The SGX ETF market today
Record assets, a doubling of turnover in a single quarter, and demand arriving through channels that did not exist at scale five years ago.
Record high. Net inflows of S$1.3bn in 1Q26: S$1.8bn into 35 ETFs, S$504m out of 15.1
Gold +164%, Equity +141%. January 2026 set a record at S$65m a day.1
Robo-advisers, regular savings plans and retirement schemes. Was S$0.5bn in Dec-19.1
CSOP CSAM CSI A500 (SUN), UOBAM Ping An FTSE ASEAN Dividend (UPD | UPU), LionGlobal SG Physical Gold (GLS | GLU).1
Retail is now 42% of the market. Retail ETF AUM rose 57% year on year to S$8bn, against S$11bn held by institutions. That is a different market from the one issuers modelled in 2019, when retail was 29% and the whole market was under S$5bn. Every SGX-listed ETF is SRS-eligible, and a subset is eligible under the CPF Ordinary Account Investment Scheme.1
SGX reports 53 ETF and L&I products. Counted by trading counter — dual-currency and dual-class listings counted separately — the same market is roughly 92 lines. Both numbers are correct; they answer different questions. Product counts are used throughout this document.
Where the white space is
Fifty-three products across four asset classes. Mapped against geography, most of the grid is empty.
The existing shelf is concentrated: 36 equity products, 10 fixed income, 5 REIT, 2 gold. Geographically it is Singapore (14), China (15) and regional or global (24). Read as a matrix, the concentration becomes a map of what has not been built.
| Singapore | China | Japan | India | SE Asia | Asia / EM | US | Europe | Global | |
|---|---|---|---|---|---|---|---|---|---|
| Equity | 7 | 13 | 1 | 2 | 4 | 7 | 2 | — | — |
| Fixed income | 4 | 2 | — | — | — | 2 | — | — | 2 |
| REIT & property | 2 | — | — | — | — | 3 | — | — | — |
| Commodity | 1 | — | — | — | — | — | — | — | 1 |
| Multi-asset & allocation | — | — | — | — | — | — | — | — | — |
| Income overlay & options | — | — | — | — | — | — | — | — | — |
| Digital assets | — | — | — | — | — | — | — | — | — |
Product counts derived from the SGX ETF product map, March 2026. Products classified once, by primary exposure. Leveraged and inverse products are included in the equity row.1
Empty rows
No multi-asset or allocation ETF. No income-overlay or covered-call product, despite a retail base that buys for yield — REIT and dividend products dominate retail purchases. No digital-asset product. No target-maturity bond series.
Empty columns
No European equity or credit exposure at all. One Japan product, and it is active. Two India products. US exposure is two S&P 500 and Dow trackers, both cross-listed.
Thin depth where it matters
Only 3 of 53 products are active, four years after the framework opened in December 2023. Fixed income is 10 products against 36 in equity, in a market whose retail base is buying income.
The gaps are not evidence of absent demand — they are evidence of manufacturing capacity. Every issuer in this market has assembled the same eleven components separately, at sub-scale pricing. The economics of filling a single empty cell are set out in §14, and in full in the detailed issuer briefing.
The addressable pool
S$19bn of ETF assets sits inside a S$6 trillion Singapore asset management industry. And that S$6 trillion is not the whole pool.
The S$6 trillion figure understates the accessible market, in four directions.
- It measures assets managed from Singapore, not assets investable through Singapore. Cross-listed UCITS reach European and international books that never appear in the survey; the ICSD settlement model makes those units fungible between markets (§08).
- It excludes the China channel. The ETF Product Link routes Chinese retail and institutional money into SGX-listed masters through QDII, and international money into China through QFI feeders (§12). That is a separate pool with its own scale.
- It does not capture the retirement and mandated-savings pools by potential. SRS and CPF-IS ETF holdings are S$1.4bn today — against a scheme balance base orders of magnitude larger, and every SGX-listed ETF is SRS-eligible from day one.
- It excludes secondary-market liquidity. Dual-currency counters in six currencies (SGD, USD, EUR, HKD, AUD, CNH) let one fund draw on separate currency-preference investor bases without separate share pools (§08).
Sustainable finance
Sustainability-linked ETF AUM on SGX has crossed S$2.5bn, alongside MAS's long-term green finance strategy.1
Fintech distribution
Regular savings plans and robo-advisers carry S$1.4bn and grew 366% since 2020 — the fastest-growing distribution surface in the market.1
Wealth management hub
Singapore is the gateway for global managers into regional growth, with family-office capital now able to count qualifying ETF investments toward deployment requirements (§11).
