If your firm forms companies, acts as company secretary, provides a registered office, or arranges nominee directors for clients, the Corporate Service Providers Act 2024 compliance regime already applies to you. Since 9 June 2025, every business offering these services in or from Singapore must register with the Accounting and Corporate Regulatory Authority (ACRA) as a corporate service provider (CSP) and follow strict anti-money laundering obligations.
What the Corporate Service Providers Act 2024 actually changed
Before 9 June 2025, only firms that filed transactions with ACRA on a client’s behalf needed to register as Registered Filing Agents (RFAs). The Corporate Service Providers Act 2024 (Act 22 of 2024), passed by Parliament on 2 July 2024 and assented to on 31 July 2024, closed that gap. Section 2 of the Act defines “corporate service” broadly: forming a corporation on behalf of another person, acting or arranging for another to act as a director, secretary or nominee shareholder, providing a registered office or correspondence address, carrying out designated accounting-related activities, or performing ACRA transactions on a client’s behalf. If your firm does any of these, by way of business, you are a corporate service provider under the Act, whether or not you ever touch BizFile.
Raffles Corporate Services works with a panel of corporate and employment law firms; this article is general information, not legal advice.
Decision tree: do you need to register as a CSP?
Work through these questions in order:
- Do you form companies, LLPs or other legal persons on behalf of clients, even occasionally? If yes, you are in scope.
- Do you act, or arrange for someone else to act, as a director, company secretary or nominee shareholder? If yes, you are in scope, and you also take on nominee-vetting duties.
- Do you provide a registered office, business address or correspondence address for a fee? If yes, you are in scope.
- Do you carry out ACRA transactions (BizFile filings) for clients, or as secretary for multiple companies? If yes, you are in scope, and you likely already held RFA status before the Act.
- Are you an accounting entity performing designated activities such as managing client money or organising the creation of legal persons? If yes, you are in scope even though you are separately regulated as an accountant.
Answering “no” to every question means the Act does not apply to your business model, though it is worth revisiting this test whenever your service lines expand.
Registration, fees and the practical timeline
Registered CSP status runs for a two-year period, with a registration fee of S$400 for the CSP and S$200 for each registered qualified individual (RQI) over that period, a change from the previous annual RFA/RQI fee structure. Firms that were validly registered as RFAs before 9 June 2025 were transitioned into deemed CSP registration, but new entrants and firms newly caught by the wider definition must apply directly to the Registrar of Corporate Service Providers, an ACRA officer appointed under section 5 of the Act. The Registrar maintains a public register of registered CSPs and a separate register of registered qualified individuals under section 6.
What happens if you do not register
Carrying on a business of providing corporate services without registration is an offence attracting a fine of up to S$50,000, imprisonment of up to two years, or both, plus a further daily fine of up to S$2,500 for a continuing offence. Registered CSPs that breach their anti-money laundering, counter-terrorism-financing or counter-proliferation-financing obligations face fines of up to S$100,000 per breach, and senior management can be personally liable for the same amount if they fail to ensure compliance.
The nominee director rule that trips up small firms
A change that catches many smaller practices off guard: nobody may act as a nominee director by way of business unless a registered CSP arranged the appointment and assessed the individual as fit and proper. A registered CSP that arranges a nominee director without that fit-and-proper check is liable to a fine of up to S$100,000, and the individual who accepts the nominee role outside a CSP arrangement faces a fine of up to S$10,000. This is a direct response to shell-company structures where unqualified nominees were used to obscure beneficial ownership, and it sits alongside the existing duty under section 157A(1) of the Companies Act 1967 for every director, nominee or otherwise, to act honestly and use reasonable diligence in discharging their duties.
Cost and timeline snapshot
- Commencement: 9 June 2025 (already in force).
- Registration period: 2 years, versus 1 or 2 years previously for RFAs.
- CSP registration fee: S$400 per 2-year period.
- RQI registration fee: S$200 per 2-year period.
- Maximum offence fine for unregistered CSP activity: S$50,000 plus up to 2 years’ imprisonment.
- Maximum fine for AML/CFT/PF breaches: S$100,000 per breach, for both the CSP and its senior management.
How this interacts with your beneficial ownership filings
The CSP Act 2024 was passed together with the Companies and Limited Liability Partnerships (Miscellaneous Amendments) Act 2024, which strengthened Singapore’s Register of Registrable Controllers (RORC) and beneficial ownership transparency regime. Registered CSPs now play a gatekeeper role in that regime: they must satisfy anti-money-laundering due diligence before onboarding a client, and nominee arrangements must be disclosed and filed with ACRA. Our companion piece on the Register of Registrable Controllers sets out what a Singapore company itself must file, separately from the CSP’s own obligations, and our sister site has a detailed RORC and beneficial-owner register FAQ under the CSP Act 2024 if you want the client-facing side of this in more depth.
