If your company uses a corporate secretarial firm, a registered office address, or a nominee director arrangement in Singapore, the rules governing that relationship changed materially when the Corporate Service Providers Act 2024 took effect on 9 June 2025. Most of the commentary on this Act has, understandably, been written for the corporate service providers (CSPs) themselves, covering registration, fit-and-proper checks and the registered qualified individual (RQI) regime. Less has been said about what changes for the companies on the other side of the table: the clients.
This matters because the Act does not just tighten obligations on providers in the abstract. It changes what your CSP is legally allowed to ask you for, what it must verify before it can act for you, and what happens if the firm you have engaged has not registered at all. A director who assumes nothing has changed on their end of the engagement may be surprised the next time their corporate secretary asks for source-of-funds documentation or a fresh round of identification checks.
This article sets out, in plain terms, what the Corporate Service Providers Act 2024 requires of CSPs and, more importantly, what it means practically for the companies and individuals who engage one. For the registration mechanics from the provider’s side, our companion pieces on CSP Act eligibility and requirements and the documents and templates CSPs now need go into greater depth.
What the Corporate Service Providers Act 2024 actually changed
The Corporate Service Providers Act 2024 was passed by Parliament on 2 July 2024 and commenced on 9 June 2025, alongside the Corporate Service Providers Regulations 2025. It was administered by the Accounting and Corporate Regulatory Authority (ACRA) and replaces the older registered filing agent (RFA) framework that many practitioners will remember.
Under the previous regime, only firms that actually lodged transactions with ACRA on a client’s behalf had to register as RFAs and were subject to anti-money laundering and countering the financing of terrorism (AML/CFT) obligations. A firm that provided a registered office address, or arranged nominee directors, but never filed anything itself, could sit outside that regime entirely. ACRA identified this as a regulatory gap: such firms could be used, wittingly or not, to help set up shell companies for illicit purposes.
The new Act closes that gap. Every business entity carrying on a business of providing a corporate service in or from Singapore must now register with ACRA as a CSP, whether or not it lodges filings itself. Corporate services caught by the definition include company incorporation, acting as or arranging for a company secretary, providing a registered office address, and arranging for nominee directors or shareholders. Registered CSPs must comply with AML/CFT and countering proliferation financing (AML/CFT/PF) obligations, and a failure to register is an offence carrying a fine of up to S$50,000, imprisonment of up to two years, or both.
Old regime versus new regime, at a glance
| Aspect | Registered Filing Agent (RFA) regime (before 9 June 2025) | Corporate Service Provider (CSP) regime (from 9 June 2025) |
|---|---|---|
| Who must register | Only firms that lodge transactions with ACRA on a client’s behalf | Any entity providing a corporate service by way of business, whether or not it files with ACRA |
| Nominee director arrangements | Not specifically regulated under the RFA scheme | Must be arranged by a registered CSP, which must first assess the nominee as fit and proper |
| AML/CFT obligations | Applied to RFAs only | Applied to all registered CSPs, extended to cover proliferation financing (AML/CFT/PF) |
| Registration period and fee | One or two years; RFA S$200 per year, RQI S$100 per year | Two years; CSP S$400 for two years, RQI S$200 for two years |
| Penalties for breach | Regulatory sanctions, restricted BizFile access, suspension or cancellation | Fines of up to S$100,000 per breach for the CSP and its senior management, in addition to the above |
What this means practically if you are a CSP’s client
None of the fines above fall on you as the client. But the practical consequences of the regime flow through to every company that engages a corporate secretary, uses a registered office service, or has a nominee director on its board. Four changes are worth knowing about.
1. Expect more rigorous know-your-customer (KYC) checks, not fewer
Because registered CSPs must now run documented customer due diligence as part of their AML/CFT obligations, clients should expect their provider to ask for more, not less, at onboarding and periodically thereafter. This typically includes certified identification documents for all directors and shareholders, proof of address, a clear explanation of the intended business activity, and, for higher-risk structures, source-of-funds evidence. If your current provider has not asked you for any of this since June 2025, it is worth asking whether they are registered at all.
