Corporate Service Providers Act 2024 compliance means registering with the Accounting and Corporate Regulatory Authority (ACRA) as a registered corporate service provider before carrying on, in or from Singapore, a business of company incorporation, nominee arrangements, registered office provision, filing services or company secretarial work, and then meeting the Act’s anti-money laundering obligations on an ongoing basis.
Raffles Corporate Services works with a panel of corporate and employment law firms; this article is general information, not legal advice.
What is the Corporate Service Providers Act 2024, and why was it introduced?
The Corporate Service Providers Act 2024 (the CSP Act) took effect on 9 June 2025. It replaced the older, lighter-touch regime for corporate service providers with a dedicated registration-based framework administered by ACRA, bringing Singapore’s corporate services sector into closer alignment with international standards on anti-money laundering (AML), countering the financing of terrorism (CFT) and countering proliferation financing (CPF). Before the Act, firms offering incorporation, nominee director, registered office or company secretarial services faced a patchwork of obligations under the Companies Act 1967 and general AML guidance. The CSP Act consolidates these into a single registration requirement, a single supervisor, and a single set of ongoing due diligence duties. The full text of the Act is available on Singapore Statutes Online, which we recommend directors consult directly rather than relying on summaries, including this one.
For directors and in-house counsel, the practical shift is straightforward: any firm your company engages to incorporate an entity, hold a nominee role, provide a registered address, or act as company secretary on a commercial basis must now be a registered CSP, and you are entitled to check that status before instructing them.
Who needs Corporate Service Providers Act 2024 compliance?
The Act applies to any entity, whether a sole proprietorship, partnership or company, that carries on a business of providing corporate services in and from Singapore. This is a business test, not an incidental one: a law firm that incorporates a subsidiary for an existing client as part of a wider mandate sits differently from a firm that markets and sells incorporation, nominee or secretarial services as a standalone commercial offering. If your organisation’s finance or legal team occasionally sets up a special purpose vehicle for its own group, that is not “carrying on a business” of corporate services in the sense the Act targets.
But if a vendor advertises company formation, nominee director placement, registered office hosting or ACRA filing services to the public or to a client base, Corporate Service Providers Act 2024 compliance is mandatory for that vendor, regardless of firm size, and you can confirm a provider’s registration status directly through ACRA. This also matters for HR and mobility teams: firms that bring in specialist compliance or company secretarial staff from overseas to support CSP operations should note that intra-corporate transferee routes under the Employment Pass framework can sometimes reduce the usual labour market testing burden, though eligibility depends on the specific pass category and group structure.
What counts as “corporate services” and what happens if a firm operates without registering?
“Corporate services” under the Act is defined broadly. It captures company incorporation carried out on behalf of others, acting as a nominee director or nominee shareholder for a client, or arranging for someone else to act in either nominee capacity, providing a registered office or business address for a client company, certain accounting services provided on a commercial basis, and acting as company secretary or filing documents with ACRA on behalf of another party by way of business. A firm does not need to provide every one of these services to fall within scope; offering even one of them commercially is enough to trigger the registration requirement.
Operating a corporate services business without registering is a criminal offence. On conviction, the Act provides for a fine not exceeding S$50,000, imprisonment not exceeding 2 years, or both, and for a continuing offence, a further fine of up to S$2,500 for each day the contravention continues after conviction. Directors instructing an unregistered provider face no direct penalty under the Act simply for engaging that provider, but the practical and reputational risk is real: an unregistered CSP is, by definition, operating outside ACRA’s AML/CFT supervision, which increases the risk that due diligence on your own company has not been properly performed, with knock-on consequences if that gap surfaces during a bank onboarding review, an audit, or a regulatory enquiry.
What ongoing AML/CFT obligations apply to registered CSPs?
Registration is the entry point, not the end point. Registered CSPs carry a continuing set of obligations modelled on Singapore’s broader AML/CFT/CFT-proliferation-financing architecture, the same architecture that underpins the supervisory approach the Monetary Authority of Singapore applies to the financial institutions it regulates. The four pillars below are the ones directors should expect their CSP to be able to evidence on request.
Customer due diligence
A registered CSP must identify and verify the identity of its clients and, where relevant, the clients’ beneficial owners, before establishing a business relationship. This includes understanding the nature and purpose of the intended relationship and the source of funds where the risk profile warrants it.
Enhanced due diligence
Where a client presents a higher money-laundering or terrorism-financing risk, such as a politically exposed person, a complex ownership structure, or a connection to a higher-risk jurisdiction, the CSP must apply enhanced due diligence measures. This typically means more detailed source-of-wealth checks, closer senior management approval, and more frequent ongoing monitoring.
Record-keeping
Registered CSPs must keep due diligence records, transaction records and supporting documentation for at least 5 years. This period generally runs from the end of the business relationship or the date of the relevant transaction, and the records must be capable of being produced promptly if ACRA or another authority requests them.
Suspicious transaction reporting
Where a registered CSP knows or has reasonable grounds to suspect that funds or a transaction are connected to criminal conduct, it must file a suspicious transaction report. This obligation sits alongside, and does not replace, any separate reporting duties the CSP or its client may have under other legislation.
How does the Act affect nominee directors, nominee shareholders and the Register of Registrable Controllers?