Pre- and post-listing support, orchestrated
ETF-X runs the launch and the years after it. The SGX and MAS programmes are instruments we hold and deploy on your behalf — not a separate queue you join.
Most of what follows exists in the market. The difficulty is that it exists in pieces: a grant administered by MAS on a three-month clock, an education platform run by the Exchange, a market-making rulebook, a research funding scheme with its own eligibility test, and a distribution network of brokers and digital platforms each with a separate onboarding path. An issuer arriving alone assembles these one at a time, in sequence, mostly after listing.
ETF-X sequences them as one programme, and starts before the listing application does. Each column below is a workstream we own end to end; the SGX and MAS entitlements are named where they are the funding or infrastructure behind that workstream.
01 · Demand, built ahead of listing
We run the investor education and campaign programme for your product — course content built around your specific exposure, a scheduled campaign calendar rather than a single launch push, issuer–distributor partner events across the broker and digital-platform network, and independent analyst, social-media and influencer outreach.
Deployed through: SGX Academy, 300+ courses and 15,000 participants a year, including ETF 101 and portfolio construction; SGX's ETF digital campaigns; the broker–issuer partner event framework.
02 · Listing, liquidity and settlement
We run the listing execution, appoint a DMM panel matched to product type rather than defaulting to one house (§15), negotiate the market-making terms, structure the currency counters and settlement model, provide matching seed capital, and file the grant application inside the three-month post-listing window.
Deployed through: the GEMS Listing Grant and ETF Product Link (§11); SGX-approved DMMs under Rulebook Chapter 6; commercial market maker and liquidity provider schemes; dual currency trading in six currencies; DVP and FOP settlement for creations and redemptions.
03 · Research and distribution
We run the research coverage through the Smartkarma network — itself a GEMS-eligible research channel, so coverage of your product is funded rather than bought — produce the dissemination formats the grant pays for, and run joint institutional roadshows and retail broker programmes.
Deployed through: the GEMS Research Development & Dissemination Grant; SGX joint investor roadshows and in-house research; retail broker partnerships; traditional media (CNBC, CNA) and social outreach to retail investors and trading representatives.
Two of these workstreams are funded rather than paid for. The ETF Listing Grant is worth up to S$250,000 per primary-listed ETF — more than the upper end of the indicative all-in setup cost of S$97k–247k (§14) — and the Research Development & Dissemination Grant funds coverage of your product at S$4,000–5,000 per report.
Both are claimable only against conditions with deadlines attached: an Initial Offer Period, a marketing plan filed with the application, a two-year minimum listing, a three-month filing window, and a research provider that already qualifies. Owning that sequence from the start is the difference between the entitlement being available and it being realised.
Three routes to a listing
Every SGX-listed ETF is a collective investment scheme, either authorised under s286 of the SFA or recognised under s287. The route determines your wrapper, your licensing burden and your timeline.
| Authorised scheme | Recognised scheme | China–Singapore ETF Link | |
|---|---|---|---|
| Domicile | Singapore-domiciled. Unit trust or VCC. | Constituted outside Singapore. UCITS (Ireland ICAV, Luxembourg) or ASEAN (MY / TH). | Master–feeder across SGX and SSE / SZSE. |
| Manager | Must hold a Capital Markets Services licence for fund management, or an exemption, to offer an authorised fund in Singapore. | Must be licensed or regulated in the jurisdiction of its principal place of business. Must appoint a local representative as investor liaison. | Must hold a CMS licence and be approved to offer authorised funds to retail investors in Singapore. |
| Regime | Trust deed meeting SFR requirements; CIS-approved trustee; full compliance with the Code on Collective Investment Schemes. | Home jurisdiction must be regulated and supervised comparably to Singapore. Not subject to the Code's investment guidelines. SFA-compliant prospectus lodged and registered. | Full CIS authorisation and disclosure under the SFA and the Code, plus SGX-ST Chapter 4 and the ETF Link requirements (§12). |
| Discretionary AUM test | — | Manager should manage at least S$500m of discretionary funds in Singapore — waived if the fund is listed on SGX. | — |
| Prospectus | SFA-compliant prospectus lodged and registered. | Foreign prospectus as base reference plus a Singapore wrapper containing all SFA-required information. | Prospectus must carry master-ETF information ordinarily required under SGX's ETF framework, plus disclosure-lag risk factors. |
| Typical use | Preferred for white-label Local product, SRS and CPF-IS eligibility, GEMS primary listing grant of S$250k. | Cross-listing Existing UCITS range extended into Asia. Cross-listed grant S$180k. | China access Feeder into an SSE / SZSE master via QFI, or a Chinese feeder into your SGX master via QDII. |
Sources: SGX ETF listing framework; SFA s286 and s287; Code on Collective Investment Schemes.13
Admission requirements
Size, portfolio and standing obligations, by scheme.
