Most guidance on Singapore family offices stops at the point of approval — how to qualify for Section 13O or 13U, what AUM and headcount you need, which structure to use. Far less is written about what happens after: the five conditions MAS and ACRA expect a family office to keep meeting for the full five-to-ten-year life of the exemption, not just on the day of the application.
Miss one of these on an ongoing basis and the risk is not a warning letter — it is clawback of the tax exemption itself, retroactively. What makes this genuinely hard is that the five conditions land on different desks: a portfolio and finance problem, a governance and company-secretary problem, and a fund-accounting problem, each tracked in a different system that was never built to talk to the others. This is the map of all five, with a full breakdown of each linked below.
The five things MAS and ACRA check after approval
- The Capital Deployment Requirement (CDR) — a minimum share of AUM held in MAS-specified local investments, at all times.
- Local Business Spending (LBS) — a minimum annual spend on qualifying Singapore-based costs, verified every year.
- A UBO register kept current, with any change reported to ACRA within two business days.
- VCC sub-fund segregation — no commingling or cross-liability between sub-funds sharing an umbrella.
- Evidence, on renewal, that the AUM test, headcount, LBS and CDR were met throughout the period — not just at the last measurement date.
The spend and investment thresholds — CDR and LBS
CDR and LBS are both running-total problems: a minimum share of AUM in local investments, and a minimum annual spend on local costs, both drifting all year rather than sitting still until a year-end check. They fail the same way — someone reconciles them once, at renewal, instead of watching the ratio move — and they hit the same desk: whoever owns the portfolio and the P&L. Read the full breakdown of CDR and LBS, including why an offshore administrator's invoice never counts toward LBS no matter how legitimate it is.
Governance — the UBO register and the 2-business-day ACRA SLA
This is the one with no grace period. Any change to who beneficially owns or controls a Singapore-incorporated entity must be reported to ACRA within two business days of the change — not the quarter it was noticed. It is a company-secretary and governance problem, not an accounting one, and it is the requirement most likely to be missed simply because nobody started the clock. Read the full breakdown of the UBO register and the ACRA deadline.
Structure — VCC sub-fund segregation and the annual renewal pack
If your family office runs a VCC umbrella with several sub-funds, the regulatory promise is that they carry no cross-liability — but that only holds if the ledger enforces it, not just the paperwork. And whatever CDR, LBS, headcount and AUM evidence you've gathered over the year eventually needs to become a single renewal pack for MAS, per sub-fund if the structure calls for it. Both are fund-accounting problems, and they compound each other at renewal time. Read the full breakdown of VCC segregation and the renewal pack.
What a missed condition actually costs
A CDR ratio that drifts below threshold for a quarter, an LBS shortfall discovered in December, a UBO change filed on day four instead of day two — none of these are hypothetical edge cases for a busy family office running everything across spreadsheets, email and three different advisers. Each is a plausible finding at the next MAS-appointed screening review, and the consequence is not a fine — it is clawback of the exemption that was the entire reason for the structure. aama.io's family office platform tracks all five conditions in one place, on top of the fund accounting you already run, so the evidence exists before anyone asks for it.
This guide is general information, not tax, legal or regulatory advice. CDR and LBS thresholds, AUM floors and renewal cadences reflect MAS/IRAS requirements as understood in 2026 and are revised periodically — confirm the current conditions with MAS, ACRA and a licensed tax adviser before relying on them. For the underlying 13O/13U conditions, see Section 13O vs 13U (2026).
Running a Singapore family office under 13O or 13U? See how aama.io tracks CDR, LBS, UBO and VCC sub-fund compliance alongside your fund accounting in one platform, or book a walkthrough with our team to see it on your own structure.