Singapore’s Family Office Boom — and Why Hiring Is the Hard Part
Singapore has emerged as the world’s fastest-growing family office destination. The Monetary Authority of Singapore (MAS) reports that the number of single-family offices (SFOs) receiving tax incentives under its fund schemes grew from around 400 in 2020 to well over 1,100 by the end of 2023 — a near-tripling in just three years. Ultra-high-net-worth families from China, Southeast Asia, India and Europe have established Singapore as the operational base for their wealth structures, attracted by political stability, rule of law, a zero capital gains tax regime and MAS’s credible regulatory environment.
But setting up a family office entity is only half the battle. Staffing it correctly — with investment professionals who hold the right work passes, in roles that comply with MAS licensing rules — is where many principals stumble. This guide walks through the employment pass options available to family office staff, the Personalised Employment Pass for senior investment hires, and the regulatory overlay that governs sensitive roles in Singapore’s financial sector.
The MAS Family Office Framework: Section 13O and Section 13U
Most Singapore family offices operate through a fund management vehicle that applies for tax exemption status under either Section 13O or Section 13U of the Income Tax Act. These two schemes differ in their asset under management (AUM) requirements, staffing conditions, and local business spending thresholds — and those staffing conditions directly determine the employment pass obligations of the family office employer.
Section 13O (Onshore Fund Tax Exemption Scheme): This scheme is available to Singapore-incorporated companies acting as fund vehicles. Under MAS guidelines updated in August 2023, 13O family offices must maintain a minimum AUM of S$10 million at inception (growing over time), employ at least two investment professionals — of whom at least one must be a Singapore citizen or permanent resident — and incur minimum local business spending of S$200,000 per year. The local hiring requirement means that a family office cannot staff itself entirely with foreign EP holders; at minimum one investment professional must be a Singapore national or PR.
Section 13U (Enhanced Tier Fund Tax Exemption Scheme): The 13U scheme imposes more stringent conditions in exchange for a broader universe of qualifying investments. The AUM threshold was raised to S$50 million (from S$20 million) under the August 2023 revisions. At least three investment professionals must be employed, of whom at least one must be a non-family-member Singapore citizen or permanent resident, and local business spending must reach S$500,000 per year. For families with significant complexity or multiple asset classes, 13U is often the preferred vehicle despite the higher bar.
For the authoritative conditions of both schemes, refer to the MAS Tax Incentive Schemes for Funds page, which is updated whenever conditions change.
Employment Pass for Family Office Hires
Most family office investment staff — portfolio managers, analysts, chief investment officers, relationship managers — will require an Employment Pass (EP). The EP is Singapore’s primary work authorisation for foreign professionals, and it carries specific salary thresholds that are higher in the financial services sector than in other industries.
As of 2025, the minimum qualifying salary for an EP in the financial services sector is S$6,200 per month for younger applicants, rising progressively with age: approximately S$8,500 at 30, S$10,500 at 35, and S$11,800 at 45 and above. These age-progressive thresholds reflect MOM’s intent to prevent the displacement of mid-career Singaporean professionals by younger, lower-cost foreign hires. Family offices, which often hire specialists in their 30s and 40s with niche expertise in private equity, hedge funds or alternative assets, will frequently be dealing with the higher bands of these thresholds.
EP applications for family office staff are assessed under the COMPASS framework (Complementarity Assessment Framework), which assigns points across four criteria: salary relative to local peers (C1), qualifications (C2), diversity of the employer’s existing workforce (C3), and support for local employment (C4). An applicant needs at least 40 points to pass. Applicants earning S$22,500 or more per month are exempt from COMPASS entirely — relevant for senior investment professionals commanding very high salaries. Refer to MOM’s EP eligibility page for the latest salary thresholds and COMPASS point tables.
For family offices, the COMPASS diversity criterion (C3) is worth understanding carefully. A small family office with, say, five foreign staff all of the same nationality will score zero on C3, potentially making it harder to pass for additional hires of that nationality. This is a genuine operational consideration when building out a family office team, and it reinforces the MAS 13O/13U requirement for at least one Singapore citizen or PR professional to be part of the headcount.
The Personalised Employment Pass: Ideal for Senior Investment Professionals
For family office principals’ key hires — the chief investment officer relocating from London or Geneva, the senior private equity partner moving from Hong Kong — the Personalised Employment Pass (PEP) often offers significant advantages over a standard EP.