ETF under authorised scheme
Minimum asset size S$20m
- Abide by the Code on Collective Investment Schemes
- Limit investments in related companies to 10% of gross assets
- Restrict investments in unlisted securities to 30% of gross assets
ETF under recognised scheme
Minimum asset size US$20m
- Must be listed, or approved for listing, on a foreign stock exchange acceptable to SGX, where the ETF is incorporated or established in a foreign country
- Not subject to the Code's investment guidelines
Applying to both
| ✓ | Issuer must appoint a Designated Market Maker approved by SGX-ST |
| ✓ | Issuer may not change its investment objectives and policies in the first three years |
| ✓ | Feeder ETFs under the SSE / SZSE–SGX ETF Link are subject to the additional ETF Link requirements (§12) |
| ✓ | Active ETFs are subject to the additional Active ETF requirements (§07) |
Active ETF requirements
SGX RegCo's Practice Note 4.3, issued 4 December 2023. The first active ETF — Lion-Nomura Japan Active ETF, jointly managed by Lion Global Investors and Nomura Asset Management — listed in January 2024. Three active products are listed today.
Disclosure
The ETF must prominently disclose in the prospectus or offering document — and in all marketing materials — that it is actively managed.
Specifically it must disclose: (a) that it is an actively managed ETF; (b) its investment style, in terms a retail investor would plainly understand; (c) its investment limits and constraints, and how these affect risk and expected return; and (d) where it is not managed against any benchmark, a clear statement to that effect with an explanation of why, and the associated risks.
Investment style & governance
As best practice, adopt the disclosures and practices in MAS Circular CMI 32/2020, Good Disclosure Practices for Actively Managed Funds.
Processes must ensure that directors or senior management have effective oversight of the ETF's operations, and that promotional materials are clear, fair, balanced, non-misleading and fully compliant.
Investment manager track record
Rule 404(5). The management company must be reputable with an established track record, generally in operation at least five years. For an active ETF, that track record must be in managing other actively managed funds.
Rule 404(6). The individuals responsible must have at least five years managing investments, with satisfactory experience in the particular fund type — for an active ETF, in actively managed funds specifically.
Continuing obligations
- NAV. Publish daily NAV per unit on the website by the business day following each trading day, before market open; announce NAV per unit via SGXNET at the end of each week.
- iNAV. Publish on the issuer's website at least every 15 seconds during Exchange trading hours; ensure it accurately indicates NAV so far as practicable; meet prospectus disclosure requirements.
- Holdings. Publish full portfolio holdings at least monthly on SGXNET and the website. Disclosure for market-making purposes may be made only to the ETF's DMMs on a need-to-know basis, under confidentiality restraints.
- Performance. Publish at least monthly, with benchmark where applicable, over 3-month, 6-month, 1-, 3-, 5- and 10-year and since-inception periods.
Source: SGX-ST Practice Note 4.3, Actively Managed Exchange Traded Funds.4
Structures
Three structural choices that materially change distribution reach: the wrapper, the settlement model, and the currency counters.
Variable Capital Company (VCC)
Launched by MAS and ACRA on 15 January 2020, the VCC is a corporate structure purpose-built as an investment fund vehicle, complementing companies, limited partnerships and unit trusts. It can be a standalone fund or an umbrella with sub-funds, across traditional and alternative strategies.
Capital flexibility
Greater flexibility in issuing and redeeming shares, and in paying dividends out of capital.
Ring-fencing
Assets and liabilities segregated in each sub-fund — enhanced safeguards for an umbrella range.
Tax
Treated as a single entity for tax purposes and eligible for tax exemption.
Strategy-agnostic
Usable for all traditional and alternative strategies, open-ended or closed-end.
Manager requirement
Must be managed by a fund manager regulated by MAS.
Re-domiciliation
Foreign corporate entities can re-domicile into Singapore as VCCs.
