An SFC Type 9 licence in Hong Kong and a CMS licence for fund management in Singapore authorise the same business — managing client portfolios and funds under delegated discretion — but divide the market differently. Hong Kong's Securities and Futures Commission (SFC) grants one Type 9 licence under the Securities and Futures Ordinance (SFO) for every class of investor and ties capital to whether the manager may hold client assets: HK$100,000 of liquid capital under a licensing condition not to hold them, HK$5 million paid-up and HK$3 million liquid capital without it (SFC Licensing Handbook, para 3.2.18). The Monetary Authority of Singapore (MAS) splits the capital markets services (CMS) licence for fund management under the Securities and Futures Act (SFA) into three categories — the retail licensed fund management company (LFMC), the A/I LFMC restricted to accredited and institutional investors, and the venture capital fund manager (VCFM) — and sizes an LFMC's capital by client class and product: base capital of S$250,000, S$500,000 or S$1 million, plus financial resources of at least 120% of the risk requirement (MAS Guidelines SFA 04-G05).
Retail business runs through SFC authorisation of the fund in Hong Kong and through a retail LFMC in Singapore. Hong Kong requires at least two responsible officers (ROs), Singapore a resident team and a management-held controlling stake; a Hong Kong RO stationed overseas gets a non-sole condition and cannot supervise alone. The SFC indicates about 15 weeks; MAS up to six months to in-principle approval and up to six after it, with a 2025 median of 5.5 months across all CMS licensees.
Common to both
Unlicensed business is a criminal offence. As a rule, marketing the manager's own funds needs no dealing licence. Buying a significant stake needs the regulator's prior approval.
Hong Kong
One licence for all investors, capital set by the right to hold client assets, retail access through fund authorisation, a separate virtual-asset licence on the way.
Singapore
Three categories by investor class and product, base capital plus 120% of the risk requirement, a resident team, capital markets products only.
The two regimes side by side
Regulator, categories, capital and staffing all diverge.
| Parameter | Hong Kong: Type 9 | Singapore: CMS licence for fund management |
|---|---|---|
| Regulator and statute | SFC; SFO (Cap. 571), Schedule 5; Financial Resources Rules (FRR, Cap. 571N) | MAS; SFA 2001; Guidelines SFA 04-G05 |
| What it covers | Securities and futures management under delegated discretion; incidental dealing and advice for its own portfolios only | Portfolio management, research and trade execution, including a sub-adviser that influences the portfolio; capital markets products only |
| Retail investors | No separate category; the SFC authorises the fund, and the management company needs HK$10m and key personnel with five years' public-fund experience | Retail LFMC; MAS looks for a five-year retail track record and S$1bn of group assets |
| Capital under the rules | HK$100,000 liquid without client assets; otherwise HK$5m paid-up and HK$3m liquid | LFMC: S$250,000 / S$500,000 / S$1m base; resources of at least 120% of the risk requirement |
| People and presence | At least 2 responsible officers per activity, one an executive director; an RO based overseas only under a non-sole condition | CEO and an executive director resident in Singapore; 2 representatives (3 for retail) there too; management above 50% outside groups |
| Timeline | SFC indication: about 15 weeks for a corporation | MAS standard: up to 6 months to in-principle approval and up to 6 (+3) after; 2025 statistics: median 5.5 months |
| Regulator's fees | HK$4,740 to apply and HK$4,740 a year per regulated activity | S$1,000 to apply; S$4,000 a year |
| Register size | 2,358 Type 9 firms at end-2025 | 1,146 fund managers and 180 VCFMs at 29.09.2026 |
What each licence covers
Hong Kong requires a licence to carry on a business in a regulated activity (s.114 SFO) or to actively market such services to the Hong Kong public from anywhere (s.115); the maximum penalty is a HK$5 million fine and seven years' imprisonment (SFO, Cap. 571). In Singapore s.82(1) SFA prohibits fund management without a CMS licence; in the text MAS reproduced in a 2022 case, the penalty is a fine of up to S$150,000, up to three years' imprisonment or both, plus up to S$15,000 a day for a continuing offence.
Discretion and advice
Under Schedule 5 to the SFO, Type 9 means securities or futures contracts management or real estate investment scheme management, and the SFC generally expects an applicant to be able to exercise properly delegated discretionary authority (para 1.4.24). A firm delegated discretion over a fund's securities needs Type 9; a firm without discretion may still need Type 1 to market or distribute the fund or execute deals, and Type 4 to advise on its investments (para 1.4.19). A Type 9 licensee may place orders and advise without Types 1, 2, 4 or 5 solely for its asset management business (for Types 4 and 5 only when managing a collective investment scheme portfolio), never for portfolios it does not manage (para 1.3.6).
