Maintaining Client Lists as a CSP

Your client list in Bizfile is the list of entities your firm is permitted to file for. If a company is not on it, you cannot lodge anything for them, however long you have acted and however many engagement letters you hold. Adding a client is free and instant, but the client has to endorse it before access goes live.

Raffles Corporate Services works with a panel of experienced Singapore law firms who offer cost-effective and efficient legal service and advice. This article is general information only and is not legal advice.

That endorsement requirement is the design point worth understanding. ACRA has deliberately built a two-sided control: the corporate service provider claims the client, and the client confirms the claim. Neither side can quietly grant or assume access to the other’s filings.

Here is how to run the list properly, and why a stale one is a liability rather than an inconvenience.

What the client list actually controls

Under the Corporate Service Providers Act 2024, carrying out an ACRA transaction on behalf of another person through the electronic transaction system is itself a corporate service. Section 7 makes carrying on that business without registration an offence. The client list is the operational expression of that: it is the record of which entities your registered CSP is authorised to transact for.

Three things follow from that, and all three matter.

The list is permission, not record-keeping. It is not a CRM. Adding a client grants filing access, and withdrawing one removes it. Treating it as a marketing database is how firms end up with access they should not have.

Access flows through the firm, not the person. Once a client is on the list, all of your firm’s appointed registered qualified individuals and authorised employees can file for them. You do not assign clients to individuals. If you need to understand how the people side works, our notes on registering as a registered qualified individual and on appointing or withdrawing RQIs cover it.

The client can see you and can remove you. Clients view their appointed CSPs on their own Bizfile dashboard, and their authorised position holders can remove a CSP’s filing access without telling you first.

Who can maintain the list

You must satisfy all three of these:

• Be an authorised position holder or an appointed RQI of the CSP. Ordinary employees, even trusted ones, do not get to touch the list.
• Hold an active Corppass account in your own name.
• Have been granted access to the ACRA Bizfile e-Service by your firm’s Corppass administrator. That is a separate act from having a Corppass account at all, and it is the step most often missed.

If that last distinction is unfamiliar, our guide on who should have Bizfile access and how to assign Corppass e-Service roles sets out the sensible allocation for a professional firm.

What you need to prepare

One thing: the client’s unique entity number (UEN) or registration number. Bizfile retrieves the rest.

There is no fee for maintaining the list, and processing is immediate. The only waiting is for the client’s endorsement.

Adding a client, step by step

1. Log in to Bizfile as a Business User with Corppass. Our walkthrough of the Corppass route into Bizfile covers the credential side if you are setting this up for the first time.
2. Select the Corporate Service Provider profile when prompted to choose an entity profile. If you act for more than one CSP firm, pick the right one from the dropdown. This is the step that sends filings to the wrong entity when rushed, which is why we wrote separately on switching profiles on Bizfile.
3. Open the client list e-Service from the “Manage” mega menu under the corporate service provider heading. This takes you to your “My clients” page.
4. Select “Add client” and enter the client’s UEN in the search bar, then retrieve their details.
5. Add more clients in the same transaction if you have several, rather than repeating the whole process for each.
6. Submit. The addition is recorded immediately.
7. Wait for the client to endorse. A newly added client must endorse your request before filing access is granted. Until they do, the entry sits on your list without giving you any ability to file.

Step 7 is where onboarding stalls. The endorsement request lands with the client’s authorised position holders, who may not check their Bizfile inbox from one quarter to the next. Build it into your onboarding message: tell the new client, in writing, that they will receive a Bizfile endorsement request and that nothing can be filed until a director approves it.

Withdrawing a client, step by step

1. On the “My clients” page, find the entity. Use the search function rather than scrolling if the list is long: you can search by entity name or UEN.
2. Select “Withdraw client” beneath their details.
3. Check the name carefully. Companies within a group often have near-identical names, and this is the point at which you are about to remove your own access to the wrong one.
4. Review the submission and confirm.
5. The client’s status updates to “Withdrawn” on your list.

Withdrawal is immediate. If you withdraw the wrong entity you will need to add them again and obtain a fresh endorsement, which means a director of the client has to act before you can file for them. During a filing deadline that is an unpleasant afternoon.

Who can remove whom

The asymmetry is deliberate. Granting access needs both sides. Revoking it needs only one, and either side can do it alone. That is the right way round for a regime built to prevent misuse of the filing system.

What goes wrong in practice

The client who “disappears” from the list. This is the most common support question a CSP fields, and the answer is almost always that the client removed your filing access from their own dashboard. Your list will show who initiated the withdrawal. Before you raise a system fault, check that.