ICSD model for UCITS ETFs
The international central securities depository settlement model is available in Singapore, allowing ETF units to move across international stock exchanges. Issuance goes into one of the two ICSDs — Clearstream Banking Luxembourg or Euroclear Bank — and once issued, shares settle freely between them. Units issued into an ICSD and cross-listed onto SGX are fungible between markets. This is the settlement infrastructure European issuers use to extend distribution into Asia through SGX.
Dual currency trading
A single ETF can carry counters in two currencies, fully fungible — shares trade seamlessly between the two without moving between pools. Investors choose their preferred currency based on need and currency outlook, with clearing and settlement handled behind the counters. Available currencies: SGD, USD, EUR, HKD, AUD and CNH.
Roughly a third of the listed range already uses it. Examples include CSOP iEdge S-REIT Leaders (SRT / SRU), ICBC CSOP FTSE Chinese Government Bond (CYC / CYB), Lion-OCBC Securities Hang Seng TECH (HST / HSS), SPDR Gold Shares (GSD / O87), UOB APAC Green REIT (GRN / GRE) and Xtrackers MSCI China UCITS (TID / LG9).
Listing process and timeline
Twelve to sixteen weeks for a new issuer, across three phases and two regulatory tracks that can run concurrently or in sequence.
Pre-submission engagement with MAS and SGX on listing intention, the ETF and the structure. Authorised scheme (Singapore-domiciled or Singapore–China ETF Link) or recognised scheme (ASEAN / UCITS) is settled here.
Regulatory review and issuance of Eligibility to List (ETL) by SGX — seven weeks. Registration of the prospectus with MAS runs concurrently over three weeks.
Preparation for listing, including marketing and distribution. The IOP itself typically runs one to two weeks where applicable.
What you submit
Seven weeks or shorter review on submission of a complete pack. Incomplete packs are where timelines slip.
Application letter
- Introduction and purpose
- Background of the ETF
Supporting documents
- Prospectus
- Compliance checklist for listing of investment funds (ETF)
- Memorandum and Articles of Association, if applicable
- Trust deed, if applicable
- Payment of the initial listing fee
Marketing plans and promotional material for the ETF must be included in the grant application submission — and the grant application must be filed no later than three months after the issuance or listing date. Prepare the marketing pack alongside the listing pack, not after listing (§11).
Grants and tax incentives
The Grant for Equity Market Singapore scheme runs 21 July 2025 to 31 December 2028, and family-office capital deployment rules now recognise qualifying ETF investments.
ETF Listing Grant
Conditions. The ETF must be newly listed on SGX; launched with an IOP; remain listed at least two years; and marketing plans and promotional material must be included in the application. For cross-listed ETFs whose shares have already been issued in another market, issuers may still be assessed as meeting the IOP criterion where they demonstrate proactive engagement with product distributors on pre- and post-launch marketing.
How to apply. Write to fsdf_ext@mas.gov.sg for the latest application form. Applications must be submitted no later than three months after the issuance or listing date.
ETF Research Development & Dissemination Grant
| Research Development Grant | Research Dissemination Grant | |
|---|---|---|
| Eligible applicants | Financial institutions with equity research capabilities — brokers, fund managers, VC and PE firms, private banks, credit rating agencies — and independent research providers based in Singapore, including those serving accredited and institutional investors. | Approved participants under the Research Development Grant. |
| Qualifying activity | Basic tier: minimum 20 equity research reports a year. Enhanced tier: at least 40 reports. |
Produce and disseminate financial research materials in video or non-video digital formats, in-house or through Key Opinion Leaders specialising in financial research. Digital content must be based on a qualifying report and meet a minimum of 5,000 views per dissemination. |
| Funding level | S$4,000 per report on the basic tier. S$5,000 per report from the 40th report, capped at the 80th, on the enhanced tier. |
S$4,000 per video-format dissemination. S$2,500 per non-video dissemination. Capped at 12 disseminations a year per applicant. |
Enquiries: gemsresearch@SGX.com. Source: MAS, Grant for Equity Market Singapore scheme.6
Fund tax incentive schemes for family offices — capital deployment
The latest update to the Fund Tax Incentive Schemes for Family Offices specifies that the Capital Deployment Requirement recognises ETF investments with a master fund listed on SGX. Capital that a family office deploys into feeder ETFs listed on SSE or SZSE therefore counts toward its Capital Deployment Requirement under the Section 13O and 13U incentives for funds managed by single family offices.