Singapore draws the line elsewhere. MAS licenses substantive fund management in Singapore — portfolio management, investment research or trade execution — and a Singapore adviser, sub-adviser or research provider to other managers also conducts fund management if it can influence or control the portfolio or provides inputs to its composition (para 3.2 SFA 04-G05).
MAS will not license a conduit for customers' own investments, a company raising capital for its own operating business, a front for other managers' funds, a pure fund marketer or a company investing ultimately outside capital markets products; managing only one's own money needs no licence (paras 3.3.1–3.4). Managing assets for related corporations, or a pool of immovable assets or non-capital markets products for accredited and institutional investors, is exempt (MAS Fund Managers page).
Selling funds: own and third-party
Under SFC licensing FAQ 10.5, a Type 9 manager marketing funds under its own management relies on the incidental exemption and needs only Type 9; marketing funds it does not manage requires Type 1. Adding Type 1 changes capital: with several activities the highest minimum applies, so a Type 9 manager without client assets moves from HK$100,000 of liquid capital to HK$500,000 if it is an approved introducing agent, and otherwise to HK$5 million paid-up and HK$3 million liquid capital (paras 3.2.17–3.2.18).
In Singapore marketing funds is dealing in collective investment scheme units, but a licensed manager needs no dealing licence to market funds of its own or its related corporations, authorised, recognised or exempt schemes it is responsible for, or to invest clients into third-party funds within segregated mandates. Accepting unsolicited client orders, for example on an online platform, requires adding dealing to the licence (MAS FAQs on the Licensing of FMCs, Q1). Singapore's exemption also covers related corporations' funds. A CMS licensee advises outside its main business as an exempt financial adviser under the Financial Advisers Act (FAA), lodging Form 26 at least 14 days ahead (MAS FAQs).
Private companies and venture capital
Shares and debentures of a private company within s.11 of the Hong Kong Companies Ordinance are not “securities”, so managing Hong Kong private-company equity may need no licence, while managing private offshore companies' shares likely does (para 1.4.18). Singapore has a separate venture category: a VCFM manages only closed-ended funds for accredited or institutional investors that invest in products issued directly by unlisted ventures no more than ten years old, with up to 20% in other unlisted investments. The detail is in “Venture capital fund manager — VCFM”.
Clients: professional and retail
Hong Kong licenses the manager the same way for all clients and vets the retail product; Singapore vets the manager by client class.
| What retail changes | Hong Kong | Singapore |
|---|---|---|
| Gateway | SFC authorisation of the fund; the management company must be acceptable to the SFC | Retail LFMC; MAS looks for five years of retail fund management and S$1bn managed by the company and its related corporations |
| Capital | At least HK$10m of paid-up capital and non-distributable reserves | S$1m for funds; S$500,000 for non-fund mandates |
| People | Key personnel with five years managing public funds, generally at least two per fund | CEO with 10 years' experience; 3 relevant professionals and 3 representatives; an independent dedicated compliance function in Singapore |
Hong Kong: one licence, retail through the fund
The FRR floors turn on client assets and ignore the investor type, so Type 9 has no retail category. A fund offered to the public is authorised by the SFC, and its management company must meet Chapter 5 of the Code on Unit Trusts and Mutual Funds. The SFC's October 2025 consultation 25CP10 proposes to deem the key-personnel requirements met for managers in well-established fund groups and for managers licensed in jurisdictions with a mutual recognition of funds arrangement with Hong Kong, and to keep the two-key-personnel rule for others. As at 30.09.2026 no conclusions had been published. Professional investor tests are in “Accredited and Qualified Investor: Rules and Thresholds”.
Singapore: A/I LFMC or retail LFMC
A retail LFMC may deal with all types of investors, an A/I LFMC only with accredited and institutional investors, and a VCFM only with venture funds for them (para 2.1 SFA 04-G05). For a retail licence MAS looks for a five-year record of the company or its shareholders in managing retail funds under comparable regulation, and at least S$1 billion managed by the company and its related corporations (para 3.21.1); MAS lists them among the factors it may consider. An A/I LFMC with AUM below S$1 billion may instead designate a senior staff member independent of the front office, rely on group compliance or use an external provider. MAS may require a retail LFMC to carry professional indemnity insurance from S$2 million (AUM below S$100 million) in steps up to S$25 million (AUM of S$10 billion or more); A/I LFMCs are strongly encouraged to carry it and must tell customers whether they do.
