No, a Singapore company does not have to use a filing agent for every ACRA transaction. Since 9 June 2025, filing agents have been replaced by registered corporate service providers (CSPs) under the Corporate Service Providers Act 2024. A director, company secretary or other authorised person can file for their own company on Bizfile, using Singpass to incorporate and Corppass afterwards. You need a registered CSP when nobody involved can log in, most commonly a foreign founder without Singpass, or when you want someone else to file for you. Anyone who files for other companies as a business must itself be registered with ACRA.
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.
What happened to “registered filing agents”?
Before June 2025, firms that filed on Bizfile for clients were registered filing agents under the ACRA Act. The Corporate Service Providers Act 2024 came into force on 9 June 2025 and replaced that regime. ACRA treats existing registered filing agents as registered CSPs, so the label has changed but many of the same firms are still doing the work.
The new regime is wider. ACRA lists six types of corporate service that require registration when provided to others: setting up companies and other entities, providing registered office and other addresses, acting or arranging for others to act as directors or secretaries, nominee shareholder services, certain accounting services for designated activities, and filing ACRA transactions on behalf of others or for companies where the provider is the secretary. Section 7 of the Act prohibits carrying on a business of providing a corporate service in Singapore without being registered for that type of service. The penalty on conviction is a fine of up to S$50,000, imprisonment of up to two years, or both.
For a business owner, the practical message is simple: if someone is charging you to file on Bizfile, act as your company secretary or provide your registered address, they should be a registered CSP.
Can I file with ACRA myself?
Yes, for your own company. ACRA’s guidance says you do not need to register as a CSP if you are filing for your own entity as a director, secretary, partner, sole proprietor or other authorised representative, or for a holding company or related corporations as a group secretary or their authorised employee.
Which login you use depends on whether the company exists yet:
- Incorporating a new company: the person who reserved the company name logs in to Bizfile as an individual user with Singpass, and must also be appointed as a director or secretary of the new company. The other position holders then endorse the registration within 60 days. ACRA’s current incorporation fee is S$300.
- Filings after incorporation: annual returns, changes of officers, share allotments and other company transactions are made as a business user through Corppass, which the company’s Corppass administrator sets up and assigns.
- Personal tasks: endorsing your own appointment or verifying your email address are done as an individual user with Singpass. Our guide to logging in to Bizfile as an individual explains which door to use.
Singpass is available to Singapore citizens, permanent residents and holders of a Foreign Identification Number, such as Employment Pass holders, who are at least 15. That is why the login, not the law, is usually the real obstacle for overseas founders.
Which transactions can a director file, and when is a CSP needed?
| Situation | Can the company’s own people file? | When a registered CSP is the usual route |
|---|---|---|
| Incorporating a local company | Yes, if the person who reserved the name has Singpass and will be a director or secretary | No proposed officer has Singpass, or you want the CSP to handle endorsements and documents |
| Annual return | Yes, a director or the company secretary through Corppass | The company has no one who can log in, or the CSP already prepares the accounts and AGM papers |
| Appointing or removing a director or secretary | Yes, through Corppass, with the person’s consent | The incoming officer is overseas and the paperwork needs coordinating |
| Share allotment or transfer, registered office change | Yes, through Corppass | Supporting resolutions and registers need preparing at the same time |
| Registering a foreign company branch or other foreign business | No | ACRA says all foreign businesses must engage a CSP to register in Singapore |
| Sole proprietorship, partnership, LLP or VCC registered by a foreigner without Singpass | No | ACRA’s guides say foreigners without Singpass must engage a CSP |
ACRA’s local company guide presents a CSP as an option rather than a requirement, but in practice a founder who has no Singpass cannot log in to file the incorporation personally, so a CSP files it. Every company also needs at least one director who meets ACRA’s local residency rules, and must appoint a company secretary within six months of incorporation. Those are separate requirements from the question of who presses “submit”. Our guide to registering a Singapore company as a foreigner covers the residency side.
