Every registered filing agent, corporate secretarial firm and one-person CSP practice in Singapore now operates inside the Corporate Service Providers Act 2024 (CSP Act) regime. What fewer people realise is that the regime itself is not simply handed down from ACRA to the industry in one direction. Since November 2025, ACRA has run a standing 11-member Corporate Service Providers Advisory Panel (CAP) that sits between the regulator and the sector, discussing issues, testing proposals and advising on where the CSP landscape is heading next.
For a firm like Raffles Corporate Services (RCS), which is itself a registered CSP under the same Act, the CAP is not an abstract governance curiosity. Its three-year focus areas of regulatory compliance, professional competency and technology developments are a reasonably reliable signal of where the next round of CSP obligations, guidance and enforcement emphasis will land. Yet despite RCS having covered the CSP Act in depth elsewhere on this site, the CAP itself has never been explained here.
This article sets that right. We look at what the CAP actually does, who sits on it, how it differs from ACRA’s compliance and enforcement function for CSPs and RQIs, and what its priorities suggest for SME directors and CSPs planning ahead, against the backdrop of ACRA’s overview of the CSP Act regime.
What the CAP Is, and Why ACRA Set It Up
The Corporate Service Providers Advisory Panel (CAP) is a standing advisory panel established by ACRA under the CSP Act 2024 regime. According to ACRA’s own webpage on the panel (last updated 29 January 2026), the CAP was formed to strengthen ACRA’s partnership with the CSP community as the sector transitioned from the older Registered Filing Agent (RFA) framework into full registration and supervision under the CSP Act.
ACRA’s November/December 2025 issue of ACRAConnect, its newsletter for professional stakeholders, confirms the panel was set up in November 2025 and describes it as an 11-member body “made up of stakeholders from the CSP sector” that would “focus on three areas over the next three years: regulatory compliance, professional competency and technology developments.” That framing matters. The CAP was not established as a one-off consultation exercise; it is a multi-year structure built to track the CSP Act regime as it matures.
A Standing Panel, Not a One-Time Consultation
The distinction between a standing panel and an ad hoc consultation is not a technicality. A one-off feedback exercise closes once ACRA has what it needs. A standing panel keeps meeting, keeps discussing, and keeps being consulted as rules bed in and new issues emerge. For CSPs and the directors who rely on them, that means the CAP is a continuing channel through which practical friction in the CSP Act regime, such as ambiguous client due diligence expectations or awkward transitional provisions for former RFAs, can in principle be raised and refined over time rather than left to a single implementation phase.
The Three Formal Roles ACRA Has Given the CAP
ACRA’s CAP webpage sets out the panel’s remit in three parts. The CAP is there to:
- discuss issues relevant to CSPs;
- provide feedback on ACRA’s proposals relating to CSPs; and
- advise on developments relating to CSPs, both locally and internationally.
Read together, these three roles position the CAP as a sounding board rather than a decision-making body. It does not approve or veto ACRA policy. What it does is give ACRA a structured, sector-informed reaction before a proposal is finalised, and a standing source of intelligence on how CSP regulation is evolving in other jurisdictions. For a firm operating a business registration and corporate secretarial practice under ACRA’s oversight, that quiet feedback loop is worth understanding, because proposals that eventually become compliance obligations for every CSP often pass through a body like this first.
Who Sits on the Panel
The CAP is co-chaired by Mr Leong Weng Tat, Deputy Chief Executive of ACRA’s Registry and Compliance Group, and Mr Raymond Lam, Managing Director of RL Law LLC and Treasurer of the Chartered Secretaries Institute of Singapore. Pairing a senior ACRA regulator with a practising lawyer and professional-body office holder as co-chairs is a fairly deliberate structural choice: it keeps the panel anchored to both the regulator’s supervisory perspective and the profession’s operating reality.
The remaining nine members, as listed on ACRA’s website, are drawn from across the corporate service ecosystem, including firms offering corporate secretarial and management services, law firms, accounting networks and CSP-focused technology providers. We mention this composition purely as a matter of public record, since ACRA names each member on its own website; it is not an endorsement of, referral to, or commercial relationship with any of the individuals or organisations concerned, several of which compete directly with RCS in the Singapore CSP market.
What the composition does tell us is that ACRA deliberately built a panel spanning different segments of the CSP sector, from traditional corporate secretarial and accounting firms to newer, more technology-led service providers, rather than drawing solely from one type of practice. That breadth is consistent with a regime that, since the CSP Act 2024 came into force, now covers a much wider range of firm sizes and business models than the old RFA framework did.
The Three-Year Focus: Compliance, Competency and Technology
ACRA has said the CAP’s work over its first three years will concentrate on three areas. Each is worth unpacking for what it signals about the direction of travel for CSP obligations.
Regulatory Compliance
This is the most immediately practical of the three. It points to continued attention on how CSPs actually apply their obligations under the CSP Act, things like client due diligence, maintaining accurate client lists, and the declarations Registered Qualified Individuals (RQIs) and directors must make. RCS has separately covered how ACRA has tightened related obligations, including the tougher penalties now attached to the registers of nominee directors, nominee shareholders and controllers, and the amended Form 45 money-laundering disqualification declaration that directors and RQIs are now required to sign. A panel with regulatory compliance as a standing agenda item is likely to keep this kind of tightening under active review rather than treating it as a one-off reform.