A Singapore accredited investor is an individual with net personal assets above S$2 million (the home counted at up to S$1 million), net financial assets above S$1 million or income of at least S$300,000 in the last 12 months, or a corporation with net assets above S$10 million (MAS response of 2015).
Capital
Hong Kong sets an absolute floor; Singapore sets base capital and a multiple of the risk requirement.
| Requirement | Hong Kong | Singapore |
|---|---|---|
| Lower tier | HK$100,000 of liquid capital and no paid-up minimum — under the condition not to hold client assets | S$250,000 of base capital — an LFMC with no retail funds or mandates |
| Upper tier | HK$5m paid-up and HK$3m liquid — without that condition | S$1m — funds for retail investors; S$500,000 — non-fund mandates for retail investors |
| Above the floor | Operating expenses projected for the first 6 months; a funding plan if excess liquid capital falls short | Financial resources of at least 120% of the total risk requirement (SF(FMR)R, Notice SFA 04-N13); MAS calls a further buffer prudent |
The figures come from Licensing Handbook paras 3.2.18 and 3.2.20 and SFA 04-G05 paras 3.13–3.14. The Singapore floors are set for LFMCs; for a VCFM, Appendix 4 to SFA 04-G05 sets a separate package of requirements and exemptions. A Hong Kong licensee holding only Types 4, 5, 6, 9 or 10 under the no-client-assets condition files financial resources returns half-yearly instead of monthly. How other regimes calculate capital is compared in “Regulatory Capital: How Regulators Calculate It”.
People and presence
In Hong Kong every individual performing a regulated function is accredited to the licensee as a licensed representative; in Singapore minimum staffing is set role by role and tied to residence.
| Requirement | Hong Kong | Singapore |
|---|---|---|
| Management | At least 2 responsible officers per activity, one available at all times, one an executive director; every executive director approved as a responsible officer | CEO with 5 years' experience (10 for retail); at least 2 directors with 5 years each, including an executive director with 5 years of portfolio management relevant to the strategy |
| Residence | No SFO residence rule for directors; the SFC licenses individuals who will work in Hong Kong; an RO stationed overseas gets a non-sole condition | CEO and an executive director full-time and resident in Singapore; representatives overseas for exceptional reasons only |
| Specialists | Managers-In-Charge of core functions approved as responsible officers | At least 2 relevant professionals and 2 representatives (3 each for retail) |
| Company | Hong Kong-incorporated, or an overseas company registered with the Hong Kong Companies Registry | Singapore-incorporated, with a permanent dedicated office |
| Custody and valuation | A functionally independent custodian under the Fund Manager Code of Conduct; if self-custodying, a segregated function and the Client Money and Client Securities Rules | Independent custody and independent valuation; the annual audit does not satisfy the valuation requirement |
Hong Kong. ROs directly supervise each regulated activity (Licensing Handbook paras 3.2.3–3.2.7). An RO stationed overseas receives a non-sole condition, so the licensee must keep enough onshore ROs free of conditions, and itinerant professionals should not be ROs (paras 4.4.11–4.4.13). Under the SFC's Guidelines on Competence an RO applicant needs at least three years of relevant experience in the past six (one option: five in eight), two years of management experience and the local regulatory paper; for private fund managers serving professional investors the SFC accepts wider experience such as proprietary trading, research and alternative strategies.
Singapore. Everyone working on the portfolio, deals, research, marketing or clients is appointed a representative, even if employed by an affiliate; control and back-office staff are not (Appendix 1 to SFA 04-G05). Custodians are prime brokers, depositories or suitably licensed banks (paras 4.1.1–4.1.2). For a relocating team MAS allows a provisional representative (moving to Singapore, three years' experience, three months to meet the exam requirements) and a temporary representative (an overseas-resident employee of a related company, five years' experience, appointed in three-month blocks) (MAS representatives page).
Owners and control
Anyone becoming a substantial shareholder of a Hong Kong licensee — more than 10% of the shares or voting power alone or with associates, including through a 35%-held intermediate company — needs the SFC's prior approval. In Singapore MAS approval is needed before anyone obtains effective control of a CMS licensee (s.97A SFA), which MAS's fund manager toolkit treats as a change of controller of 20% or more; a licence condition also requires approval before anyone comes to control or hold 20% or more of an LFMC. VCFMs are exempt from ss.97A–97I.