Because the Act also touches who a company may lawfully appoint as a resident director or company secretary, businesses that are simultaneously navigating work pass strategy for foreign directors should also look at how COMPASS scoring interacts with corporate appointments; our employment-focused affiliate has a useful guide to the COMPASS framework, points and shortage-list bonuses for foreign hires who may also sit on the board.
Who this actually affects, in practice
It helps to think in terms of business models rather than industry labels. A boutique accounting practice that only prepares management accounts and tax computations, with no involvement in incorporation, secretarial filings or registered addresses, sits outside the Act. The same practice, the moment it agrees to act as company secretary for even one client company, or to hold a nominee shareholding while a foreign investor’s own incorporation is finalised, steps inside the regime and must register within a reasonable time of starting that activity. Law firms that occasionally form special purpose vehicles for transactional clients are also caught, as are HR consultancies that quietly provide a registered address for a client’s Singapore branch as a convenience. The Act does not care about your primary business description on ACRA’s own records; it looks at what you actually do for clients.
Groups and umbrella structures
Where a corporate services group operates through several related entities, for example a secretarial arm and a separate accounting arm under common ownership, each entity that independently provides a corporate service in its own right generally needs its own CSP registration, rather than relying on a sister company’s registration. This is a common area of confusion during group restructurings, and worth confirming directly with ACRA or your compliance adviser before assuming a single group registration covers every entity.
Building a practical compliance checklist
For a firm working through this decision tree and concluding that registration is required, the practical steps typically run as follows. First, identify every key appointment holder within the business, since the definition covers sole proprietors, partners, directors, the chairperson or chief executive officer of a company, and any other individual principally responsible for managing the corporate services side of the business. Second, assess which of those key appointment holders also need to register individually as a registered qualified individual, which carries its own qualification route through the Institute of Singapore Chartered Accountants or the Chartered Secretaries Institute of Singapore pathway. Third, put in place the customer due diligence, screening and record-keeping processes required under the Corporate Service Providers Regulations 2025, rather than treating these as a box-ticking exercise to be revisited only when ACRA asks. Fourth, review every existing nominee director and nominee shareholder arrangement on your books against the new fit-and-proper requirement, since arrangements that were acceptable informally before 9 June 2025 are not automatically grandfathered if they continue without the required assessment.
Common mistakes to avoid
- Assuming that because you never file with ACRA directly, you are outside the Act. Providing a registered office or acting as a nominee shareholder is enough to bring you into scope.
- Continuing an informal nominee director arrangement that predates June 2025 without routing it through a registered CSP’s fit-and-proper assessment.
- Treating the CSP Act as purely an administrative registration exercise, when it in fact imposes substantive, ongoing AML/CFT/PF obligations under the Corporate Service Providers Regulations 2025.
- Forgetting that senior management, not just the corporate entity, can be personally fined for compliance failures.
FAQs
Does the Corporate Service Providers Act 2024 replace the Registered Filing Agent regime?
Yes. RFAs who were validly registered before 9 June 2025 were transitioned into deemed CSP registration, but the Act widens the pool of businesses caught to include those that never filed with ACRA directly, such as registered-office-only providers.
Do I need to register if I only provide a registered address, with no secretarial work?
Yes. Providing a registered office, business address, correspondence or administrative address for another person is itself a listed “corporate service” under section 2 of the Act.
Can an individual still act as a nominee director privately, outside any firm?
Not by way of business. A person must not act as a nominee director by way of business unless a registered CSP arranged the appointment after a fit-and-proper assessment.
Where can I find the compliance obligations in detail?
The substantive AML/CFT/PF duties sit in the Corporate Service Providers Regulations 2025, made under the Act, and ACRA’s published guidelines for registered CSPs.
Does this Act affect companies themselves, or only service providers?
Primarily service providers, but companies should confirm that any firm handling their incorporation, secretarial or nominee arrangements is a registered CSP, since using an unregistered provider carries its own risks.
Related guides
For the underlying beneficial ownership filing that many CSP clients must still make themselves, see our guide on registrable controllers in Singapore.
Deciding whether the Corporate Service Providers Act 2024 changes how your firm, or your appointed corporate secretary, must operate is not always straightforward, particularly around nominee arrangements and registered-office services. Raffles Corporate Services can help you work through the decision tree above for your specific structure.
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.
The Editorial Team, Raffles Corporate Services