The Trust Freedom Card’s 100,000 miles sign-up bonus is undoubtedly one of the most exciting developments in the miles game in recent times, but what tends to sober people up is the hefty minimum spend requirement.
To unlock the full 100,000 miles, cardholders must spend at least S$15,000 within 31 days, which works out to just under S$485 per day — more than seven times what the average Singapore resident spends daily. If it’s any consolation, there are smaller bonuses of 20,000 miles and 50,000 miles, available at the S$1,000 and S$5,000 mark.
But regardless of which bonus you’re gunning for, you’ll of course want to ensure that your spending doesn’t run afoul of the exclusions list. And as with every mega sign-up offer, there’s been an understandable wave of questions regarding what counts as qualifying spend.
Here’s my attempt at providing some clarity.
Recap: How much must you spend?
 Trust Freedom Card |
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| Apply via app with referral code 2GQEAM81 | |||
| Min. Income | S$30,000 p.a. | Points Validity | 3-4 years |
| Annual Fee | None | Min. Transfer | 1 Trust Mile (1 mile) |
| FCY Fee | None | Transfer Partners | 2 |
| Earn Rate (Miles Mode) |
1.3 mpd (SGD & FCY) |
Transfer Fee | S$27.25 |
| Cardholder Terms and Conditions |
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Here’s a brief recap of how the Trust Freedom Card’s 100,000 miles sign-up bonus is broken down.
| Min. Spend (within 31 days of approval) |
Max Miles Gift | Total Max Miles |
| S$1,000 | 20,000 | 20,000 |
| S$5,000 | 30,000 | 50,000 |
| S$15,000 | 50,000 | 100,000 |
- Once you hit S$1,000, you’ll receive a scratch card for 20,000 Max Miles
- Once you spend a further S$4,000 (S$5,000 total), you’ll receive a second scratch card for 30,000 Max Miles
- Once you spend a further S$10,000 (S$15,000 total), you’ll receive a third scratch card for 50,000 Max Miles
This means that the maximum reward that can be earned is 100,000 Max Miles, across three separate scratch cards, for spending S$15,000.
What won’t count?
Let’s start by going through what you definitely can’t spend on.
Any transaction on the Trust Freedom Card’s rewards exclusion list won’t earn Trust Miles, and will not count towards qualifying spend for the sign-up bonus.
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All the usual suspects are here (except hospitals, see below): charitable donations, education, government services, insurance premiums, prepaid account top-ups and utility bills.
However, there are three less-common exclusions that you need to know about: 7299, 7399 and 8999
| MCC | Description | Examples |
| 7299 | Personal Services Not Elsewhere Classified |
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| 7399 | Business Services Not Elsewhere Classified |
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| 8999 | Professional Services Not Elsewhere Classified |
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These exclusions mean that CardUp and Points.com will not count towards qualifying spend. You also need to be careful with Shopee, because transactions have occasionally been reported to code as 7399 (#1, 2, 3, 4).
What can you spend on?
Before we discuss this, here’s a PSA: the minimum spend for sign-up bonuses should be spending that you were planning to do anyway. You’re not going to win any awards for financial prudence by deliberately splurging just so you can earn some extra miles.
What about frontloading spending? That’s more of a grey area, in my opinion. I have no issues frontloading a certain amount of spending, though what constitutes an acceptable amount is very much open to interpretation. I think we can all agree that buying S$15,000 of NTUC vouchers is a little extreme, but beyond that, it depends on the opportunity cost of tying up your funds instead of having them earn returns elsewhere.
In the sections below, I’m going to address some common ways of frontloading spending, as well as other commonly-asked questions about qualifying spend.
As a reminder, transactions need to be posted within the first 31 days of approval. For example, suppose your 31-day period ends on 5 October 2026. A transaction made on 3 October 2026 that posts on 6 October 2026 will not count towards the minimum spend. In other words, don’t leave things until the last moment!
| ❓ Supplementary cards unavailable |
| If you need the help of a “Player 2” to meet the minimum spend, it’s worth noting that the Trust Freedom Card does not offer supplementary cards at this time. A workaround is to digitise one card on your phone, and give the physical card to the other person — though it goes without saying that you should only do this with someone you trust unequivocally. |
Gift cards and vouchers
The classic way of frontloading spend is to purchase gift cards and vouchers. Purchases made with the following merchants will count towards qualifying spend.
 MCC 5311 |
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| Get 200 Max Miles when you open an account and complete your first transaction | |
| Get a HeyMax Account |
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 MCC 5947 |
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 MCC 5999 |
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Mall vouchers
Alternatively, if you don’t want to tie yourself down to a specific merchant, then buying mall vouchers is another option.
The two big players here are Frasers Experience and CapitaMalls.
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| MCC 5965 | |
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Purchases of FRx gift cards will initially show as MCC 6513 when pending, which is an excluded MCC. However, upon posting it switches to MCC 5965, which is included.
