In Singapore, the Code on Collective Investment Schemes (CIS Code) is structured to cater to a broad spectrum of investors, ranging from retail participants to sophisticated institutional players. To ensure investor protection while supporting market development, the Monetary Authority of Singapore (MAS) classifies collective investment schemes (CIS) into four regulatory regimes: Authorised, Recognised, Exempted, and Restricted. Each category is subject to its own set of regulatory requirements, eligibility criteria, and disclosure obligations. Understanding these distinctions is crucial for investors, fund managers, and fund management companies seeking to navigate Singapore’s fund management landscape effectively.

1. Authorised Schemes

Authorised Schemes are fully regulated CIS constituted in Singapore. Under Section 286(1) of the Securities and Futures Act (SFA), such schemes must be formally authorised by MAS and remain subject to any conditions or restrictions imposed by the Authority.

Target Investors: Authorised Schemes are typically open to retail investors. In the context of the SFA, they are the primary vehicle for offers to the public, whereas “Restricted Schemes” refer to CIS that are either (i) offered only to “relevant persons”  (Section 305(1) of the SFA) or (ii) offered on terms where each transaction is not less than SGD 200,000 (or its equivalent in foreign currency) (Section 305(2) of the SFA).

It should be noted that “relevant persons” are defined as:

1. 1. An accredited investor;

1. 1. A corporation, the sole business of which is to hold investments, and whose entire share capital is owned by individuals, each of whom is an accredited investor;

1. 1. A trustee of a trust, the sole purpose of which is to hold investments, and each beneficiary of which is an individual who is an accredited investor;

1. 1. An officer or equivalent person of the entity making the offer, or a spouse, parent, brother, sister, son, or daughter of such officer or equivalent person; or

1. 1. A spouse, parent, brother, sister, son, or daughter of the person making the offer, where such person is an individual.

How does a Scheme get Authorised?

To authorise a CIS in Singapore, a Manager must submit an application to the MAS under Section 286 of the SFA. The process requires the Scheme to have a compliant constituent document, such as a trust deed for unit trusts or a constitution for Variable Capital Companies (VCCs). Key structural requirements include the appointment of an independent trustee or VCC custodian and ensuring the Manager meets requisite expertise and asset under management thresholds.

Prior to formal filing, the CIS Code provides that where a Scheme involves a novel structure, investment strategy, or risk profile, the Manager is expected to consult MAS. MAS will then assess the Scheme’s adherence to Core Requirements in the Appendices, including those relating to permissible investments, diversification limits, and borrowing restrictions. For cross-border offers, the Scheme may also be required to be assessed as a Qualifying CIS under the ASEAN CIS Framework.

Regulatory Requirements

• • Mandatory Appointments & Independence: Authorised Schemes must appoint a Manager and an [1]independent trustee or Variable Capital Company (VCC) custodian. Independence is compromised if there is a 20% or greater shareholding interest overlap between the Manager and the trustee or custodian.
    

    [1] MAS Code on Collective Investment Schemes, Chapter 2.1 (p. 7). Independence is primarily defined by shareholding: a trustee is generally not considered independent if there is a common shareholding of 20% or more (including deemed interests) between the trustee and the manager. Furthermore, the Code mandates that the trustee conduct all scheme transactions at arm’s length.

• • Variable Capital Company (VCC) Governance: At least one VCC director must be independent of the Manager, custodian, and substantial shareholders. This director must not have been an officer or director of the Manager or custodian in the current or preceding financial year.

• • Operational Timelines: Redemption proceeds must generally be paid within T+7 business days. The CIS Code allows exceptions for specialised funds. For example, Property Funds follow the timelines set out in Appendix 6 of the CIS Code, while Hedge Funds must pay redemption proceeds according to their prospectus, as required under the Securities and Futures Regulations (SFR). Managers are required to send semi-annual accounts and reports to participants within two months of the end of the relevant period. Annual accounts and audited reports must be issued within three months of the end of each financial year.

