Corporate Service Providers Act 2024 compliance means registering with ACRA before offering company incorporation, secretarial, nominee director or registered office services, appointing a Registered Qualified Individual, and meeting ongoing AML/CFT obligations — most rejections stem from incomplete RQI qualifications or weak due diligence records.
Raffles Corporate Services works with a panel of corporate and employment law firms; this article is general information, not legal advice.
Since 9 June 2025, any business entity that carries on a business of providing corporate services in and from Singapore has had to be a registered corporate service provider (CSP) with the Accounting and Corporate Regulatory Authority (ACRA). The Corporate Service Providers Act 2024 (Act 22 of 2024) was introduced primarily to detect and prevent money laundering, terrorism financing and proliferation financing risks in the corporate secretarial and company formation industry — an industry that had previously operated with comparatively light regulatory oversight relative to banks, financial advisers and payment institutions.
Fourteen months into the regime, ACRA’s case officers have seen the same handful of application errors again and again. This guide sets out what corporate service providers act 2024 compliance actually requires, and — more usefully — the specific mistakes that cause registration applications, RQI approvals and CSP Regulations 2025 audits to be rejected or flagged.
What the Corporate Service Providers Act 2024 regulates
The Act broadens the legal definition of “corporate services” beyond simple company secretarial work. It now explicitly captures: forming Singapore or foreign business entities on a client’s behalf; acting as, or arranging for, a nominee director or nominee shareholder; acting as a company secretary by way of business; providing a registered office, business or correspondence address; and transacting with ACRA on a client’s behalf (for example, filing annual returns or changes of particulars). A firm — or a sole practitioner — offering any one of these services for a fee must be a registered CSP. Ancillary bookkeeping or tax filing work does not, by itself, trigger registration, but firms that bundle these services with company secretarial work usually do fall within scope.
Who this applies to
The regime applies broadly: corporate secretarial firms, accounting firms that also provide incorporation and nominee services, family office administrators, and individual freelance company secretaries. It also applies to law firms and law practices to the extent they provide corporate services outside the practice of law, although solicitors acting in their capacity as lawyers are treated separately under the Legal Profession Act. Directors and business owners engaging a CSP should also care about this — engaging an unregistered provider exposes the client entity to filing delays, since ACRA will not accept transactions lodged by an unregistered agent, and to reputational risk if the provider is later found non-compliant.
Eligibility and requirements
To register, an entity must appoint at least one Registered Qualified Individual (RQI) to carry out or supervise its regulated corporate services. Section 9 of the Corporate Service Providers Act 2024 sets out the RQI framework: the individual must hold a relevant professional qualification (for example, being a Chartered Secretary, qualified accountant, or holding recognised legal training) and must have completed the mandatory anti-money laundering, countering the financing of terrorism and countering proliferation financing (AML/CFT/PF) training recognised by ACRA. A CSP with no RQI, or whose RQI’s qualification has lapsed, cannot lawfully operate.
Beyond the RQI, a registered CSP must maintain customer due diligence (CDD) procedures, an internal audit function proportionate to its size, recordkeeping policies that meet the CSP Regulations 2025, and — where it provides or arranges nominee directors — a register of nominee arrangements with annual re-verification of the beneficial owner behind each nominee appointment. Nominee director arrangements are particularly tightly controlled: under the Act, a person may only act as a nominee director by way of business if the arrangement is made through a registered CSP that has separately assessed the nominee as fit and proper.
Cost and timeline
Registration (and renewal) is currently priced at S$400 for a two-year period — the previous one-year registration option has been discontinued, so every CSP is now on a two-year cycle. Applications are lodged through Bizfile and, where the RQI and supporting documents are in order, are typically processed within a few weeks; ACRA has not published a statutory turnaround time, so firms should not assume same-day approval. Renewal applications can be filed up to 60 days before the current registration expires, and firms that let registration lapse must stop providing corporate services until it is restored, which in practice means a client-facing outage.
Numerically, the exposure for operating unregistered is significant: providing corporate services without registration is an offence carrying a fine of up to S$50,000 and/or up to two years’ imprisonment, with a further daily fine of up to S$2,500 for each day the offence continues after conviction. Firms should weigh this against the S$400 registration fee — the asymmetry is deliberate.
Step-by-step registration process
- Confirm scope. Map every service line against the Act’s definition of “corporate service” to confirm whether registration is triggered.
- Appoint or confirm the RQI. Identify an individual meeting the qualification bar, and enrol them in ACRA-recognised AML/CFT/PF training if not already completed.
- Build the compliance infrastructure. Draft or update CDD procedures, a recordkeeping policy, and — for larger firms — an internal audit or compliance monitoring function before applying, since ACRA can request evidence of these at registration or during a later inspection.
- Lodge the application via Bizfile. Submit entity particulars, RQI details and the S$400 fee.
- Respond to queries promptly. Most delays occur because ACRA’s request for clarification is not answered within the stipulated window, causing the application to lapse.
- Maintain ongoing compliance. Once registered, keep the nominee register current, refresh CDD periodically, and calendar the renewal 60 days ahead of expiry.
Common mistakes and rejection reasons
These are the recurring issues practitioners report when corporate service providers act 2024 compliance applications or audits go wrong:
- RQI qualification does not meet the bar. Applicants sometimes nominate a general administrative staff member without a recognised professional qualification, or list an RQI who has not yet completed the mandatory AML/CFT/PF training — this is the single most common rejection reason.
- No fallback RQI. Firms with only one qualified individual risk a compliance gap the moment that person leaves, goes on long leave, or has their qualification lapse; ACRA guidance expects firms to plan for continuity.