2× multiplier
Investment in Singapore-listed equities, and in eligible ETFs investing primarily in Singapore-listed equities. Applies where the ETF's underlying securities are more than 50% Singapore-listed equities.
1× multiplier
Investment through the ETF Product Link where underlying securities are less than 50% Singapore-listed equities.
A Singapore-equity-mandated ETF carries a 2× deployment multiplier for single family offices. That makes the product structurally attractive to a specific, sizeable and locally concentrated buyer base — before any performance argument is made.
China–Singapore ETF Product Link
A master–feeder structure operating under the QFI and QDII schemes, opening cross-border flow in both directions.
Currently eligible master ETFs cover equity ETFs characteristic of the home market — broad market, sectoral and thematic index trackers. Other asset classes may follow as the link develops.
Feeder ETF requirements
- Comply with authorisation and disclosure requirements for CIS under the SFA 2001 and the Code
- Manager must hold a CMS licence for fund management and be approved to offer authorised funds to retail investors in Singapore
- Subject to SGX-ST Chapter 4 listing rules, plus: prospectus must carry master-ETF information ordinarily required under SGX's ETF framework where publicly available and relevant; must carry risk factors on disclosure time lag and Chinese-language disclosure; and must disclose in English, on a continuing and timely basis, information likely to materially affect the feeder's unit price once made public by the master
Master ETF criteria
- Publicly offered securities investment fund registered with the CSRC, managed by a CSRC-licensed firm
- Listed on SSE or SZSE for at least one year, and either a fund size of at least S$150m, or a fund size of at least S$50m where the master's manager has at least S$1bn AUM globally
- Master's manager has a five-year investment management track record
- Master, its manager and its trustee/custodian have a good compliance record in the home jurisdiction — the feeder's manager must establish this to MAS's satisfaction
- Master uses only full or sampling-based physical replication
- Securities lending or repo only for efficient portfolio management, and total value of such transactions must not exceed 50% of the master's NAV at any time
Source: MAS CFC 03/2022, guidance on requirements applicable to ETFs participating in the SZSE-SGX and SSE-SGX ETF Link.7
Creation and redemption
Primary market mechanics for a local issuer, with the CDP cut-offs that govern them.
Creation flow
Barring unforeseen circumstances, the credit completes by 12:00 the following day after the creation request is submitted to CDP, provided the request reaches CDP by 15:00 on the submission date and the issuer, trustee and depository agent give proper and timely instructions.
Redemption flow
The debit completes by 12:00 the following day, provided the issuer's or trustee's depository agent has sufficient securities in its sub-account, the redemption request reaches CDP by 15:00 on the submission date, and instructions are proper and timely.
Creation and redemption fees
No costs arise at the participating dealer, the issuer, trustee or registrar, or at CDP. Fees are incurred at the depository-agent movement layer, and they scale with the number of lines in the basket — not with the size of the order.
| Settlement type | Basis | Worked example | Fee type |
|---|---|---|---|
| Cash | FOP, S$40 × 2 movements | S$80 | — |
| In kind — FOP | S$40 × 2 × (30 stock lines + 1) | S$2,480 | Type A |
| In kind — DVP | S$41 × 2 × (30 stock lines + 1) | S$2,542 | Type A |
| In kind — trade-related transfer | S$40/41 × 2, plus S$30/31 × 2 × 30 stock lines | S$1,860 | Type B |
Worked on a 30-line basket. Type B is the trade-related transfer rate, allowed up until settlement date + 2. Source: SGX ETF creation/redemption timing, primary listing, August 2025.8
A 30-line basket costs roughly 31× a cash creation to settle in kind. Basket construction, and the choice between cash and in-kind creation, is a live cost decision on every primary-market order — not a documentation detail.
Indicative cost of listing
SGX's published fee schedule, and an indicative view of what it costs to bring a product to market and run it.
SGX listing fees
Initial fees
| Initial listing fee — fixed, non-refundable | S$10,000 |
| CDP processing fees | S$15,000 Waived to 31 Dec 2026 |
Annual listing fees — tiered on AUM
| Minimum | S$400 |
| First S$350m | S$55 per S$1m AUM |
| S$350m to S$1,000m | S$35 per S$1m AUM |
| Above S$1,000m | S$20 per S$1m AUM |
| Maximum | S$30,000 |
Money market ETFs: S$100 per S$1m AUM, no maximum. The maximum applies to ETFs with minimum average daily turnover of S$1m. Euroclear asset servicing and central maintenance fees (currently 0.009% of ETF AUM held under CDP) are passed on for UCITS ICSD cross-listings. Corporate action fees for dividend distribution and annual retainer fees apply.
