The financial services industry has shifted and repositioned itself over the last few years. Spurred by the pandemic, the industry has seen a rise in digitalization efforts to maintain the relationships between the company, employees, and customers. To operate in the financial services industry in Singapore, a company must obtain the necessary licenses.
Types of Financial Service Licenses in Singapore
Setting up a company offering financial services, especially in FinTech, in Singapore could be a strategic move. Ranked 2nd in growth by industry in Singapore by the Ministry of Trade, the finance and insurance industry is expected to grow 4-5% per annum from 2021 to 2025, according to the Monetary Authority of Singapore (MAS).
To operate a financial service company, you must obtain one of the key financial service licenses in Singapore:
Capital Market Services (CMS) License
Financial Adviser’s (FA) License
Capital Market Services License in Singapore
Those who conduct activities which are regulated by the Securities and Futures Act must apply for a Capital Markets Services License, unless exempted. These activities include:
Dealing in securities
Trading in futures contracts
Securities financing
Providing custodial services for securities
Leveraged foreign exchange trading
Advising on corporate finance matters
Fund management
Real estate investment trust management
The CMS License in Singapore can only be applied by corporations. If an individual intends to act as a representative of the CMS License holder in conducting any of the above activities, the individual will need to acquire the related CMS Representative’s License, unless there is an exemption.
Financial Adviser’s License in Singapore
Those who conduct activities that are regulated by the Financial Advisers Act must apply for the Singapore Financial Adviser’s License. These activities include:
Providing advice on investment products such as securities and unit trusts, futures contracts, life insurance policies including investment-linked life insurance policies), foreign exchange and leveraged foreign exchange contracts, and other structured products
Issuing reports on investment products
Making arrangements for life insurance products
Marketing collective investment schemes such as unit trusts
The Financial Services Act in Singapore does not regulate the following areas:
Bank deposits – regulated under the Banking Act.
General insurance – arranged by intermediaries according to the Insurance Act and not considered to be an investment product.
Loans and mortgages – not regulated, also not investment activities.
Similar to the CMS license, only corporations can apply for the FA license and individuals acting as a representative of the FA license holder will need to acquire the FA Representative’s License, unless exempted.
Exempted Entities for CMS & FA Licenses in Singapore
There are some entities who do not apply for such licenses. The list includes the following:
Capital Market Service License |
Financial Adviser’s License |
Banks, merchant banks, finance companies, and insurance companies – these entities are already regulated by the Monetary Authority of Singapore (MAS) under a separate legislation |
Banks, merchant banks, finance companies, and insurance companies – these entities are already regulated by the Monetary Authority of Singapore (MAS) under a separate legislation |
Individuals who are acting on behalf of an exempt person |
Individuals who are acting on behalf of an exempt person |
Individuals who are acting on behalf of CMS license holders who are engaged in custodial services for securities or securities financing |
Individuals who are Singaporean residents and act (directly or indirectly) as financial advisers who give advice on investment products excluding life insurance policies to no more than 30 accredited investors on any occasion. An accredited investor is an individual whose income over the preceding 12 months is either S$300,000 or whose net personal assets exceed S$2 million, a corporation with a net asset amount that exceeds S$10 million, or a trustee of a trust. |
Individuals who are employees of banks or merchant banks and who are registered as associate persons of the Singapore Exchange Derivatives Trading Ltd. |
NOTE: Those who are exempted from holding a CMS or FA license are still required to comply with the same requirements on market practices and conduct as those who hold such a license. You may find more information on these requirements on the MAS website. Eligibility Criteria for Financial Services Licenses Application in Singapore
As with every business license, there is a set of eligibility criteria that you must fulfil before applying for them. The requirements for CMS and FA licenses are listed below.
Corporate Structure and Activities |
- The application must be for a corporation.
- The corporation’s primary business activity must align with the regulated activities specified in the Second Schedule to the Securities and Futures Act.
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Track Record and Management |
- Evidence of a positive track record, management skills, and financial soundness over the preceding five years.
- This requirement extends to any parent company of major shareholders.
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Business Plans and Projections |
- The corporation must have clear business plans and future financial projections in place.
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Internal Compliance Systems |
- Adequate internal compliance systems must be established and operational.
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Financial Requirements |
- The corporation must satisfy the minimum financial requirements listed in the Securities and Futures Act.
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Personal Status of Key Individuals |
- The personal status of the applicant, employees, officers, and substantial shareholders must meet MAS standards.
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Key Personnel |
- Approval from the Monetary Authority of Singapore (MAS) to hire a CEO or Director who is a Singaporean resident.
- At least two full-time employees must be involved in each of the regulated activities for which the corporation is seeking a license.
- These employees must also hold a Representative’s License for the respective activities.
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Capital Requirements for Specific Activities |
- For securities dealing: Cumulative shareholders’ funds of S$200 million.
- For futures contract trading: Cumulative shareholders’ funds of S$100 million.
- For fund management: At least S$1 billion in global funds under management.
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Insurance Requirements |
- For fund management or advising on corporate finance matters, MAS may require a Professional Indemnity Insurance policy, compliant with MAS’s basic requirements.
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Applicant Status |
- Application must be for an individual aged 21 years or older.
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Qualifications and Examination |
- Applicant must meet the minimum academic qualification and examination requirements as stated by MAS.
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Fit and Proper Criteria |
- Applicant must fulfill MAS’s criteria for being a fit and proper person.
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Corporate Structure and Presence |
- Application must be for a corporation with a physical presence in Singapore.
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Financial Requirements |
- Applicant must meet the minimum financial requirements as outlined in Regulation 15 of the Financial Advisers Regulation.
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Business Plans and Projections |
- The corporation must have clear business plans and future financial projections in place.
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Internal Compliance Systems |
- Adequate internal compliance systems must be established and operational.
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Personal Status of Key Individuals |
- The personal status of employees, officers, and substantial shareholders must meet MAS standards.
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Industry Experience |
- At least three years of experience in the financial advisory industry.
- Executive directors, including the CEO, must have at least five years of relevant experience and the proper academic and professional qualifications.
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Insurance Requirements |
- Active professional indemnity insurance policy with a minimum coverage of S$500,000.
- The allowable deductible must not exceed 20% of the applicant’s net asset value at the end of the preceding financial year.
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Applicant Status |
- An individual aged 21 years or older must submit the application.
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Qualifications and Examination |
- Applicant must meet the minimum academic qualification and examination requirements as stated by MAS.
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Fit and Proper Criteria |
- Applicant must fulfill MAS’s criteria for being a fit and proper person.
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