• • Compliance & Enforcement: Trustees must report specific breaches of Section 289(3) of the SFA to MAS within three business days after becoming aware of such breaches. While the CIS Code is non-statutory, MAS may take any breach into account when determining whether to revoke or suspend a Scheme’s authorisation, or when considering future authorisation applications by the same responsible person.

2. Recognised Schemes

Recognised Schemes are CIS constituted outside of Singapore that have been granted formal recognition by MAS under Section 287 of the SFA. This allows such foreign funds to be offered and marketed within Singapore, provided they are regulated under a jurisdiction that offers investors a level of protection at least equivalent to that of Singapore’s “Authorised Schemes”.

The CIS Code does not provide an exhaustive list of approved jurisdictions, but specifies that a jurisdiction is considered “equivalent” if its laws and regulatory framework afford participants a level of protection comparable to that in Singapore. A key example is the ASEAN CIS Framework, under which jurisdictions such as Malaysia and Thailand have entered into a Memorandum of Understanding (MOU) with Singapore to facilitate the cross-border offering of funds through a streamlined authorisation process. Under this framework, schemes from signatory jurisdictions may be offered in Singapore if they are assessed as “Qualifying CIS” and comply with the Standards of Qualifying CIS. In addition, the Manager is generally required to oversee at least S$500 million in discretionary funds within Singapore.

Target Investors: Recognised Schemes may be offered to retail investors, institutional investors, or other non-retail investors, depending on the distribution strategy.

Regulatory Requirements

• • AUM Threshold: The Manager (together with its related corporations) must manage at least S$500 million of discretionary funds in Singapore, unless the Scheme’s units are approved for listing and trading on an approved exchange.

• • Ongoing Notification of Home Status: MAS must be notified as soon as practicable, and in any event no later than 14 days, if the home financial supervisory authority imposes or varies any condition or restriction on the Scheme’s authorisation.

• • Risk Management Submission: Updated documentation of the Scheme’s risk management framework must be submitted to MAS no later than one month after approval by the home financial supervisory authority.

• • Mandatory Disclosure Compliance: Recognised Schemes must comply with disclosure requirements set out in the CIS Code, including those related to performance fees and specific asset class guidelines (for example, Hedge Funds, Index Funds, and Property Funds).

Key Changes under the CIS Code (Last Revised 28 November 2025)

Based on the revised CIS Code, last updated on 28 November 2025, the following are six key changes for Authorised Schemes and Recognised Schemes:

• • Authorised Schemes must prepare all semi-annual and annual financial statements in accordance with Singapore Financial Reporting Standards (International) [SFRS(I)]. This framework is fully converged with International Financial Reporting Standards (IFRS), ensuring that scheme reporting remains aligned with global accounting benchmarks

• • Property Funds are required to maintain a minimum Interest Coverage Ratio (ICR) of 1.5 times, to ensure adequate coverage of interest expenses and borrowing costs.

• • Property Fund Managers must include sensitivity analyses in their reports, illustrating the impact of a 10% decrease in Earnings Before Interest, Tax, Depreciation and Amortisation (EBITDA) or a 100 basis point increase in interest rates, on the fund’s ICR.

• • The CIS Code prohibits the use of the terms “capital protected” or “principal protected” (or any derivatives thereof) in the name or description of any Scheme.

• • If a home regulator varies any condition or restriction for a Recognised Scheme, MAS must be notified within 14 days.

• • Authorised Schemes are subject to a transition period and must comply with the revised financial reporting requirements and Property Fund provisions for financial years ending on or after 31 December 2028.

How Curia Regis Can Help

Curia Regis supports investors and fund managers in navigating Singapore’s collective investment scheme landscape by providing end-to-end support.  This includes fund setup, licensing, ongoing regulatory monitoring, documentation, and corporate governance support, enabling clients to maintain compliance while achieving operational efficiency, and informed decision-making at every step.

Ensure your operational response is seamless. You can reach us here or email admin@thecuriaregis.com to get in touch.