Maintenance and corporate action fees
Retainer fee — maintenance of depositor records
| Depositors | Monthly | Annual |
|---|---|---|
| ≤ 500 | S$150 | S$1,800 |
| 501 – 3,000 | S$450 | S$5,400 |
| > 3,000 | S$750 | S$9,000 |
Billed 12 months in advance in July. Depositor count determined as at 30 June each year.
Cash dividend / cash to foreign shareholders
Administrative and handling: S$3,250 per issue. Processing: S$2.50 per record for the first 5,000; S$1.875 for the next 10,000; S$1.25 beyond 15,000. Plus out-of-pocket expenses.
REIT ETF cash distribution
Tax handling administrative and handling: S$2,000 per issue; processing S$0.30 per record. Cartridge validation S$200 per run; submission to IRAS S$150 per submission.
Scrip dividend / DRP / currency election
Administrative and handling: S$18,000 per issue. Processing: S$6.60 per record for the first 5,000; S$5.00 for the next 5,000; S$2.20 beyond 10,000.
Stock split / delisting of 'A' securities / conversion / consolidation
Administrative and handling: S$5,000 per issue. Processing: S$2.00 per record for the first 5,000; S$1.50 for the next 5,000; S$1.00 beyond 10,000.
Source: SGX Securities Listing Fee Schedule, 2026.5
Indicative listing setup cost
| Component | Lower | Upper | Average | Notes |
|---|---|---|---|---|
| Legal — filings, trustee, product documentation, deed | 50.0 | 150.0 | 100.0 | |
| SGX listing fees | 10.0 | 10.0 | 10.0 | |
| MAS lodgement fees | 3.2 | 4.0 | 3.6 | |
| Tax adviser | 6.0 | 15.0 | 10.5 | Where applicable |
| Index licence | 25.0 | 60.0 | 42.5 | Where applicable |
| Miscellaneous — LEI code, website, other | 2.5 | 7.5 | 5.0 | |
| Total setup | 96.7 | 246.5 | 171.6 | S$ thousands |
A primary-listed ETF qualifying for the full S$250,000 GEMS Listing Grant covers the upper end of this range. The economic question is not the cost of listing; it is the cost of the operating capability behind the listing, and the AUM at which it breaks even.
Indicative Initial Offer Period costs
| Line | Unit fee | Units | S$ | Notes |
|---|---|---|---|---|
| Electronic Share Application (ESA) | 6.00 | 1 | 6 | |
| ESA account processing fees | 4.50 | 5,000 | 22,500 | |
| ESA bank fees | 30.00 | 3 | 90 | Assuming three banks |
| ESA bank variable fees | 25 bps | S$50m | 125,000 | On amount raised |
| Broker / dealer variable fees | 15–25 bps | S$25m | 37,500 | On amount raised |
The fixed lines total roughly S$22,600. The two variable lines scale with the raise — on the S$50m and S$25m illustrations above they add S$162,500, so the all-in IOP cost is a function of the offer size rather than a fixed number.9
Product economics by AUM
| AUM, S$m | 20 | 50 | 100 | 250 | 500 | 1,000 |
|---|---|---|---|---|---|---|
| Revenue at 70bps TER | 140 | 350 | 700 | 1,750 | 3,500 | 7,000 |
| Platform fees — base + variable | 99 | 135 | 183 | 318 | 575 | 975 |
| Third-party costs — DMM, legal, trustee, new issuance | 180 | 180 | 180 | 200 | 250 | 400 |
| P&L | −139 | 35 | 337 | 1,232 | 2,675 | 5,625 |
All figures S$ thousands, annual. Platform fees comprise a base of S$75k plus a variable component tapering from 1.2bps to 0.9bps as AUM rises. Indicative only, not a quotation. Break-even sits between S$20m and S$50m of AUM — at or just above the S$20m minimum asset size for an authorised scheme.9
Benchmark 1 — European white-label platform, single UCITS ETF
An established European white-label ETF platform's indicative cost summary for a single UCITS ETF, reproduced as a market reference for what third-party manufacturing economics look like at each level of scale. The provider is not identified. It is not ETF-X's economics.
