Can both IPs be family members?

No. The 2026 standard requires at least one of the two IPs to be a non-family member — an individual who is not a beneficial owner of the family fund. One family member with the right qualifications and buy-side experience can fill one of the two seats; the other seat must be a third-party hire.

How does the one-year grace period for the second IP work?

If only one IP is in place at the time of application, MAS allows a one-year grace period to hire the second IP. The grace is a one-time bridge to the steady-state two-IP condition; it is not a permanent waiver, and prolonged shortfalls after the grace expires trigger MAS engagement. The practical posture is to dimension the IP hire plan for two professionals from year one and use the grace only where a specific phasing rationale supports it.

How long does the IP build typically take?

The practical timeline from a decision to build a Singapore family office to two qualifying IPs in seats is rarely less than six months and often closer to twelve. Lateral hires from Singapore asset managers or private banks are fastest where supply allows; international relocations on an EP run three to six months when handled efficiently. The IP build is the gating timeline for the 13O application.

Are family member IPs paid at market rates?

Yes — MAS expects market-rate compensation for IPs regardless of family relationship. Sub-market compensation for a family member IP raises questions about whether the role is genuine. The MAS substance review reads the entire compensation package (salary plus bonus plus benefits, against the market for senior investment professionals in Singapore) rather than the family relationship alone.

How does Anlian Group support 13O preparation including the IP layer?

Anlian Group Pte. Ltd. (ACRA Corporate Service Provider FA20200346) supports the corporate-structure side of the 13O preparation — Singapore incorporation of the SFO and the fund vehicle, ACRA filings, registered office, and the documentation chain MAS expects to see. The licensed fund management work touching the 13O scheme itself runs through Anlian Capital Pte. Ltd. (UEN 202224273H, MAS Capital Markets Services Licence CMS101702). For the IP hire layer, Employment Pass sponsorship and COMPASS coordination for inbound IPs runs through Dahe Private Ltd. (UEN 202005455G, Employment Agency Licence EA20C0327). The three workstreams are run in coordination because the IP build, the corporate structure, and the EP timeline all gate the 13O application.

Article

MAS 13O Investment Professional Requirements 2026: What "Two IP" Really Means for International Family Office Applicants

In one sentence

Two qualifying Investment Professionals, employed full-time in Singapore, with identifiable buy-side experience and at least one non-family — that is the 2026 substance standard MAS applies to every Section 13O application.

Quick answer

Headcount: at least two Investment Professionals employed throughout the basis period under the post-1 January 2025 framework. A one-year grace period applies for the second IP where only one is in place at application; the grace is a one-time bridge, not a permanent waiver.
Qualification: CFA charter, a recognised MBA, a relevant master's in finance/accounting/economics, or a qualification approved by MAS on application. Of these, CFA + ≥3 years of buy-side experience is the cleanest documentary path.
Experience: identifiably buy-side — portfolio management, investment analysis, fund management at an asset manager, sovereign wealth fund, pension fund, endowment, or another family office. The 2025 update excludes purely advisory or sell-side roles.
Local employment: full-time in Singapore, tax-resident, paid at market rates for senior investment professionals. The Employment Pass regime under COMPASS is the practical gating mechanism for non-citizen IP hires.
Independence: at least one of the two IPs must be a non-family member — an individual who is not a beneficial owner of the family fund. The intent is to prevent the requirement being satisfied entirely by family members with qualifications but no independent professional judgement.

Why this matters in 2026

Section 13O of the Singapore Income Tax Act is, to most international principals, a piece of paperwork. It is the tax exemption that makes a Singapore family office structure tax-efficient on specified investment income for the family fund managed by the Single Family Office (SFO). To the Monetary Authority of Singapore (MAS), which administers the incentive jointly with the Inland Revenue Authority of Singapore (IRAS), it is something more demanding: a substance test that asks whether the structure does what it says it does.

The substance test pivots on people. The 2026 standard, articulated in MAS's updated 13O application guidance and reinforced by the changes that took effect through 2025, requires a 13O-approved family office to employ at least two Investment Professionals (IPs) who meet specific qualification and experience criteria. MAS announced the first significant tightening in July 2023, requiring two IPs and increasing local business spending. A 2025 update sharpened the qualification criteria for the second IP and reinforced the local employment expectation. International coverage framed the 2025 tightening as part of MAS's response to capital inflows from Greater China and the Gulf — a substance-over-form recalibration rather than a closing of the door.

The application is the easy part; compliance is where structures most often fail. For international principals, the question is not whether to apply for 13O but whether the structure can sustain the IP headcount over the multi-year window during which the incentive matters. Families combining 13O with [the GIP Option B family office route at S$25M AUM](/insights/gip-2026-three-tier-restructure) or with [the Option C bundled PR pathway](/insights/gip-option-c-13o-bundled-pr-pathway) should treat the IP build as the central design constraint, not a hiring problem to be solved after MAS award. The phrase "Two IP" gets used loosely in family office marketing; in practice, it carries more weight than the headline suggests.

