Authorised vs Recognised CIS is an important distinction for fund managers offering Collective Investment Schemes (CIS) in Singapore. Fund managers must understand MAS requirements. This helps determine whether MAS should authorise or recognise a fund.

In Singapore, the Code on Collective Investment Schemes (CIS Code) caters to a broad spectrum of investors. These range from retail participants to sophisticated institutional players. To balance investor protection with market development, MAS classifies schemes 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. Investors, fund managers, and fund management companies all need to understand these distinctions to navigate Singapore’s fund management landscape effectively.

1. Authorised Schemes (Authorised vs Recognised CIS)

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

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).

The Securities and Futures Act defines “relevant persons” as:

I. An accredited investor;

II. 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;

III. 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;

IV. 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

V. 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 Scheme must have a compliant constituent document. This may be a trust deed for unit trusts or a constitution for Variable Capital Companies (VCCs). Key structural requirements include an independent trustee or VCC custodian. The Manager must also meet the requisite expertise and assets under management thresholds.

Prior to formal filing, the CIS Code provides that Managers should consult MAS where a Scheme involves a novel structure, investment strategy, or risk profile. MAS then assesses whether the Scheme satisfies the Core Requirements in the Appendices. This covers permissible investments, diversification limits, and borrowing restrictions. For cross-border offers, MAS may also assess whether the Scheme qualifies 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. A 20% or greater shareholding interest overlap between the Manager and the trustee or custodian compromises independence.

    [1] MAS Code on Collective Investment Schemes, Chapter 2.1 (p. 7). Shareholding primarily defines independence. A trustee is generally not independent if it shares 20% or more common shareholding, including deemed interests, with 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 served as an officer or director of the Manager or custodian in the current or preceding financial year.

• • Operational Timelines:

    Managers must generally pay redemption proceeds 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 must send semi-annual accounts and reports to participants within two months of the end of the relevant period. They must also issue annual accounts and audited reports 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. The CIS Code is non-statutory. However, MAS may consider breaches when deciding whether to revoke or suspend a Scheme’s authorisation. MAS may also consider them when assessing future applications by the same responsible person.

2. Recognised Schemes (Authorised vs Recognised CIS)

Recognised Schemes are CIS constituted outside Singapore. MAS grants formal recognition to these schemes under Section 287 of the SFA. This allows foreign funds to be offered and marketed in Singapore, provided they are regulated under a jurisdiction offering investors protection at least equivalent to Singapore’s Authorised Schemes.

The CIS Code does not provide an exhaustive list of approved jurisdictions. Instead, it considers a jurisdiction “equivalent” where 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, Managers may offer schemes from signatory jurisdictions in Singapore. MAS must assess these schemes as Qualifying CIS, and they must 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: Managers may offer Recognised Schemes 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 an approved exchange approves the Scheme’s units for listing and trading.

• • Ongoing Notification of Home Status: Managers must notify MAS as soon as practicable, and 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: Managers must submit updated documentation of the Scheme’s risk management framework to MAS no later than one month after the home financial supervisory authority approves it.

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

Authorised vs Recognised CIS: Key Differences

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

Based on the revised CIS Code, last updated on 28 November 2025, the CIS Code introduces 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 fully converges with International Financial Reporting Standards (IFRS), keeping scheme reporting aligned with global accounting benchmarks.

• • Property Funds must maintain a minimum Interest Coverage Ratio (ICR) of 1.5 times to adequately cover interest expenses and borrowing costs.

• • Property Fund Managers must include sensitivity analyses in their reports. These analyses must show 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, Managers must notify MAS within 14 days.

• • MAS has introduced a transition period for Authorised Schemes. Managers 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 navigating Singapore’s collective investment scheme landscape. Our services cover fund setup, licensing, regulatory monitoring, documentation, and corporate governance. We help clients maintain compliance while improving operational efficiency and decision-making.

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