Introduction
The Corporate Service Providers Act 2024 introduces a new regulatory framework for firms offering corporate services in Singapore. Many company directors, business owners and service providers are asking: what is the Corporate Service Providers Act 2024 and how does it affect my company?
This article explains the main obligations introduced by the Corporate Service Providers Act 2024, who it applies to, and practical steps companies and corporate secretaries should take to remain compliant. The Corporate Service Providers Act 2024 affects both providers of corporate secretarial services and the companies that engage them.
Who this applies to
The Corporate Service Providers Act 2024 primarily targets firms that provide corporate services. In Singapore this includes companies and firms that offer any of the following:
- Company incorporation and registration services (including filings on ACRA BizFile+)
- Corporate secretarial services (statutory filings, minute books, lodgements)
- Registered office and nominee director services
- Provision of directors or corporate officers, and similar corporate management services
It also has implications for companies that engage third-party corporate service providers, because those companies must ensure their advisers meet the new regulatory standards. Where relevant, the Act aligns with existing frameworks such as the Companies Act, AML/CFT measures and PDPA obligations.
Key rules and requirements in Singapore
The Corporate Service Providers Act 2024 introduces several statutory requirements. Key elements include:
- Registration and licensing: Corporate service providers (CSPs) must register with the designated regulator and obtain a licence before carrying on regulated activities.
- Fit and proper criteria: Individuals and firms must meet suitability requirements, including checks on directors, controllers and key personnel.
- Anti‑money laundering and countering financing of terrorism (AML/CFT): CSPs must implement enhanced AML/CFT policies, customer due diligence (KYC), transaction monitoring and suspicious transaction reporting consistent with FATF guidance.
- Record-keeping and retention: CSPs must maintain accurate records of clients, beneficial owners and supporting documents for prescribed retention periods, and make records available to regulators on request.
- Client onboarding and ongoing monitoring: Requirements include risk-based onboarding, ongoing monitoring, and screening of clients and associated persons for sanctions or PEP status.
- Data protection: CSPs must handle personal data in accordance with the PDPA, especially when storing or sharing information across jurisdictions.
- Reporting and supervision: Regular reporting obligations, regulatory audits and compliance reviews are introduced to ensure ongoing adherence.
These requirements are intended to strengthen Singapore’s corporate services sector and align it with international standards. CSPs should also consider related obligations under the Companies Act, ACRA filing requirements, IRAS tax rules, CPF and Employment Act matters where they provide payroll or HR-related services.
Step-by-step process
If you operate as a corporate service provider or engage one, follow these practical steps to comply with the Corporate Service Providers Act 2024:
- Determine scope: Assess whether your activities fall within the definition of corporate services under the Act.
- Register or verify provider: CSPs must apply for registration/licence; companies should verify that their provider is properly licensed.
- Update policies: Implement or update AML/CFT, KYC and PDPA-compliant policies and procedures.
- Train staff: Deliver regular compliance training for staff on AML, KYC, PDPA and reporting obligations.
- Enhance record-keeping: Adopt secure record-keeping systems for beneficial ownership, transaction histories and client documents; integrate with ACRA BizFile+ and IRAS myTax Portal processes where relevant.
- Conduct due diligence on clients: Apply risk-based client acceptance and ongoing monitoring processes.
- Engage professional support: Seek assistance from compliance advisers or corporate secretaries to ensure processes meet regulatory expectations.
Common mistakes to avoid
Non-compliance can lead to penalties, licence restrictions or reputational damage. Common pitfalls include:
- Failing to register or confirm a provider’s licence status before engaging services.
- Inadequate KYC and beneficial ownership checks at onboarding.
- Poor record-keeping or insecure storage of personal data, breaching PDPA requirements.
- Neglecting staff training and weak internal controls for AML/CFT reporting.
- Assuming overseas compliance suffices for Singapore obligations—local rules (ACRA, IRAS, MOM) apply.
Practical examples
Example 1: A newly incorporated company uses a third-party firm for company secretarial services. Under the Corporate Service Providers Act 2024, the firm must be licensed. The company should confirm the licence and request documentation that the firm complies with AML and PDPA policies.
Example 2: A CSP provides nominee director services. The CSP must maintain up-to-date records of the beneficial owner and undertake ongoing monitoring for suspicious transactions. Failure to do so may trigger regulatory action and impact the client company’s standing with ACRA.
Example 3: A small business engaging a CSP for payroll and accounting. The CSP must ensure CPF contributions and Employment Act obligations are correctly handled and maintain records for IRAS audits and CPF inspections. Companies should ask providers how they integrate payroll filings with IRAS myTax Portal and CPF submission processes.
How a corporate secretary can help
A professional corporate secretary plays a central role in helping companies navigate the Corporate Service Providers Act 2024:
- Advising on whether your provider’s services fall within the Act’s scope.
- Maintaining statutory registers, minute books and ACRA filings in compliance with the Companies Act and ACRA BizFile+ requirements.
- Implementing KYC and AML/CFT procedures and advising on PDPA-compliant handling of personal data.
- Coordinating with tax and payroll teams to ensure IRAS, CPF and Employment Act obligations are met.
- Supporting licence applications, regulatory reporting and remedial measures where needed.
Raffles Corporate Services can help with filings, compliance, accounting, tax and payroll support to ensure your company and its providers meet regulatory expectations.
Frequently Asked Questions
Who must register under the Corporate Service Providers Act 2024?
Entities that provide corporate services as defined by the Act—such as company incorporation, corporate secretarial services, nominee services and related corporate management functions—generally must register or obtain a licence. Companies should verify the status of any external provider they use.
Will the Act affect my company’s directors or beneficial owners?
Yes. The Act strengthens requirements around beneficial ownership disclosure and ongoing monitoring. Directors and beneficial owners may be subject to fit-and-proper checks where they are involved in the management of a regulated CSP.
How does the Act interact with existing laws like the Companies Act and PDPA?
The Act complements existing legislation. Companies must continue to comply with the Companies Act, ACRA filing rules, PDPA for personal data, IRAS tax rules and AML/CFT obligations. The CSP Act adds a regulatory layer specifically focused on service providers in the corporate services sector.
What penalties apply for non-compliance?
Penalties can include fines, licence suspension or revocation, and enforcement actions. Specific sanctions depend on the breach. Businesses should adopt robust compliance frameworks to mitigate risk.
Key takeaways
- The Corporate Service Providers Act 2024 introduces licensing, AML/CFT, record-keeping and supervision requirements for CSPs in Singapore.
- It applies to firms offering incorporation, corporate secretarial, nominee or corporate management services, and affects companies that engage them.
- Companies should verify provider licences, update policies (KYC, AML, PDPA) and enhance record-keeping.
- Professional corporate secretaries can assist with compliance, ACRA filings (BizFile+), IRAS interactions and payroll/CPF matters.
- Requirements may change, so always check the latest guidance from ACRA, IRAS or MOM, or consult a professional adviser.
If you would like to find out more about how Raffles Corporate Services can assist with your company’s compliance and corporate secretarial requirements, please get in touch with the team at [email protected].
Yours sincerely,
The editorial team at Raffles Corporate Services
Disclaimer: This does not constitute legal advice. If you require legal advice, please contact a lawyer.