What will a CSP do before it files for me?
A registered CSP must carry out customer due diligence before providing a corporate service. Expect to provide identity documents for directors, shareholders and beneficial owners, proof of address, an ownership chart for corporate shareholders and an explanation of what the company will do and where its money comes from. Our article on why your corporate secretary asks for KYC documents explains each request.
For an existing company, there is one more step. ACRA says a CSP can only file for a client after adding it to its client list on Bizfile, and newly added clients must endorse the request before the CSP gets filing access. An authorised position holder of your company approves it from the Bizfile dashboard. We have set out the screens in how to authorise our request to add your company to our client list.
How do I check that a provider is registered?
- Go to Bizfile and use the free entity search, without logging in.
- Search for the provider’s name or UEN and open its profile.
- If it is a registered CSP, its CSP information appears at the bottom of the entity profile, with its CSP details.
- If the details are unclear, ask the provider to confirm in writing which types of corporate service it is registered to provide.
Once a CSP is appointed, you can see it on your company’s Bizfile dashboard. ACRA says authorised position holders can remove the filing access of any CSP the company no longer engages, which is worth doing when you change providers.
Should I file myself or use a CSP?
Filing yourself is entirely lawful and works well for a simple company with a resident director who is comfortable with Bizfile. The risks are not in the login but in the content: a filing that does not match the company’s resolutions or registers, a missed deadline, or a change that needed shareholder approval first. Directors are responsible for what is filed in the company’s name, whoever submits it.
A CSP tends to make sense when:
- no officer has Singpass, or the only resident director is a nominee;
- the company secretary role is also outsourced, since the secretary usually files anyway;
- a filing has to be supported by resolutions, updated registers or a share certificate prepared at the same time;
- you want one party tracking the dates in your company compliance calendar.
Example: two founders, two answers
Example: Mei, a Singapore citizen, incorporates a design company on her own. She reserves the name, logs in with Singpass, appoints herself as director and her brother, who lives in Singapore, as secretary, and pays the fee. She later sets up Corppass and files the company’s first annual return herself. She never needs a CSP, although she must still keep proper registers and minutes. Lars, a founder based in Denmark with no Singapore pass, wants a Singapore holding company. He has no Singpass, so he engages a registered CSP, completes its due diligence, and the CSP files the incorporation, provides a resident nominee director under a written agreement and acts as company secretary. When Lars later obtains an Employment Pass and Singpass, he can file some transactions himself if he wishes. Both scenarios are hypothetical.
Frequently asked questions
Is a registered filing agent the same as a CSP?
Broadly, yes. Registered filing agents became registered CSPs automatically on 9 June 2025, but the CSP regime covers more services and comes with anti-money laundering duties.
Can my company’s accountant file on Bizfile for us?
Only if the firm is a registered CSP for filing services, or the accountant is filing as your company’s own officer or authorised representative. ACRA notes that public accounting entities need CSP registration if they file transactions for others.
Does using a CSP mean the directors do not need to sign anything?
No. If a CSP files the incorporation, the other position holders do not need to endorse it on Bizfile, but the CSP will still collect signed consents, declarations and resolutions as evidence for its records.
Can an employee who is not a director file for the company?
An authorised employee can file through Corppass if the company’s Corppass administrator has assigned the Bizfile e-service to them. The directors remain responsible for what is filed.
What happens if I pay an unregistered provider?
Carrying on a corporate services business without registration is an offence by the provider, and an unregistered provider has no CSP access to file for your company on Bizfile. Check its registration before paying.
Need help with ACRA filings?
Raffles Corporate Services is a registered corporate service provider. We incorporate companies for local and overseas founders, act as company secretary, prepare the resolutions and registers that support each filing, and file annual returns and other transactions on Bizfile on our clients’ behalf. If you would rather file yourself, we can also review your documents before you submit. Contact us at [email protected] or on WhatsApp at +65 8501 7133.
Willie Tan, Raffles Corporate Services