Why would a client do this without telling you? Usually because somebody at their end was tidying up their dashboard and did not understand what they were removing. Occasionally because they appointed a new provider and nobody thought to mention it. Either way the fix is to add them again and ask a director to endorse.

The unendorsed new client. You have the engagement letter, the KYC file and the fee. What you do not have is the endorsement, so on the day the annual return is due you discover you cannot file it. Chase the endorsement during onboarding, not at the deadline.

Keeping former clients on the list. A client who left eighteen months ago should not still be on your list. Two reasons. First, it is live filing access to an entity you no longer act for and no longer diligence, which is exactly the exposure the Act is designed to close. Second, section 17 of the Act requires a registered CSP to perform customer due diligence and to keep the records, with a fine not exceeding $100,000 for failure to comply. A client list that includes entities you stopped monitoring is an awkward thing to explain at a compliance review, because the list is the regulator’s shortest route to the question “show me the AML file for each of these”.

Withdraw clients when the engagement ends. Same week, as part of the disengagement checklist.

Adding an entity before due diligence is finished. Section 17(1) requires customer due diligence before providing any corporate service to a customer, and section 17(4) requires a CSP that cannot or chooses not to complete due diligence to decline the work or terminate it. Adding a company to the client list in advance, to save a step later, is the wrong order. Our Corporate Service Providers Act 2024 compliance FAQ goes through the CDD obligations properly.

Not reconciling the list against your billing. Once a year, export the client list and compare it to the entities you actually invoice. Entities on the list you do not bill are candidates for withdrawal. Entities you bill that are not on the list are filings waiting to fail. It takes an hour and it catches both problems.

A word on what the client sees

Clients are not passive here, and it is worth telling them so. From their own Bizfile dashboard, an authorised position holder of the client can see every CSP that has added them and can remove any of them. Companies that have been through a provider change, or that inherited arrangements from a previous owner, should look at that screen. Our note on using Bizfile’s transaction history as an audit trail explains how to see what has actually been filed in a company’s name, which is the natural follow-up question once you have seen who holds access.

For a CSP, being upfront about this is good practice rather than a risk. A client who understands that they control access is a client who will not panic when they find the screen.

Frequently asked questions

Can I file for a client before they endorse my request?
No. Adding an entity to your client list records the request, but filing access is only granted once the client endorses it. The endorsement goes to the client’s authorised position holders through Bizfile, so a director or company secretary at their end has to act before you can lodge anything.

Who at my firm can see and use the client list?
Only authorised position holders and appointed registered qualified individuals of the CSP can view and maintain the list. Once a client is on it, all of your firm’s appointed RQIs and authorised employees can file for that client. Access is granted at firm level, not per person.

A client has vanished from my list. What happened?
Almost always, the client removed your filing access from their own Bizfile dashboard. Your client list shows who initiated the withdrawal, so check there first. To restore access you add the entity again and the client endorses the new request.

Is there a fee for adding or withdrawing clients?
No. Maintaining the CSP client list is free and processed immediately in Bizfile. The only input you need is the client’s unique entity number or registration number, and the only delay is waiting for a newly added client to endorse your request.

Should I leave a former client on the list in case they come back?
No. The list grants live filing access, and an entity you no longer act for is an entity you no longer perform ongoing due diligence on. Withdraw clients as part of your disengagement process. Re-adding them later takes two minutes plus their endorsement.

Can a client be on more than one CSP’s list at the same time?
Yes. A company can appoint more than one corporate service provider, and each appears on the client’s dashboard. That is common where, for example, one firm handles secretarial work and another handles accounting filings. The client can remove any of them independently.

Making the list trustworthy

A client list that is accurate is a small piece of compliance infrastructure that quietly does a lot of work: it proves who you act for, it limits what you can touch, and it gives a compliance reviewer a clean starting point.

A client list that has not been cleaned in three years does the opposite. It grants access you have not thought about, to entities you have not diligenced, and it invites exactly the questions you would rather not be asked.

Raffles Corporate Services is a registered corporate service provider, so we maintain this list on ourselves and reconcile it annually against our engagements. If you run a CSP and you are not confident your Bizfile client list matches your actual client base, that reconciliation is the single highest-value hour you will spend this quarter.

You can reach us through Raffles Corporate Services, or read more on Singapore corporate secretarial practice at Singapore Secretary Services.

The Editorial Team, Raffles Corporate Services