- Thin or templated CDD files. Reviewers frequently find customer due diligence records that consist of a photocopied passport and nothing else — no source-of-wealth notes, no risk rating, no beneficial ownership trace for corporate clients.
- Nominee director register incomplete or missing annual re-verification. CSPs that arrange nominee directors but cannot produce a current fit-and-proper assessment, or have not re-verified the beneficial owner within the past year, are routinely flagged.
- Treating registration as a one-off exercise. Some firms register correctly but never revisit their policies; when ACRA later inspects, the CDD framework has not kept pace with the CSP Regulations 2025 or with new guidance issued after registration.
- Confusing “corporate services” scope. Firms that provide registered office addresses or ACRA-facing filing services, but assume this is exempt because it is “just admin,” are frequently the ones later found to be operating unregistered.
- Late renewal. Because the registration window moved to two years, some firms lose track of the renewal date; letting registration lapse — even briefly — means the firm cannot lawfully continue providing services in that window.
Where the CSP Act intersects with other Singapore compliance regimes
Company secretaries remain separately governed by the Companies Act 1967: Section 171 of the Companies Act 1967 requires every company to appoint a company secretary within six months of incorporation, and that secretarial function is one of the specific services now brought within CSP Act registration when performed by way of business. Directors and CSPs should not conflate the two — being a company secretary under the Companies Act does not itself satisfy CSP Act registration, and vice versa. Firms whose clients also hold Monetary Authority of Singapore licences (fund managers, payment institutions) should be alert that MAS-regulated entities have their own, often stricter, AML/CFT expectations of any CSP they engage, layered on top of the CSP Act baseline.
What a strong compliance file looks like
Firms that pass ACRA reviews without incident tend to share a few habits. First, they keep the RQI’s qualification certificate and training completion records in a single, dated file rather than scattered across staff email inboxes — this matters because an inspector will ask for evidence, not an assurance. Second, they risk-rate every client at onboarding (low, medium, high) and can explain, on request, why a particular client sits where it does; a flat, undifferentiated CDD approach is a common flag even where no actual money-laundering issue exists. Third, they treat the nominee director register as a living document, updating it whenever a nominee arrangement starts, changes or ends, rather than reconstructing it retrospectively when asked. Fourth, they separate the RQI’s supervisory sign-off from the staff member who actually prepared the CDD file, so there is a genuine second pair of eyes rather than a single person self-certifying their own work.
It is also worth noting what corporate service providers act 2024 compliance does not require. The Act does not require a CSP to refuse every higher-risk client outright — it requires enhanced due diligence and a documented basis for proceeding. Overly conservative firms sometimes turn away legitimate business (for example, a foreign holding company with a layered but explicable ownership structure) when a properly documented enhanced CDD file would have sufficed. Getting this balance right is as much a commercial skill as a compliance one, which is one reason many firms lean on their panel lawyers when a structure looks unusual.
Preparing for an ACRA compliance inspection
ACRA has signalled that post-registration inspections, rather than the initial application, are where most substantive compliance gaps surface. A CSP preparing for one should be able to produce, on short notice: the current RQI’s qualification and training records; a sample of CDD files across the firm’s risk tiers; the nominee director register with re-verification dates; and the firm’s written AML/CFT/PF policy, ideally reviewed within the past 12 months. Firms that only assembled these documents to satisfy the original Bizfile application, and have not revisited them since, are the ones most likely to be issued directions to remediate — and, in serious or repeated cases, to face the fines set out under the Act.
FAQs
Do sole-practitioner company secretaries need to register under the CSP Act 2024?
Yes. Registration is based on the activity, not the size or structure of the provider — an individual offering corporate secretarial services by way of business must register and, in practice, will typically be their own RQI if suitably qualified.
Does using an unregistered CSP put the client company at risk?
It can. ACRA will not accept lodgements from an unregistered agent, which can delay statutory filings, and clients relying on an unregistered provider for nominee director arrangements lose the fit-and-proper safeguards the Act was designed to provide.
How long does CSP registration last before renewal is needed?
Two years from the date of registration or last renewal. The one-year option has been withdrawn, and renewal can be filed up to 60 days before expiry.
What is the most common reason a CSP registration application is rejected or queried?
An RQI who does not meet the qualification and training requirements under Section 9 of the Act — either an unqualified nominee or one who has not completed the recognised AML/CFT/PF training.
Does the CSP Act replace the need for a law firm on regulatory matters?
No. A registered CSP handles corporate secretarial and formation services; it does not provide legal advice. Firms and clients needing an interpretation of the Act’s application to a specific fact pattern should consult a qualified lawyer.
Related guides
For the company secretary appointment duties that sit alongside CSP Act registration, see Company Secretary in Singapore: Role, Duties and How to Appoint One (2026) from our sister site Singapore Secretary Services. Businesses managing broader employer compliance alongside corporate secretarial obligations may also find our sister site’s Singapore Work Permit 2026: Complete Employer Guide useful. For a wider walkthrough of what the Act changed for CSPs and their clients, see our own Corporate Service Provider Act 2024: New Compliance Obligations for Singapore CSPs and Their Clients.
Primary sources: the Corporate Service Providers Act 2024 is published in full on Singapore Statutes Online, with registration guidance and forms available directly from ACRA. Firms whose clients are MAS-regulated should also review obligations set by the Monetary Authority of Singapore.
Need help with this? Call, SMS or WhatsApp +65 8501 7133, or email [email protected]. Raffles Corporate Services works with a panel of corporate and employment law firms; this article is general information, not legal advice.