On 7 April 2026, the Financial Supervisory Commission amended the Q&A for Offshore Funds to establish minimum personnel requirements for securities investment trust and advisory enterprises (SITE/SICE) conducting private placement of offshore funds and sales/advisory/administrative services for offshore funds not qualifying as securities investment trust funds (Non-SIT Funds). The scope of concurrent duties permitted for master agents’ product analysts was also expanded. A one-year grace period is given.
| Amendment | Previous Rule | Amended Rule | Remarks |
| Scope of Duties for Product Analysts (Amended) | Restricted to master agent’s offshore fund business only | May handle: 1.Master agent’s offshore fund business 2.Private placement of offshore funds (New) 3.Sales/advisory for Non-SIT Funds (New) 4.Admin services for foreign asset managers (New) | Expanding scope of duties |
| Personnel Requirements for Private Placement, Non-SIT Fund, and Admin Services (New) | No specific provision | Minimum staffing now required: 1.Channel service personnel: at least 3 2.Internal auditors: at least 1 3. Product analysts: at least 1 | Articles 9 and 16 of the Regulations Governing Offshore Funds |
| Grace Period | Must comply within one year from 7 April 2026 (Deadline: 6 April 2027) | Non-compliant entities must review current headcount and initiate hiring plans |
Mike Lu / Jeffrey Liu