The PEP is not tied to a specific employer. Unlike an EP, which is linked to the sponsoring company and must be cancelled and reapplied for if the holder changes jobs, a PEP allows the holder to switch roles without losing their work authorisation, and to remain in Singapore for up to six months between positions. This flexibility is attractive to family offices that are still finalising their structure, or to investment professionals who may be moving between the SFO vehicle and a related operating entity.
To qualify for a PEP, a candidate must either: (a) currently hold an EP and be earning at least S$22,500 per month; or (b) be an overseas professional with a last drawn fixed monthly salary of at least S$22,500. The PEP is valid for five years and cannot be renewed — after five years, the holder must either qualify again or switch to a standard EP. The holder is also required to earn at least S$144,000 within any calendar year while on the PEP to maintain it.
Note that PEP holders cannot start their own businesses or be self-employed — they must be employed by a Singapore-registered entity. For a family office principal who intends to be actively involved as an investor rather than an employee, a different immigration pathway (such as the Global Investor Programme administered by the Economic Development Board) may be more appropriate. Our team regularly advises families on the right pass structure for the principal versus the professional staff — contact us to discuss your specific situation.
Sensitive Roles and MAS Licensing
Family offices that conduct regulated activities — including managing a portfolio of investments on behalf of clients, dealing in capital markets products, or providing financial advice — must hold, or operate within an entity that holds, the appropriate MAS licence or registration.
Most single-family offices managing only the family’s own assets qualify as exempt fund managers under the Securities and Futures Act (SFA) and do not need to hold a Capital Markets Services (CMS) licence. However, if the family office manages assets for any external party — including extended family members or associates outside the immediate family — it may need to register as a Registered Fund Management Company (RFMC) or obtain a full CMS licence for fund management.
For family offices that are licensed or registered, the individuals who conduct regulated activities are classified as “representatives” under the SFA and must be appointed (and in some cases, individually approved by MAS) before they can carry out those activities. CEOs and directors of licensed entities may require prior MAS approval, particularly where the individual is subject to a fit and proper assessment. This regulatory overlay has significant hiring implications: a family office cannot simply onboard a new investment director and have them begin managing the portfolio on day one — the MAS approval process (where required) must be completed first.
Even for exempt fund managers, individuals performing investment management functions should be aware that Singapore’s regulatory environment is increasingly attentive to conduct standards in the family office sector, following high-profile cases involving inadequate AML controls. Family offices are expected to have robust AML/CFT policies, and the staff responsible for implementing these — typically a compliance officer — must be suitably qualified and empowered.
Building the Family Office Team: Practical Considerations
A well-structured family office typically requires several distinct functions: investment management (portfolio construction, manager selection, direct deal execution), family administration (accounting, treasury, reporting), risk and compliance (regulatory obligations, AML/CFT), and potentially family governance (succession, philanthropy, trust administration). Each function may require different pass types and has different regulatory sensitivity.
For investment staff, the EP and PEP routes described above are the primary options. For operations and administration roles that are less senior or that can be filled locally, a Singapore work permit, S Pass, or S Pass may apply — though given the typically small headcount of a family office, most hires will be EP-level. For principal family members who wish to reside in Singapore, a combination of the Global Investor Programme (for the principal) and Employment Passes (for professional staff) is common.
One consideration that surprises many families is the timeline. An EP application typically takes three to eight weeks from submission; MAS representative appointment, where required, can take several weeks on top of that. Families that need their investment team operational by a specific date — for example, to coincide with an MAS 13O/13U application milestone — need to plan their hiring well in advance.
If your family office is at the stage of hiring its first team in Singapore, our specialist team at Little Big Employment Agency (MOM Licence 19C9790) can advise on EP eligibility assessment, COMPASS scoring, and the coordination between MOM work pass and MAS regulatory timelines. Explore our wealth migration and family office services or speak to a consultant directly.
Key Takeaways
- MAS 13O and 13U family offices must employ at least one (13O) or two (13U) Singapore citizen/PR investment professionals — pure foreign teams do not satisfy the scheme conditions.
- EP financial services salary thresholds start at S$6,200/month and rise with the applicant’s age; COMPASS exemption applies above S$22,500/month.
- The Personalised Employment Pass is employer-independent and valid for five years — ideal for senior CIO-level hires who value flexibility.
- If the family office conducts regulated activities beyond managing the family’s own assets, MAS licensing and individual representative appointment requirements will apply and must be factored into hiring timelines.
- EP applications typically take three to eight weeks; allow additional time for MAS regulatory approvals where relevant.