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| MCC 5947 (Purchased via Wogi) |
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eCapitaVouchers, if purchased directly through the CapitaStar App, will code as ineligible spend. However, if purchased through Wogi, they will code as eligible spending (MCC 5947, as mentioned above).
Wogi no longer sells stand-alone eCapitaVouchers, but they are still listed as an option under the multi-brand shopping gift card.
Hospitals & medical expenses
While MCC 8062 Hospitals is a common exclusion category, it’s not on the Trust Freedom Card’s rewards exclusion list. This means that any surgical costs, consultant fees or delivery charges can count towards your minimum spend.
On that note, there is no exclusion for dental or medical clinics either — good news for those planning to bring forward their annual health screening.
Telco bills
Telco bills code as MCC 4814 and are not on the exclusion list. The bigger issue is that given the 31-day spending period, you won’t be able to charge more than one month’s bill anyway. Certain telcos may allow for overpayment — with Singtel, the limit (when paying at a kiosk, which by the way codes as MCC 5999) is twice your current bill or S$500, whichever is lower.
Wedding banquet expenses
I’ve seen a few people asking about wedding expenses, and the answer is yes: your banquet charges will almost certainly count as qualifying spend, regardless of whether it’s a hotel or a stand-alone restaurant.
PayPal
PayPal is a common area of confusion.
The general rule is that payments to personal PayPal accounts, or to any PayPal account associated with an excluded MCC (e.g. investment services, forex trading) are likely to be excluded. However, payments made to business PayPal accounts will be fine.
You need to be careful though, because some mom-and-pop businesses may use a personal PayPal account to collect payment, for simplicity’s sake.
I’ve written more about this topic and how to tell account types apart in the post below.
Be careful with refunds!
While big-ticket purchases such as airfares, tours and hotel stays are great ways of meeting the minimum spend, you’ll need to be wary of refunds. If circumstances change and you need to cancel your plans, the refund could trigger a clawback of the bonus miles, or a charge to your account if those miles have already been redeemed.
The best practice for sign-up bonuses is to only charge the kind of spending that you know will not be refunded.
How to track your qualifying spend
The great thing about the Trust Freedom Card’s sign-up bonus is that there’s no need to “spend and pray”.
With sign-up bonuses, what usually happens is that cardholders, after meeting the minimum spend, hold their breath for the bonus miles to show up a few months later — remember the tension with the Standard Chartered X Card?
With the Trust Freedom Card, cardholders can track their progress towards the minimum spend goal in real-time, through the Trust app under Rewards > Quests.
Only transactions which count towards qualifying spend will show up here. Non-qualifying transactions will not be included. So if the tracker says S$3,500, you can be confident that S$3,500 of your spending counts towards the sign-up bonus.
If you’ve just made a transaction and nothing happens to the tracker, don’t panic. The tracker will only move once the transaction posts, which usually takes 1-3 days. You can see the transaction’s status under the Activity tab.
If all your transactions show as posted, but the tracker hasn’t moved by a commensurate amount, you can also investigate which transaction didn’t count by using the HeyMax app.
To do this, you must link your Trust Freedom Card to the HeyMax app. Make sure to link your Trust Freedom Card before you start spending, because the HeyMax app can only track transactions made after linking!
- Home page > Cards button (next to mile balance), or Profile > My Cards.
- Add card > Trust Freedom Card > Link and verify card.
- Card Settings > Pick the reward mode (Miles)
Once this is done, the Card Maximiser feature will automatically track your spending, and the number of Trust Miles earned. Any transaction which shows 0 Trust Miles is an ineligible transaction that does not count towards qualifying spend.
To summarise the situation:
- Trust app: Tracks aggregate qualifying spending
- HeyMax app: Tracks transaction-level qualifying spending
If you want to check a merchant’s MCC before spending anything, here are the three main ways of doing it.
| Method | Ease of Use | Reliability |
| ❓HeyMax | ●●● | ● |
| 📱 Instarem app | ●● | ●● |
| 🤖 DBS digibot | ● |
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| Note: “Ease of use” and “reliability” are all relative. HeyMax already provides a solid baseline for reliability, and the DBS digibot is still simple enough to use, despite requiring more steps than the other two methods. | ||
Conclusion
The Trust Freedom Card’s 100,000 miles sign-up bonus is a very lucrative reward — which also means that any slip-ups with qualifying spend could be extremely costly.
The good news is that it’s easy to track your overall qualifying spending through the Trust app, and dig into what transactions didn’t qualify with the HeyMax app. With a combination of these two, you shouldn’t be missing out on your welcome bonus because of a careless mistake.
Of course, whether you’re actually able to spend S$15,000 in 31 days is a different matter entirely. If your major life expenses happen to coincide with this window, then great, but otherwise please don’t overextend yourself.
It’s just miles, you know.
