The RFA to CSP Transition, One Year On: What Carried Over and What Did Not

If you were a registered filing agent on 8 June 2025, you woke up on 9 June 2025 as a registered corporate service provider. Nothing was required of you to make that happen: no application, no fee, no change to your expiry date. That part was automatic.

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The part that was not automatic is where firms got into trouble, and it is still generating problems more than a year later.

The Corporate Service Providers Act 2024 came into force on 9 June 2025 and replaced the registered filing agent regime that had sat inside the ACRA Act. The transitional arrangements were generous, but they were not a blanket amnesty. Two things were always going to land on the firm’s own desk: declaring the types of CSP services you actually provide, and renewing on the new footing rather than the old one. The window for tidying the first of those closed on 9 December 2025.

This is a retrospective. If you are reading it because you have just discovered your Bizfile record still says something that was true in 2024, skip to the last two sections.

What actually changed on 9 June 2025

The regime moved from being a filing-agent registration bolted onto the ACRA Act to being a standalone licensing statute for corporate service provision. That is not cosmetic. A filing agent registration was, in substance, permission to transact on Bizfile on someone else’s behalf. A CSP registration is permission to be in the corporate services business, with the anti-money laundering obligations sitting at the centre of it rather than at the edge.

Four changes have practical bite:

The registration period became two years. Previously a firm could choose a one-year or two-year term. That choice is gone. Everyone is on a two-year cycle now, which means a firm that used to renew annually has had its renewal rhythm quietly rebuilt, and the diary entry that used to fire every twelve months fires every twenty-four.

Fees were reset. Registration costs $400 for a CSP and $200 for an RQI.

RQI eligibility tightened. Membership criteria were added to the qualifying requirements for registered qualified individuals. An individual who satisfied the old test does not automatically satisfy the new one, and the new test bites at renewal, not at transition.

Duties expanded and penalties rose. The obligations attaching to a registered CSP under the CSP Act, and to its RQIs, are broader than the old filing-agent duties, and the consequences of breaching them are heavier.

What transitioned automatically, and what did not

This table is the whole transition in one place.

Read the bottom two rows twice. Everything above them happened to you. The bottom two were things you had to do.

Why the “types of services” declaration mattered more than it looked

Under the old regime, ACRA knew you filed transactions. Under the CSP Act, ACRA wants to know what kind of corporate service business you run, because the risk profile of a firm that only lodges annual returns is not the risk profile of a firm that supplies nominee directors, provides registered office addresses to hundreds of shell entities, and acts as a payments conduit.

The declaration is the input to ACRA’s supervisory targeting. A firm that never updated it is, from the regulator’s point of view, either dormant or misdescribed. Neither is a comfortable position to be in when a compliance review lands.

How the update was done, and still is

The eService has not gone anywhere. If your record is wrong today, the same route fixes it.

1. Log in to Bizfile as a business user through Corppass, using the entity profile for the CSP firm itself, not a client entity.
2. Select Corporate service provider from the eService menu.
3. Select Update corporate service provider information.
4. Work through the service types and select every category the firm actually provides, not the ones it intends to provide or used to provide.
5. Submit.

If you hold positions across several entities, switch to the right profile before you start. Filing the CSP update against the wrong UEN is a common and entirely avoidable waste of an afternoon. Our note on switching profiles on Bizfile covers the mechanics.

What goes wrong in practice

Three failure patterns have shown up repeatedly since the transition.

The firm assumed “automatic” meant “everything”. This is the big one. Because the registration, the client list and the employee access all rolled over without a keystroke, firms reasonably concluded that the whole transition was handled for them. The service-type declaration was the exception, and it was easy to miss precisely because everything around it was frictionless.

The renewal diary was never rebuilt. A firm on a one-year cycle that renewed in, say, March each year now has a two-year registration. The person who used to chase the renewal left, the calendar entry was never updated, and nobody is watching the real expiry date. A CSP whose registration lapses is not a CSP. It cannot lodge, and its clients’ filings stop.

The RQI turned out not to qualify on renewal. The new membership criteria were added at the front end. An individual who was grandfathered through the transition discovers at renewal that they no longer meet the test, and the firm finds itself short of registered qualified individuals with a deadline running. This is recoverable, but only if you find it months ahead rather than weeks.

The consequence in all three cases is the same shape: a gap in registration, or a registration that does not describe what the firm does. Both are enforcement exposure, and both are visible to ACRA without anyone having to investigate you.

If you missed the window

The transitional window closed on 9 December 2025. That does not mean the door is shut; it means you are no longer being handled under transitional arrangements. You are simply a registered CSP with an inaccurate or incomplete record, and the ordinary obligations apply.

What to do, in this order:

1. Pull your own record. Log in and look at what ACRA currently holds for the firm: registration status, expiry date, declared service types, RQIs, client list.
2. Fix the service types now. Same eService, same route. Do it before anyone asks.
3. Check the real expiry date. Not the one in your diary. The one on the record.
4. Audit your RQIs against the current criteria. If someone is short, you need lead time, not a surprise.
5. Reconcile the client list. Entities you no longer act for should not still be sitting there, and entities you do act for should be on it. See our guide on maintaining your CSP client list.

None of this is difficult. It is just work that nobody assigned.

Frequently asked questions

Did my RFA registration lapse when the CSP Act came into force?
No. Registered filing agent registrations became CSP registrations automatically on 9 June 2025, with the same expiry date and no fee. Any conditions already attached to the registration were preserved by section 8(3) of the CSP Act and continue to bind the firm.

Do I need to reapply as an RQI under the CSP Act?
No. Existing RQI registrations transitioned across automatically and kept their original expiry dates, with conditions preserved under section 10(3). The new eligibility criteria, including the added membership requirement, apply when you renew, so check you still qualify well before your expiry date.

My registration was suspended when the Act commenced. What happened to it?
The suspension transitioned with the registration and ran for its original duration. Commencement of the CSP Act did not shorten it, lengthen it, or reset it. Your status and the end date of the suspension were unaffected.

What happens if I never declared my CSP service types?
Your registration is still live, but ACRA’s record of what your firm does is wrong. That is a compliance problem in its own right and it distorts how you are supervised. Submit the update through the Update Corporate Service Provider Information eService on Bizfile. There is no benefit to waiting.

How long is a CSP registration valid now?
Two years. The old option to register for one year is gone. If your firm was on an annual cycle, your renewal date has moved, and the internal reminder you set under the old regime is almost certainly wrong.

Can I keep using the employees I had given filing access to?
Yes. Existing employee filing access carried over intact and needed no action. You should still review it periodically, because access granted to someone who has left the firm is a live risk, not a dormant one.

Where this leaves you

The transition was designed to be painless, and for the most part it was. The residue is a small number of firms carrying a registration that is technically valid and factually out of date, on a renewal cycle nobody has recalculated, with RQIs who may or may not still qualify.

If you are not certain which category you are in, the check takes twenty minutes and the answer is worth having before ACRA asks. The wider obligations that now sit on a registered firm are set out in our Corporate Service Providers Act 2024 compliance FAQ, and the eligibility side is covered in our guides on CSP registration requirements and on becoming a registered qualified individual. ACRA’s own reference point for the statutory framework sits on its Corporate Service Providers Act page.

Raffles Corporate Services is a registered corporate service provider and lives inside this regime daily. If your firm needs a second pair of eyes on its registration record, its RQI bench or its client list, that is a short conversation. You can also read more on Singapore corporate secretarial practice at Singapore Secretary Services.

The Editorial Team, Raffles Corporate Services