The fundamentals

The Section 13O statutory basis and MAS application path

Section 13O sits in the Singapore Income Tax Act and grants tax exemption on specified income derived by an approved company from designated investments. The companion incentive, Section 13U (formerly 13X), applies to enhanced-tier funds with higher asset and business spending thresholds. The two incentives sit on a continuum: 13O for smaller family funds, 13U for larger ones. The IP requirements are similar in shape but differ in number and detail.

The application process is administered by MAS, with IRAS confirming tax positions. Applications are reviewed on a fact-and-circumstance basis; there is no formula that yields automatic approval. The MAS application form, available through the regulator's family office desk, requires disclosure of the fund's investment strategy, projected asset base, operating budget, employment plan, and family ownership chain — the most documented family office application path in Asia.

The 13O approval is conditional. The fund must continue to meet the conditions for the duration of the incentive. MAS conducts periodic reviews, and the post-2024 supervisory posture is more active than the pre-2023 baseline, with the regulator increasing on-site engagement with approved family offices.

What "Two IP" now means — qualification, experience, independence

The minimum of two IPs is the headline. The substance of the rule is what counts as an IP. MAS's 2026 standard defines an IP by three elements.

First, the individual must hold a recognised qualification: a Chartered Financial Analyst (CFA) designation, a recognised MBA, a relevant master's degree in finance, accounting, or economics, or a qualification approved by MAS on application. The CFA route is the most established — a candidate holding the CFA charter with three years of buy-side experience generally satisfies the IP test without further documentation. The MBA route is conditional on the institution; MAS does not publish a list of qualifying MBA programmes, and the operating assumption is that MBAs from internationally recognised institutions will satisfy the qualification element while less established programmes require supplementary evidence. The master's degree route covers finance, accounting, or economics from recognised institutions. The approved-by-MAS-on-application route is the safety valve, used for senior practitioners whose careers predate the CFA's dominance.

Second, the individual must have relevant buy-side experience — typically three to five years in portfolio management, investment analysis, or fund management. The 2025 update tightened this materially: where the pre-2025 reading would accept general financial services experience, the post-2025 reading expects experience that is identifiably buy-side. Discretionary portfolio management at an asset manager, sovereign wealth fund, pension fund, endowment, or another family office counts; experience as a private banker, financial adviser, or wealth manager at a retail bank does not automatically count. The roles MAS recognises are explicitly investment-side: portfolio manager, investment analyst, head of investments, fund manager.

Third, the individual must be employed by the family office in Singapore on a full-time basis, with local tax residency. The 2026 standard also addresses independence: at least one of the two IPs must be a non-family member — an individual who is not a beneficial owner of the family fund. The intent is to prevent the requirement being satisfied entirely by family members who hold qualifications but lack independent professional judgement.

Local employment, EP / COMPASS, and sourcing IPs

The 2026 standard expects the two IPs to be employed in Singapore on a full-time basis. The local employment test reaches beyond the contractual position. MAS asks whether the IP is physically present in Singapore, whether the IP is the tax-resident decision-maker for the portfolio, and whether the family office's investment activity is conducted from Singapore.

The Employment Pass (EP) regime, administered by the Ministry of Manpower (MOM), is the practical gating mechanism. An IP who is not a Singapore citizen or permanent resident requires an EP. The Complementarity Assessment Framework (COMPASS), in effect since 2023, scores EP applications against criteria including salary, qualifications, and firm diversity. Family office EP applications are not exempt from COMPASS, and the salary thresholds for IPs are typically well above the framework's qualifying minimums — which generally helps the application but does not guarantee approval. MAS also expects IPs to be paid at market rates for senior investment professionals; sub-market compensation, particularly where the IP is a family member, raises questions about whether the role is genuine.

Three sourcing patterns dominate. The first is the lateral hire from a Singapore asset manager or private bank — efficient because the candidate is already on a Singapore work pass and has MAS-recognised experience, but expensive and supply-constrained. The second is the international relocation — a candidate from London, New York, Hong Kong, or Zurich brought to Singapore on an EP, typically a three- to six-month timeline when handled efficiently, with material relocation cost. The third is the family-member IP, where appropriate — a family member with a CFA and buy-side experience can satisfy one half of the requirement, subject to the 2026 standard's non-family expectation for at least one of the two. Across all three patterns, the practical timeline from decision to two IPs in seats is rarely less than six months, and often closer to twelve.

Cross-jurisdictional comparison — Hong Kong FIHV, Dubai DIFC, UK

The Singapore IP requirement is one approach to a problem every family office jurisdiction has confronted: how does the regulator verify that a tax-favoured structure is actually being run by qualified people?

Hong Kong's Family-owned Investment Holding Vehicle (FIHV) regime, introduced through the Inland Revenue (Amendment) (Tax Concessions for Family-owned Investment Holding Vehicles) Ordinance, requires the FIHV to be managed by an eligible Single Family Office meeting a substantive activities test — a minimum of two full-time qualified employees with a minimum operating expenditure threshold. The Hong Kong approach is parallel in structure to Singapore's but differs in quantitative thresholds.

