VCFM & the RFMC Repeal: The Venture Capital Fund Manager Regime
The VCFM licensing regime for qualifying venture-capital managers, its distinction from the RFMC regime repealed on 1 August 2024, and the available management arrangements.
A Venture Capital Fund Manager (VCFM) is a fund manager licensed by the Monetary Authority of Singapore (MAS) to manage qualifying venture capital funds under a lighter-touch regime than a full Licensed Fund Management Company (LFMC). It carries no regulatory minimum base capital and a faster MAS review — reflecting that VC funds invest in illiquid, non-retail private companies. Separately, the older Registered Fund Management Company (RFMC) regime was repealed on 1 August 2024; the two are often confused.
The VCFM and former RFMC frameworks address different activities. This guide distinguishes them and compares establishing a venture-capital management firm with appointing an existing permissible fund manager.
What is a VCFM and who is it for?
The VCFM regime is built for managers whose funds invest in early-stage and growth private companies. Because those investments are illiquid and the investors are sophisticated, MAS applies lighter prudential requirements: no minimum base capital, no risk-based capital ratio, and a simplified licensing process. The trade-off is scope — a VCFM may only manage qualifying VC funds (broadly, funds investing in unlisted business ventures, not freely traded securities, with restrictions on redemptions and investor type). A VCFM that wants to run liquid or retail strategies must convert to a full LFMC.
VCFM vs LFMC — what's the difference?
| Feature | VCFM | A/I LFMC |
|---|---|---|
| What it can manage | Qualifying VC funds only | Broad fund management (accredited/institutional) |
| Base capital | No regulatory minimum | S$250k |
| Risk-based capital | Not applied | ≥120% |
| SG-based professionals | ≥2 | ≥2 |
| MAS review | ~4 months | ~6 months |
| Compliance burden | Lighter | Fuller compliance function |
Assess whether the proposed strategy will remain within the qualifying venture-capital scope. Capital requirements and the cost of a later change in licensing category belong in the establishment plan.
Why was the RFMC regime repealed?
The Registered Fund Management Company was a general lighter-touch registration — not VC-specific — capped at S$250m AUM and 30 qualified investors. Over time MAS judged it redundant alongside the A/I LFMC and moved to simplify the framework. On 1 August 2024 the RFMC regime was repealed. Existing RFMCs were transitioned to A/I LFMC status through a streamlined Form 1AR process, and the old S$250 million AUM cap was removed in the process. New managers can no longer register as an RFMC.
Was the VCFM affected by the RFMC repeal?
No — and this is the most common point of confusion. The RFMC and the VCFM are different regimes. The RFMC was the general lighter-touch registration that has now been abolished. The VCFM is a separate, VC-specific licensing regime that remains current. If you manage qualifying VC funds, the VCFM is still very much available; only the RFMC is gone.
What changed for RFMCs after 1 August 2024?
- RFMC registration is closed to new applicants.
- Existing RFMCs moved to A/I LFMC status via the streamlined Form 1AR.
- The previous S$250m AUM cap no longer applies — transitioned managers can scale without that ceiling.
- The base capital floor for the resulting A/I LFMC is S$250k, with risk-based capital of at least 120%.
Should a VC manager establish a VCFM or use an existing manager?
Compare the resources required for a venture-capital management firm with the services and fees of an existing permissible fund manager. Confirm that the manager can support the proposed strategy. An appointment does not transfer its licence to the VCC sponsor or remove the need to assess the sponsor’s activities.
Launching a venture capital fund?
Describe the venture-capital strategy, investor base and proposed operating arrangements to request an appropriate specialist introduction.
Discuss your requirements →How this connects to the rest of your setup
The VCFM is one route to the "manager" building block in how to start a fund in Singapore; the wider licence map is on fund management licence: CMS, LFMC & VCFM. A VC fund typically pairs its manager with a VCC and a Section 13U or 13O tax exemption. Strategy-specific guidance lives on the venture capital VCC page.
Frequently asked questions
What is a Venture Capital Fund Manager (VCFM) in Singapore?
A VCFM is a fund manager holding a CMS licence granted under the simplified VCFM regime, confined to managing qualifying venture capital funds. The regime is lighter-touch than a full LFMC: there is no regulatory minimum base capital and MAS review is faster (around four months), reflecting that VC funds invest in illiquid, non-retail private companies.
When was the RFMC regime repealed?
The Registered Fund Management Company (RFMC) regime was repealed on 1 August 2024. Existing RFMCs were transitioned to Accredited/Institutional LFMC status through a streamlined Form 1AR process, and the old S$250 million AUM cap was removed.
Is a VCFM the same as an RFMC?
No. The RFMC was a general lighter-touch registration capped at S$250m AUM, now repealed. The VCFM is a separate licensing regime specifically for managers of qualifying venture capital funds. The VCFM was not affected by the RFMC repeal.
Does a VC fund need its own VCFM, or can it use an existing manager?
Either. A VC fund needs a MAS-regulated manager, but you can apply for your own VCFM licence or appoint an existing MAS-licensed Permissible Fund Manager and launch your VCC with that firm managing the fund — avoiding the application wait.
VCC Singapore is an independent informational resource and is not a regulator, law firm or tax adviser. The VCFM qualifying criteria and the RFMC transition rules are set by MAS and change periodically — confirm the current position before acting. This page is general information, not legal, tax or financial advice.