Apr22 award keeps no floor but picks up tiered spending and capital deployment; a 5Jul23 award carries the S$20 million or S$50 million floor at each year-end; and an award approved on or after 1 August 2026 is tested at application and every year-end with a phase-in for headcount. Question 10 applies the right set. The full mapping is in which conditions apply to your SFO award.
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.
Discuss the applicable tax conditions
Use the result to outline your fund’s circumstances and request an introduction to a licensed manager or family-office specialist for an eligibility assessment.
Discuss your requirements →Frequently asked questions
Is the 13O minimum S$5 million or S$20 million?
The amount depends on the track. A non-SFO fund under a CMS-licensed fund management company has a S$5 million designated-investment entry requirement, with no annual re-test. A fund managed by an exempt SFO has a S$20 million requirement at application and each basis-period end. 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.