One of the more consequential changes under Corporate Service Providers Act 2024 compliance concerns nominee arrangements. A person may not act as a nominee director by way of business unless the arrangement is made through a registered CSP that has first assessed that individual as fit and proper for the role. This closes a gap that previously allowed informal nominee arrangements to sit outside any structured screening. For a director considering a nominee appointment, whether as the nominee or as the party benefiting from the arrangement, the first practical question is whether the CSP facilitating it is registered and has documented a fit-and-proper assessment; if not, the arrangement is not compliant with the Act.
Registered CSPs also commonly sit at the centre of another related obligation: keeping a company’s Register of Registrable Controllers (RORC) current. The RORC regime is set out in the Companies Act 1967, Part 11A, sections 386AA to 386AP, and requires Singapore companies to identify and record individuals or entities with significant control or significant interest over them, typically a direct or indirect holding of more than 25% of shares or voting rights, or the right to appoint or remove a majority of directors. Because CSPs administer incorporation and secretarial functions, they frequently also maintain the RORC and beneficial ownership records on the client’s behalf, which means an audit of your CSP’s Corporate Service Providers Act 2024 compliance should include a check of how RORC filings are actually being maintained in practice, not just assumed to be correct.
Our companion guide on RORC and beneficial owner register mistakes under the CSP Act 2024 sets out the most frequent errors we see in this specific handoff between CSP registration and RORC accuracy, and is worth reading alongside this FAQ if your company relies on a third-party CSP for secretarial support.
What does Corporate Service Providers Act 2024 compliance cost, and what is the realistic timeline?
Costs and timelines vary by firm size and existing AML infrastructure, but a few numerical benchmarks are useful for budgeting purposes:
- ACRA registration itself is processed through a defined application channel, with most straightforward applications for firms that already hold relevant professional standing, such as existing company secretarial or accounting practices, taking a matter of weeks rather than months, though complex structures or incomplete applications can extend this considerably.
- Building or upgrading an AML/CFT compliance function, covering customer due diligence procedures, a risk assessment framework, staff training and a record-keeping system capable of meeting the 5-year retention requirement, typically represents the larger share of implementation cost and effort, often several months of internal project work for a small to mid-sized firm.
- Non-compliance exposure is not merely theoretical: the statutory fine of up to S$50,000, potential imprisonment of up to 2 years, and the daily continuing fine of up to S$2,500 make the cost of delay materially higher than the cost of early registration for any firm still operating outside the regime.
For a company that is a client of a CSP rather than a CSP itself, the more relevant timeline question is usually how quickly your existing provider can evidence its registration status and its due diligence file on your company; this is worth confirming at your next renewal or engagement letter review rather than waiting for it to surface during a bank or auditor query.
What mistakes do firms make when working toward compliance, and where should related guidance be sought?
The most common mistake we see is treating registration as a one-off filing rather than an operating change. Firms register with ACRA, tick the box, and then continue running customer onboarding exactly as before, without embedding customer due diligence, enhanced due diligence triggers or record-keeping into daily workflow. A second common error is assuming that only the entity providing incorporation services needs to register, when in fact a firm offering only registered office services, or only nominee arrangements, is equally in scope. A third mistake, seen particularly among smaller practices, is under-resourcing the fit-and-proper assessment process for nominee directors, treating it as a formality rather than a documented, defensible screening exercise.
A fourth and increasingly common issue arises when a compliance gap, a disputed nominee arrangement, or a regulatory query escalates beyond what an in-house team or company secretary can resolve alone. At that point, the practical path is a structured handoff to external counsel who can advise on both the CSP Act angle and any related court process. Our guide on the CSP counsel handoff and court application process in Singapore walks through how that escalation typically works and when it becomes necessary, and is a useful next read for any director who is not simply verifying a provider’s registration but is dealing with an active dispute or enforcement query.
Related guidance worth reviewing alongside this FAQ includes ACRA’s own registered CSP search facility, which lets any company verify a provider’s registration status directly, and the Monetary Authority of Singapore’s broader published guidance on AML/CFT supervisory expectations, both useful reference points beyond the statute itself.
FAQs
Does the CSP Act apply to a company that only occasionally sets up subsidiaries for its own group?
No. The Act targets entities carrying on a business of providing corporate services to others. A group finance or legal team that incorporates its own subsidiaries as part of ordinary corporate activity is not “carrying on a business” of corporate services in the sense the Act regulates, provided it is not also offering these services commercially to third parties.
Can I check whether my company secretary or incorporation agent is a registered CSP?
Yes. ACRA maintains a public register of CSPs, and checking a provider’s status before engaging them, or as part of a periodic vendor review, is a straightforward and prudent step for Corporate Service Providers Act 2024 compliance on the client side.
What happens if my nominee director was appointed before 9 June 2025?
Existing arrangements should be reviewed against the current framework. The requirement that nominee directors be arranged through a registered CSP that has assessed them as fit and proper applies to the ongoing conduct of nominee business, so legacy arrangements set up informally before the Act commenced warrant a fresh look rather than an assumption of continued validity.
Is company secretarial work always caught by the Act?
Acting as company secretary or filing with ACRA on behalf of another party by way of business falls within the statutory definition of corporate services, so a firm offering company secretarial services commercially needs to register, even if it does not also provide incorporation or nominee services.
Do the AML obligations apply equally to a small, single-director CSP firm and a large multi-office provider?
The core obligations, customer due diligence, enhanced due diligence for higher-risk clients, 5 years of record-keeping and suspicious transaction reporting, apply regardless of firm size. Supervisory expectations on how these are documented may scale with the size and risk profile of the firm, but the underlying duties are not optional for smaller providers.
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.