| Total AUM, €m | 0 | 8 | 50 | 100 | 250 | 500 | 1,000 |
|---|---|---|---|---|---|---|---|
| Revenue at 86 bps TER | 0 | 68,800 | 430,000 | 860,000 | 2,150,000 | 4,300,000 | 8,600,000 |
| Third-party costs, fixed and variable | (206,112) | (207,544) | (215,062) | (242,579) | (403,615) | (639,789) | (1,019,294) |
| Platform fee, £75k per annum plus bps | (86,776) | (88,376) | (96,776) | (106,776) | (167,355) | (317,355) | (617,355) |
| Additional listings and registrations | (20,900) | (20,900) | (21,400) | (25,900) | (25,900) | (25,900) | (32,400) |
| Profit or loss | (313,788) | (248,020) | 96,762 | 484,745 | 1,553,129 | 3,316,956 | 6,930,951 |
Indicative summary of third-party expenses and platform fees, one ETF, EUR. Setup cost €25,000. Break-even falls between €8m and €50m of AUM, at approximately €45m on the interpolated curve.10
Benchmark 2 — UCITS launch followed by SGX cross-listing
The alternative route: launch a UCITS with a large global partner, then cross-list onto SGX. The structure below reflects an existing, grandfathered arrangement with a global manager, quoted as an indicative benchmark. The partner is not identified.
Cost. At 15–20 bps plus €200k fixed, the UCITS-plus-cross-listing route costs materially more per basis point of TER than a direct SGX listing, and roughly three times the platform fee tapering from 1.2 to 0.9 bps in the table above. The European white-label benchmark sits in between, at £75k per annum plus basis points.
Time. Nine months against twelve to sixteen weeks.
Access. The €250m+ threshold means the route is unavailable for the products that fill the white space in §02 — which are, by definition, launching into unproven demand. A direct SGX listing breaks even between S$20m and S$50m of AUM.
The build-versus-partner cost stack, the interactive break-even model and the underlying benchmark detail are in the detailed issuer briefing, §09.
ETF-X professional services panel
One appointment instead of eleven. Each counterparty pre-negotiated, and matched to the product rather than taken as a default.
Licence cover
Where required, the Capital Markets Services licence and regulatory capital sit with the platform rather than the issuer — removing the retail LFMC licensing project from the critical path, and the carrying cost of S$1m base capital from the P&L.
Legal counsel
Panel firms with SGX ETF listing experience:
- Allen & Gledhill LLP
- Chan & Goh
- Greenberg Traurig Singapore LLP
Trustee
DBS, as MAS CIS-approved trustee. Required for any authorised scheme, alongside a trust deed meeting the prescribed SFR requirements.
Designated market makers
Local and smaller products: Phillip Securities, Northpoint Global, Tysaurus.
Cross-border and complex products: Flow Traders, Jane Street — higher fees, broader pricing capability.
Panel approach Match the DMM to the product type rather than appointing one house across a range.
Matching seed capital
Seed capital matched against issuer commitment, to clear the S$20m authorised-scheme minimum asset size and give the DMM a book to quote against from day one.
Distribution and research
Research coverage through the Smartkarma network, GEMS-eligible dissemination formats, retail broker and digital-platform partnerships, and independent analyst and influencer outreach (§04).
The full SGX-approved DMM list also includes China Merchants Securities Investment Management (HK), CLSA Singapore, Guotai Junan Investments (HK) and others — see §16.
Trading specifications and resources
| Trading platform | SGX-ST REACH |
| Trading hours (SGT) | 09:00–12:00 and 13:00–17:00. Mid-day break 12:00–13:00. Pre-open routine 08:30–09:00. Pre-close routine 17:00–17:06. |
| Board lot size | 1 unit |
| Currency | SGD, USD, CNH, HKD, EUR, AUD. Dual currency trading available for selected ETFs. |
| Settlement basis | T+2 in CDP |
| Daily closing price | An official closing price computed and published daily regardless of the ETF's trading activity; derived either from a traded price or from the best bid or offer; published after market close and available on SGX's website and major data vendor price pages. |
| Issuers | Amundi Asset Management · BlackRock (Singapore) · CGS International Securities · CSOP Asset Management · DWS Investments · Nikko Asset Management Asia · Lion Global Investors · Phillip Capital Management (S) · UOB Asset Management · State Street Global Advisors |
| Designated market makers | China Merchants Securities Investment Management (HK) · CLSA Singapore · Flow Traders Asia · Guotai Junan Investments (HK) · Jane Street Financial · Phillip Securities · Northpoint Global |
| Data codes | Bloomberg SGXT <GO> · Reuters o#ETF.SI · Full list at sgx.com/etf |
Rules, requirements and schemes
| Resource | Link |
|---|---|
| MAS licensing framework for fund management companies | Registration and licensing · Guidelines SFA 04-G05 · FAQs |
| Code on Collective Investment Schemes | mas.gov.sg — Code on CIS |
| Requirements for ETFs in the SZSE-SGX and SSE-SGX ETF Link | MAS CFC 03/2022 |
| SGX-ST listing rules, Chapter 4: Investment Funds | rulebook.sgx.com — Chapter 4 · Practice Note 4.3, Active ETFs |
| Grant for Equity Market Singapore — listing and research grants | mas.gov.sg — GEMS |
| Capital deployment requirement, fund tax incentive schemes for family offices | mas.gov.sg — FO tax incentives |
ETF-X
Overview
etfx.smartkarma.com — the ETF-X platform deck.