The DIFC SFO regulation in Dubai takes a different tack. Registration with the Dubai Financial Services Authority (DFSA) is required, but substance requirements are calibrated to the SFO's scale, with proportionality built into the regime. This is often chosen by families with operational MENA presence.

The United Kingdom family office model sits outside a dedicated regime. UK family offices typically operate through investment manager structures that may or may not require Financial Conduct Authority authorisation, depending on whether they manage third-party assets. For pure single-family structures, the FCA's Article 72D exemption under the Regulated Activities Order is the typical route. The FCA does not impose a specific IP headcount; the substance test is the absence of third-party clients.

For an international principal choosing between Singapore, Hong Kong, Dubai, and London, the Singapore approach is the most prescriptive among the four; the UK approach is the least. Each route is workable; none is universally optimal.

Common pitfalls

The "stretched IP" pattern
An applicant nominates an IP whose qualifications and experience are close to but not clearly within the 2026 standard. MAS does not summarily reject these applications; it returns them with queries that lengthen the timeline. The corrective is to test the IP profile against the 2026 standard before submission rather than during MAS's clarification round.
Both nominated IPs are family members
The 2026 standard requires at least one non-family IP. Applications with two family-member IPs are typically returned with a request to nominate a third-party hire. The corrective is to scope the non-family hire into the structure at design time, not as a post-approval add-on.
The "advisory creep" experience description
The applicant's experience description emphasises advisory work or wealth structuring rather than portfolio management. MAS reads these descriptions through a buy-side lens and queries the experience. The corrective is to frame the IP's experience narrative around discretionary investment decision-making, not around client advisory services.
The non-Singapore IP pattern
The nominated IP spends a significant portion of the year outside Singapore. The local employment test is about substantive presence, not contractual residence. An IP whose travel pattern places them outside Singapore for the majority of the year does not satisfy the test, regardless of the EP being in place.
Budget incongruity between operating plan and IP salaries
The projected operating budget does not support the salaries that two senior IPs will reasonably command, suggesting the structure will not in fact sustain them. MAS expects market-rate pay for market-rate work; a budget that prices IP salaries below market is a substance signal in the wrong direction.

Frequently asked questions

Does the CFA charter alone satisfy the IP qualification element?: The CFA charter is the cleanest qualification pathway, but the qualification is one of three elements. The candidate also needs identifiable buy-side experience (typically three to five years in portfolio management, investment analysis, or fund management) and full-time Singapore employment. A CFA charterholder with three years at an asset manager doing discretionary portfolio management is a textbook IP profile.
Can both IPs be family members?: No. The 2026 standard requires at least one of the two IPs to be a non-family member — an individual who is not a beneficial owner of the family fund. One family member with the right qualifications and buy-side experience can fill one of the two seats; the other seat must be a third-party hire.
How does the one-year grace period for the second IP work?: If only one IP is in place at the time of application, MAS allows a one-year grace period to hire the second IP. The grace is a one-time bridge to the steady-state two-IP condition; it is not a permanent waiver, and prolonged shortfalls after the grace expires trigger MAS engagement. The practical posture is to dimension the IP hire plan for two professionals from year one and use the grace only where a specific phasing rationale supports it.
What counts as "buy-side" experience under the 2025 tightening?: Discretionary portfolio management, investment analysis, fund management, head of investments — roles in which the individual is making or supporting binding investment decisions on behalf of a managed pool of capital, at an asset manager, sovereign wealth fund, pension fund, endowment, or another family office. Roles excluded by the 2025 tightening: private banker, financial adviser, retail wealth manager, sell-side broker. MAS reads experience through this lens during the application review.
How long does the IP build typically take?: The practical timeline from a decision to build a Singapore family office to two qualifying IPs in seats is rarely less than six months and often closer to twelve. Lateral hires from Singapore asset managers or private banks are fastest where supply allows; international relocations on an EP run three to six months when handled efficiently. The IP build is the gating timeline for the 13O application.
Are family member IPs paid at market rates?: Yes — MAS expects market-rate compensation for IPs regardless of family relationship. Sub-market compensation for a family member IP raises questions about whether the role is genuine. The MAS substance review reads the entire compensation package (salary plus bonus plus benefits, against the market for senior investment professionals in Singapore) rather than the family relationship alone.
How does Anlian Group support 13O preparation including the IP layer?: Anlian Group Pte. Ltd. (ACRA Corporate Service Provider FA20200346) supports the corporate-structure side of the 13O preparation — Singapore incorporation of the SFO and the fund vehicle, ACRA filings, registered office, and the documentation chain MAS expects to see. The licensed fund management work touching the 13O scheme itself runs through Anlian Capital Pte. Ltd. (UEN 202224273H, MAS Capital Markets Services Licence CMS101702). For the IP hire layer, Employment Pass sponsorship and COMPASS coordination for inbound IPs runs through Dahe Private Ltd. (UEN 202005455G, Employment Agency Licence EA20C0327). The three workstreams are run in coordination because the IP build, the corporate structure, and the EP timeline all gate the 13O application.

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