2. Beneficial ownership disclosure is now firmly tied to your CSP relationship
The CSP Act works alongside Singapore’s existing beneficial ownership transparency framework. Companies are already required to maintain a register of registrable controllers and file this information with ACRA. Because CSPs handling company formation and secretarial work are now directly accountable to ACRA for the corporate services they provide, they have a stronger incentive, and in many cases a direct obligation, to verify that your beneficial ownership disclosures are accurate and current. Our guide to the Register of Registrable Controllers (RORC) sets out what companies need to maintain on this front.
3. Nominee director arrangements must now run through a registered CSP
If your company structure relies on a nominee director, the Act now prohibits any person from acting as a nominee director by way of business unless the appointment is arranged by a registered CSP. The CSP arranging the appointment must first take reasonable steps to satisfy itself that the proposed nominee is fit and proper, including that the person is not disqualified from acting as a director under Singapore law. A CSP that breaches this requirement faces a fine of up to S$100,000, and the individual acting as an unauthorised nominee faces a fine of up to S$10,000. Clients using nominee arrangements should confirm, in writing, that their provider has completed this vetting. Our practical checklist for a new director joining a Singapore company is a useful reference for the underlying eligibility questions a fit-and-proper assessment will cover.
4. Registration status is now a due diligence item when choosing, or reviewing, a provider
Perhaps the most direct practical consequence is this: engaging an unregistered CSP is no longer just a compliance risk for the provider, it is a risk for you. If your provider is not registered and is later found to be operating unlawfully, your corporate records, registered office, and any documents lodged on your behalf could be thrown into question. Before signing on with a corporate secretarial firm, or renewing with your existing one, ask for their CSP registration number and, where relevant, confirmation of their RQI. Certificates issued by a CSP, such as a certificate of incumbency, carry more weight when you know the issuing firm is properly registered and accountable to ACRA.
A practical example
Consider a Singapore-incorporated trading company with a foreign majority shareholder and a locally resident nominee director arranged through its corporate secretarial firm. Before 9 June 2025, the firm may have arranged the nominee informally, with limited documented vetting. Since the Act commenced, the same firm must be a registered CSP, must have assessed the nominee as fit and proper before the appointment, and must apply ongoing AML/CFT measures to the relationship, including periodic review of the company’s beneficial ownership information. If the company later changes its shareholding structure, it should expect its CSP to ask fresh due diligence questions rather than simply updating a filing, because the CSP’s own compliance obligations require it.
What clients should do now
- Ask your current corporate secretarial provider, registered office provider, or nominee director arranger to confirm their CSP registration status and RQI details.
- Expect, and cooperate with, more thorough onboarding and periodic due diligence requests. These are not signs of an overcautious firm; they reflect a legal obligation the firm now carries.
- Keep your register of registrable controllers current, since your CSP’s own compliance position depends in part on the accuracy of the information you give them.
- If you rely on a nominee director, obtain written confirmation that the appointment was arranged through a registered CSP that carried out a fit-and-proper assessment.
- Treat CSP registration as a standing due diligence item whenever you select or review a corporate secretarial provider, in the same way you would check a law firm’s practising certificate.
The full text of the Act is available on Singapore Statutes Online, and ACRA’s guidelines for registered CSPs provide further detail on the compliance obligations firms must now meet. For companies, the underlying message is straightforward: the Corporate Service Providers Act 2024 was designed to raise the floor across the entire industry, and the clients of a properly registered CSP are, in practice, better protected as a result.
Raffles Corporate Services is a registered corporate service provider under the new regime. If you would like us to review your current corporate secretarial, registered office, or nominee director arrangements against the CSP Act’s requirements, our team is glad to help.
The Editorial Team, Raffles Corporate Services