Singapore's second ownership rule has no Hong Kong counterpart: where a manager outside an established business group is owned by individuals, MAS expects its CEO and executive directors together to hold more than 50% of the effective voting interest, with passive shareholders kept to a minimum (para 3.11 SFA 04-G05). A manager that cannot meet this may propose alternative measures case by case, showing how they stabilise the team, align it with third-party investors and preserve its control (MAS FAQs, Q20). Buying a licensee is covered in “Change of Control and Buying a Licensed Company”, owner vetting in “Qualifying Holdings and Fit & Proper: How Regulators Vet Owners and Managers”.
Timelines and fees
The SFC indicates about 15 weeks for a corporation, 10 for an RO and 8 for a licensed representative, longer with incomplete files, changes of shareholders or key persons during review, visa waits and capital injections (paras 7.7.1–7.7.2). The indication covers all licensed corporations; the SFC publishes no separate Type 9 statistic.
MAS expects up to six months to review a complete application from an applicant meeting all admission criteria, then grants in-principle approval, leaving up to six months, extendable by three, to meet the remaining requirements (MAS Fund Management Licensing page). Under MAS's 2025 licensing report the median time to admit a CMS licence holder, VCFMs included, was 5.5 months (119 admitted) against 6.5 months in 2024, counting only applications meeting all criteria; fund and REIT managers made up 78% of the 191 applications processed.
| Fee | Hong Kong, SFC | Singapore, MAS |
|---|---|---|
| Corporate application | HK$4,740 per regulated activity | S$1,000; S$500 to add a regulated activity |
| Annual, corporation | HK$4,740 per regulated activity; collected again since 01.04.2025 | S$4,000 for an LFMC or VCFM; an LFMC also pays S$5 per representative from the 101st |
| Individuals | RO: HK$2,950 per activity to approve and HK$4,740 a year per activity; representative: HK$1,790 to apply and a year | Representative: S$200 to lodge and S$200 a year |
Fees follow SFC circular 25EC16, MAS Guidelines on Fees CMG-G01 and the MAS Fund Management Licensing page.
Launching without a licence of its own
Because Hong Kong accredits individuals to a licensee, a team without its own licence works as accredited staff of an existing one. A departing representative may transfer accreditation to a new licensee within 180 days; for the same activities the SFC takes about seven business days. The temporary licence for overseas firms covers only Types 1, 2, 4, 5, 6 and 10 and is not available for asset management. Singapore sub-management and platform routes are covered in “Singapore: Fund Management Under Own and Third-Party Licenses”, and the limits of hosting in “License for Rent: How Business Works Under Someone Else's Regulation”.
Market size and former RFMCs
The number of Type 9 firms rose 7% in 2025, from 2,212 to 2,358 (SFC Asset and Wealth Management Activities Survey 2025). The MAS Financial Institutions Directory lists, as at 29.09.2026, 1,146 CMS licensees for fund management, 180 for venture capital fund management and 302 for dealing; one institution may hold several activities, so rows do not add up. The Hong Kong figure is at 31.12.2025, the Singapore one a live reading.
Singapore's registered fund management company (RFMC) regime was repealed on 1 August 2024; 22 RFMCs were admitted in 2024 before the repeal and none applied in 2025. RFMCs that wanted to continue applied for A/I LFMC status on Form 1AR between 1 April and 30 June 2024, and MAS capped the AUM of firms transitioned that way at S$250 million until it assesses a request to lift the cap (MAS response to feedback, 28.03.2024). The cap remains a licence condition: under MAS's toolkit of 29.05.2026 a review application is due before AUM exceeds S$250 million, and MAS allowed such requests immediately upon licensing. Regular A/I LFMC applicants on Form 1A do not get the cap by default.
Virtual assets
Hong Kong today
Under the SFC statement of 1 November 2018, Type 9 managers investing in virtual assets that are not securities or futures are supervised through licensing conditions, and managers of funds investing solely in them typically need Type 1 because they distribute the funds in Hong Kong. The statement limited such portfolios to professional investors; the joint circular of 22.12.2023 calls that the original approach and lets SFC-authorised funds be offered to the public. Today a Type 9 manager aiming to invest in virtual assets, or intending to put 10% or more of gross asset value into them, works under additional SFC terms and conditions and notifies the SFC before starting. Distributing in Hong Kong a fund investing wholly or partly in virtual assets requires Type 1 (para 1.4.4). This is unresolved: no primary source reconciles it with the FAQ 10.5 own-fund exemption, and the conservative reading is to hold Type 1 for marketing one's own virtual-asset fund too.
