Singapore Financial Adviser Licence: Company Setup & Requirements

Build the application around one consistent business model

Start with a short service specification: products covered, intended clients, how recommendations are made, who contracts with the client, and whether anyone has discretion to execute investments. Attach a sample customer journey and proposed engagement terms. These working documents help expose a licence mismatch before money is committed to staffing and share capital.

The MAS Financial Advisers Act FAQ covers advice on investment products, investment research and arranging life insurance policies. A business described as financial planning is not classified solely by its name. Tax or estate planning alone is outside the financial advisory activities described there; adding product recommendations changes the analysis. Fund management and broader dealing functions need their own regulatory assessment.

The permission follows the activity, not the company’s marketing label. A “consultancy” description is therefore weak evidence if the actual service recommends particular investments. Record the regulated and excluded activities expressly, rather than assuming that a generic business activity code settles the issue.

This is an application planning sheet, rather than a substitute for the official form. Give each row an owner, a source document and an unresolved issue. A missing source document is more useful as an explicit gap than as an optimistic statement in the business plan.

The wider Singapore company registration process establishes the legal entity and corporate records. It should use the same ownership and management assumptions as the regulatory application, so that a later licensing decision does not require an avoidable corporate restructuring.

Resolve management and ownership eligibility early

MAS’s current financial adviser application criteria call for at least two directors, including one resident in Singapore; a resident CEO with ten years of relevant experience, including five in management; and three full-time Singapore-based individuals with five years of relevant experience. Evidence should identify relevant roles and dates, rather than rely on senior job titles alone.

For a Singapore company, ACRA’s basic director requirement is a separate corporate test. Its company officer rules also require a secretary within six months; a sole director cannot simultaneously be the secretary. Meeting these corporate requirements does not establish that the proposed board and local team satisfy MAS.

Review the resident-director duties in a foreign-owned company when assigning the corporate role. A person who only supplies local residency does not thereby provide the financial advisory experience, executive capacity or compliance oversight needed in the application.

The enhanced criteria in Part II, question 7A of the MAS FAQ include a five-year financial advisory track record. Where the applicant does not meet that criterion, the CEO should hold at least 20% of issued capital and the CEO and executive directors together at least 50%. Assess that dependency before agreeing a founder/investor cap table; a newly incorporated shell cannot manufacture an operating history.

Prepare a role register with each person’s location, employment commitment, relevant experience, executive responsibilities and proposed representative activities. Do not assume that the same person can satisfy several roles without checking availability and the applicable criteria. Keep appointment, fit-and-proper and employment evidence aligned with the final structure.

For overseas founders, the ACRA foreign-founder rules require a corporate service provider for registration and appropriate work-pass permission to relocate and run the business. Share ownership and a licence application are not immigration permission.

Run three financial tests without adding unlike amounts

MAS expressly presents the following as enhanced requirements it expects new FA licence applicants to meet. This matters because the FAQ also describes older Financial Advisers Regulations thresholds. Treating the older figures as a sufficient application budget would omit the admission expectations.

For other advisory services with revenue above S$5 million, baseline PII is the lower of 20% of gross revenue and S$10 million. The FAQ addresses the first-year case and policy deductible as well. Obtain a policy assessment against the precise activity and capital route; a quotation mentioning a headline limit is insufficient if exclusions remove the service you intend to provide.

These figures are not four invoices. Capital is funding in the business, financial resources are a continuing financial test, PII is insurance cover, and the premium is the cost of buying that cover. Additional PII cover under the lower-capital option must not be mistaken for additional paid-up capital or an insurance premium.

For example, using prior-year relevant expenditure of S$800,000 gives a financial-resources planning threshold of S$200,000: 25% exceeds S$150,000. This calculation does not replace the base-capital test. It also does not mean the company simply adds S$200,000 to every other threshold to obtain a single regulatory cash bill; each test has its own definition and evidence.

Prepare a forecast showing recruitment, premises, systems, insurance premium and professional support separately from regulatory capital. Stress a delayed launch and slower revenue. A budget that exhausts the entity’s financial capacity during the review period undermines the plan it was meant to support.

Turn the evidence into corporate records and a Form 1 submission

For the Singapore-incorporated route discussed here, reserve the name, settle the shareholders and officers, prepare the constitution and register through Bizfile. ACRA’s current local-company registration guide requires company, registered-office, share-capital, position-holder and applicable controller or nominee information. Its registration fee is S$300; name reservation and private service costs are separate.

Use the approved corporate data consistently in the application. The company name, UEN, group ownership chart, directors, shareholdings and paid-up funding evidence should reconcile. Keep the source and movement of funding traceable. If a funding round changes the cap table while the application is being prepared, reassess the ownership-dependent criteria instead of merely replacing a diagram.

Submit the official Form 1 application for a new FA licence. Existing licensees adding a financial advisory activity use Form 2. Supporting explanations should demonstrate how the proposed operation works and who performs the controls, rather than repeat the wording of a policy manual.

Build a sample advice file, a complaint escalation route and a control-owner schedule. State how product information is checked, conflicts are handled and advice records can be retrieved. These are practical ways to demonstrate the internal compliance capability assessed by MAS; the actual submission and licence conditions determine the required evidence.

Separate review time, licence fees and representative readiness

The corporate application fee is S$500 and is non-refundable. The annual FA licence fee is S$2,000, with S$5 for each representative from the 101st onwards based on the count at 1 January. These regulatory fees are separate from formation services, insurance and professional assistance.

MAS’s review expectation is no more than six months for a straightforward, complete and clear application that fully meets admission criteria. Complex models, missing information or inaccurate material take longer. Set a provisional launch window with room for queries; do not convert that expectation into a guaranteed permission date.

Individuals conducting regulated advice need the applicable representative arrangements. The representative appointment process includes qualification, examination and fit-and-proper requirements, notification forms and company certification through CoRe. It lists S$200 for a new lodgement and a S$100 annual representative fee, with first-year proration. A job offer, CEO appointment or corporate licence does not itself complete that notification.

Keep a launch register of each intended adviser, permitted service, notification evidence and outstanding examination or other conditions. Confirm the entity’s authorised services and each individual’s readiness before allocating client work. Ongoing obligations continue after launch; the corporate licence has no routine fixed renewal term but can cease, be revoked or lapse.

Use a go/no-go test before committing the launch date

Proceed with a submission-ready plan when the service perimeter is settled, the ownership and management criteria are evidenced, each financial test has been calculated, and the controls have identified operators. Put the actual source documents beside the assertions in Form 1.

Pause the launch commitment if a founder’s ownership plan conflicts with the track-record route, the CEO’s relevant experience is unsupported, insurance excludes a planned activity or the budget uses an older capital figure without assessing current admission expectations. Resolve the affected decision and every document it changes.

The useful completion record is an evidence register with no unexplained differences between corporate filings, the regulatory application and the intended customer service. It gives the directors a concrete basis to decide whether to submit, revise the business model or defer the project.