Detailed issuer briefing
The operating chain behind an SGX-listed ETF — primary market through CDP settlement, the risk register, the build-versus-partner cost model, and the live SGX ETF screener.
Sources
- SGX, SGX as a leading Asia ETF listing venue, SGX Securities, 2026Source for all 1Q2026 market statistics, the product map and counts, the listing process and timeline, admission criteria, scheme comparison, support programmes, VCC, ICSD and dual-currency appendices, trading specifications and the DMM and issuer lists. Market data as at March 2026.
- Monetary Authority of Singapore, Singapore Asset Management Survey 2024Source for the S$6 trillion of assets under management in Singapore.
- Securities and Futures Act 2001, s286 and s287; Code on Collective Investment SchemesStatutory basis for authorised and recognised schemes and the associated manager, trustee and prospectus requirements.
- SGX-ST Practice Note 4.3, Actively Managed Exchange Traded Funds, 4 December 2023Source for active ETF disclosure, investment style, manager track record and continuing listing obligations, including Rules 404(5) and 404(6). Referenced alongside MAS Circular CMI 32/2020 on good disclosure practices for actively managed funds.
- SGX, Listing Fee Schedule, SGX Securities, 2026Source for initial listing fees, CDP processing fees, tiered annual listing fees, retainer fees and corporate action fees, and the Euroclear pass-through rate for UCITS ICSD cross-listings.
- Monetary Authority of Singapore, Grant for Equity Market Singapore schemeSource for the ETF Listing Grant and the Research Development & Dissemination Grant, funding levels and conditions. Grant period 21 July 2025 to 31 December 2028.
- MAS Circular CFC 03/2022, Guidance on requirements applicable to ETFs participating in the SZSE-SGX and SSE-SGX ETF LinkSource for feeder ETF authorisation and disclosure requirements and the master ETF criteria.
- SGX, ETF creation/redemption timing — primary listing, August 2025Source for the creation and redemption flows, CDP cut-off times and the creation/redemption fee worked examples.
- ETF-X indicative fee scheduleInternal. Source for the listing setup cost range, Initial Offer Period cost lines and the product economics by AUM. Indicative estimates calibrated to Singapore market rates, not a quotation.
- European white-label ETF platform, indicative summary of third-party expenses and platform feesConfidential third-party document, one UCITS ETF, EUR, provided to ETF-X. Provider not identified. Setup cost €25,000, platform fee of approximately £75,000 per annum plus basis points, revenue modelled at 86 bps TER. Reproduced as an independent market benchmark. Not ETF-X pricing.
- Global manager UCITS and cross-listing arrangement, indicative termsExisting grandfathered arrangement with a large global asset manager, provided to ETF-X as an indicative benchmark. Partner not identified. UCITS setup €200,000 fixed plus 15–20 bps, low end of range for easier underlyings; SGX cross-listing approximately 2 bps; approximately nine months to market including the cross-listing; partner prioritises opportunities at €250m+ expected AUM. Not ETF-X pricing.
ETF-X. Infrastructure within which ETFs on SGX can scale. Powered by Smartkarma.
Prepared for discussion with prospective issuer partners. Not an offer, solicitation or investment advice, and not a prospectus or product document. Market data is point-in-time and indicative. Fee and cost figures marked indicative are internal estimates calibrated to Singapore market rates and are not a quotation. The two benchmarks in §14 are drawn from confidential third-party documents, are reproduced for benchmarking only, and are not ETF-X's economics; neither provider is identified. Regulatory references are summaries of the sources above and do not constitute legal advice. Reference to SGX and MAS programmes does not constitute approval or endorsement by either institution.