Under SFC circular 26EC31, revised on 27.05.2026, the SFC will consider authorising for public offering funds with more than 10% of NAV in virtual assets. The management company needs a good compliance record and at least one competent staff member with virtual-asset experience, and receives additional terms and conditions from the SFC's Intermediaries Division.
Hong Kong: a standalone virtual-asset management licence
Following the consultation conclusions of 26 May 2026, Hong Kong plans to create a standalone virtual-asset management licence under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO) with a scope aligned to Type 9. It is to replace today's terms and conditions on SFO licences, so managers working under them will need the new licence or registration. Parameters from the conclusions paper:
- no de minimis threshold — Type 9 managers holding virtual assets below today's 10% trigger will also need the licence;
- capital of HK$100,000 liquid without client assets, otherwise HK$5 million paid-up and HK$3 million liquid; holders of matching SFO and virtual-asset licences meet the highest requirement without doubling, and dealing in virtual assets solely for its mandates needs no separate dealing licence;
- private fund managers may use qualified custodians anywhere in the world, with SFC self-custody rules for tokens no custodian supports;
- no deeming arrangement for existing advisers and managers: the regime takes full effect on commencement, with an expedited approval process promised to SFC licensees.
In the Supplement to the 2026 Policy Address of 16 September 2026 the Government expects the amendment bill in the Legislative Council in Q4 2026; as at 30.09.2026 it had not been introduced. The dealing and custody licences that will sit alongside are covered in “Hong Kong: the new virtual-asset dealing and custody licences”.
Singapore
A CMS licence covers the management of capital markets products: securities, units in collective investment schemes, derivatives contracts, spot FX contracts for leveraged FX trading and other prescribed products. A company ultimately investing in other assets does not qualify and may consider the exemptions for accredited and institutional investors (para 3.3.5 SFA 04-G05). MAS names no token type here: spot tokens are not on the list, derivatives contracts are. The working reading, which MAS has not confirmed in terms, is that a spot-token fund falls outside the licence while a token-derivatives fund stays within it. A manager investing in digital assets discloses their risks, segregates customer assets, keeps most of them in cold wallets and says where its custodians are licensed (para 4.1.4(i)).
From 30 June 2025 Singapore digital token service providers serving only customers outside Singapore need a DTSP licence, which MAS says it will generally not issue; firms already regulated under the Payment Services Act (PSA), the SFA or the FAA for Singapore customers may also serve customers abroad. MAS has not said whether the regime reaches a Singapore manager of a spot-token fund relying on the exemption for non-capital markets products; the cautious reading is to test the model against DTSP before launch. The regime is covered in “Singapore's DTSP Regime: Why a Singapore-Registered Crypto Company Must Licence or Leave”, other jurisdictions in “Crypto Licences by Jurisdiction: A Map of Twelve Regimes”.
Tax, fund vehicles and family offices
A Hong Kong open-ended fund company must have at least one investment manager licensed or registered for Type 9, which must retire once it ceases to be eligible (SFC Code on Open-ended Fund Companies, paras 6.4–6.5). The Singapore vehicle is covered in “VCC Singapore: Variable Capital Company for funds”, tax exemptions in “Section 13O and Section 13U: Singapore Fund Tax Exemption Schemes” and “Hong Kong FIHV: Tax Concessions for Family-Owned Investment Vehicles”, team rewards in “Carried interest 2026: the jurisdiction map for fund principals”, and the overall picture in “Fund Tax Architecture: Who Pays, Where and On What”.
A family office managing one family's money can go unlicensed in both cities, on different grounds. In Hong Kong a single family office serving no third parties needs no licence, while a company set up as a business managing assets including securities or futures may need Type 9. In Singapore, since 15 June 2026, a single family office is exempt only under the separate conditions of para 5(1)(ba) of the Second Schedule to the SF(LCB)R, including a 10% cap on key employees' share of AUM, and with a notification to MAS — by 15 June 2027 for existing offices; it can no longer rely on the related-corporations exemption (MAS FAQs on single family offices). The tax regimes for family offices are compared in “Hong Kong FIHV vs Singapore 13O: The Two SFO Regimes Compared”.