Professional Competency
The second focus area concerns the standard of practice within the CSP sector itself, an area closely tied to how RQIs are trained, appointed and held accountable. RCS has written previously about the practical edge cases this can produce, including cases where a nominee director becomes uncontactable and a CSP must navigate ACRA’s strike-off guidance on their client’s behalf. A CAP work stream on competency suggests ACRA anticipates further guidance, and possibly further training or qualification expectations, for the individuals who sit as RQIs across the industry.
Technology Developments
The third area reflects how much of CSP work, from Bizfile filings to client due diligence checks, is now conducted through digital platforms. RCS’s own guidance on using Bizfile’s search functions for due diligence before signing anything is a small example of how technology already shapes day-to-day CSP compliance. With CSP-focused technology providers represented on the panel, this focus area is likely to influence how ACRA thinks about digital filing tools, e-KYC processes and system-based compliance checks over the coming years.
How the CAP Differs from ACRA’s Compliance and Enforcement Functions
It is worth being precise about what the CAP is not. ACRA maintains a separate compliance and enforcement function for CSPs and RQIs, covering inspections, investigations and disciplinary action for breaches of the CSP Act. The CAP has no role in that process. It does not investigate individual CSPs, does not sit in judgement on specific breaches, and does not decide enforcement outcomes. Its role is upstream and advisory: shaping how rules are framed and refined, not applying them to any particular firm.
This separation matters for two reasons. First, CSPs should not assume that having sector representatives on the CAP gives them any informal channel to influence how their own compliance matters are handled; the enforcement side operates independently. Second, the CAP’s existence does not reduce a CSP’s own responsibility to stay current with its obligations. A firm still needs to track ACRA’s compliance and enforcement guidance directly, rather than treating the advisory panel as a substitute for it.
What This Means in Practice for SME Directors and CSPs
For SME directors who rely on a CSP for corporate secretarial support, the CAP is largely invisible day to day, but its three focus areas are a useful early-warning system. If regulatory compliance, professional competency and technology are ACRA’s stated priorities for the next three years, directors should expect their CSP to be tightening client due diligence processes, keeping RQI records current, and adopting more system-based compliance checks over that period, not less.
For CSPs themselves, the practical takeaway is to treat the CAP’s focus areas as a rough roadmap rather than background noise. A firm that is already disciplined about its RQI appointments, its client list maintenance, and its declarations under the CSP Act is well placed regardless of what the CAP eventually recommends. A firm that has been treating these as box-ticking exercises has three years’ notice that scrutiny in exactly these areas is unlikely to ease off.
Practical Checklist: What to Ask Your CSP or Confirm as a CSP
- Is your CSP registered with ACRA under the CSP Act 2024, and can it confirm its Registered Qualified Individual (RQI) appointments are current?
- Does your CSP maintain an accurate, up-to-date client list as required under the CSP Act?
- Has your CSP reviewed its due diligence procedures against ACRA’s latest guidance, rather than relying on processes carried over from the old RFA framework?
- If you are a CSP, are your directors and RQIs aware of, and have they signed, the current declarations ACRA requires, including the amended Form 45?
- Are you or your CSP tracking ACRA’s CSP-related announcements directly, rather than assuming changes will be flagged informally?
Frequently Asked Questions
Is the CAP a regulator or an enforcement body?
No. The CAP is a standing advisory panel. It discusses issues, gives feedback on ACRA’s proposals, and advises on CSP developments. Compliance inspections and enforcement action against CSPs and RQIs are handled separately by ACRA.
Can a CSP apply to join the CAP?
ACRA’s published materials do not describe an open application process for the current panel; membership is drawn from ACRA’s own outreach to sector stakeholders. Firms with views on CSP regulation can still raise them through ACRA’s usual public consultation channels.
Does the CAP set new rules for CSPs?
No. The CAP advises and feeds back; ACRA remains the body that sets and enforces CSP Act requirements. The CAP’s influence is on how proposals are shaped before they are finalised.
Why does the CAP’s three-year focus matter to my company, if I am not a CSP myself?
If your company is a Singapore-incorporated entity, you almost certainly rely on a CSP for company secretarial and filing functions. The CAP’s focus areas indicate the standards your CSP is likely to be held to, and by extension, the level of diligence you should expect from them, over the next few years.
Final Word
The Corporate Service Providers Advisory Panel is a quiet but structurally important part of how the CSP Act 2024 regime will keep evolving. It does not replace ACRA’s rule-making or enforcement powers, but it does give the CSP sector a standing, three-year mandated voice in how those rules are shaped, covering exactly the areas, regulatory compliance, professional competency and technology, that most directly affect how a CSP serves its clients. For SME directors, the practical lesson is simple: choose a CSP that already treats these three areas seriously, because the body advising Singapore’s regulator has just told the whole sector that this is where the scrutiny is heading.
The Editorial Team, Raffles Corporate Services