How to choose
Client base and product decide.
| Profile | What decides | Where it points |
|---|---|---|
| Liquid strategy for professional investors | Capital, residence, ownership | Hong Kong is cheaper on capital without client assets; Singapore adds a resident team and a management-held controlling stake |
| Private equity or venture fund | Where portfolio companies sit, their age | Hong Kong — Type 9 likely for offshore private-company stakes; Singapore — VCFM for closed-ended funds in ventures up to ten years old |
| Retail product | Public or retail fund track record | Hong Kong — fund authorisation (HK$10m in the management company, key personnel with five years' experience); Singapore — retail LFMC (five-year record, S$1bn of group assets) |
| Virtual-asset fund | Spot tokens or derivatives, timing of the new regime | Hong Kong — Type 9 with conditions and Type 1 now, a standalone licence once enacted; Singapore — only within capital markets products |
| Family office taking outside money | Third parties among clients | Outside money ends the exemption: Type 9 may be needed in Hong Kong, a fund management licence in Singapore |
| Adviser or sub-adviser without discretion | Influence over portfolio composition | Hong Kong — Type 4; Singapore — a fund management licence where it influences the portfolio |
Neither city opens retail business without a five-year record: Hong Kong looks for it in key personnel, Singapore in the company or its shareholders.
Common mistakes and risks
Type 4 in place of Type 9. A Type 4 adviser that in fact makes portfolio decisions manages assets without a licence. In Singapore such a team with influence over the portfolio already counts as a fund manager.
Selling third-party funds under Type 9. The FAQ 10.5 exemption covers only the manager's own funds; others need Type 1, and the capital floor rises to HK$500,000 of liquid capital or to HK$5 million paid-up and HK$3 million liquid.
A paper RO abroad. An RO stationed overseas gets a non-sole condition, and itinerant professionals should not be ROs.
A Singapore manager with passive owners or a team abroad. MAS expects management to hold more than 50% and accepts overseas representatives only exceptionally.
A licence for the tax incentive. MAS does not license a company to reach tax incentives, and a licence lapses if fund management does not start within six months (para 3.4 SFA 04-G05).
Q/A
Choosing between the licences
Which licence needs less capital?
Hong Kong's, without client assets: HK$100,000 of liquid capital against S$250,000 of base capital plus 120% of the risk requirement for a Singapore A/I LFMC. With client assets Hong Kong requires HK$5 million paid-up and HK$3 million liquid.
Where is the licence granted faster?
The SFC indicates about 15 weeks for a corporation. MAS takes up to six months plus up to six after in-principle approval; the 2025 median for all CMS licence holders was 5.5 months.
Can the manager serve retail investors?
In Hong Kong, through SFC authorisation of the fund: the management company needs HK$10 million and key personnel with five years of public-fund experience. In Singapore, through a retail LFMC: a five-year retail record, S$1 billion of group assets and S$1 million of base capital for funds.
People, owners and distribution
Does selling the manager's own funds need a separate licence?
As a rule, no. A Hong Kong manager needs only Type 9 for its own funds and Type 1 for others'; for its own virtual-asset fund the point is unresolved, and the conservative reading is to hold Type 1. A Singapore manager markets its own and related corporations' funds without dealing; accepting unsolicited orders requires adding dealing.
Can passive investors own most of a Singapore manager?
Outside an established group MAS expects the CEO and executive directors to hold over 50% of the votes, with alternatives considered case by case. A stake of 20% or more needs MAS's prior approval.
Does the S$250 million cap still apply to former RFMCs?
Yes, for firms that became A/I LFMCs on Form 1AR in 2024 it remains a licence condition, reviewed on application before AUM exceeds S$250 million. New applicants do not get it by default.
Virtual assets
Can a Type 9 manager run a virtual-asset fund now?
Yes, under additional SFC terms and conditions where the fund targets virtual assets or 10% or more of gross asset value in them, after notifying the SFC. Distributing such a fund in Hong Kong needs Type 1; the primary sources do not say whether that reaches marketing one's own fund, and the conservative reading is to hold Type 1. Only an SFC-authorised fund may be offered to the public.
When will Hong Kong's virtual-asset management licence start?
The Government expects the bill to be introduced in Q4 2026; as at 30.09.2026 it had not been. There will be no deeming, and SFC licensees are promised an expedited process.
Does a Singapore licence cover a spot-token fund?
MAS gives no direct answer. A CMS licence covers capital markets products: spot tokens are not on that list and derivatives contracts are, so on a working reading a spot-token fund falls outside the licence while a token-derivatives fund stays within it. A spot-token fund manager looks at the exemptions for accredited and institutional investors and at the DTSP regime, whose application to such a manager MAS has not addressed either.