Singapore’s Corporate Service Providers Act 2024 (CSP Act) came into effect in 2025 and has fundamentally reshaped how every Singapore company interacts with its corporate secretary, nominee director and registered filing agent. If you incorporated through a corporate service provider (CSP), or you rely on a nominee director, the rules now reach further than ever before — and the penalties for non-compliance now sit with both the CSP and the company that uses one.
This guide explains what the CSP Act covers, what changed in 2025, and the practical compliance steps every Singapore company should now have in place — including the new “fit-and-proper” duties placed on nominee directors and the heightened ACRA enforcement powers.
Why the CSP Act Was Introduced
Singapore has long been used as a jurisdiction by genuine businesses, but international watchdogs (FATF in particular) flagged that the registered filing agent regime under the old Companies Act did not give ACRA strong enough enforcement tools against bad actors. The CSP Act consolidates oversight of all “corporate service providers” — incorporation agents, corporate secretaries, accountants providing nominee services — under a single regulator (ACRA) with much broader fining and de-registration powers.
The Act sits alongside the Companies Act 1967 and the AML/CFT regime supervised by ACRA and MAS. The official ACRA portal is acra.gov.sg, and the legislation can be read on Singapore Statutes Online.
Who Counts as a “Corporate Service Provider”?
Under the CSP Act, a CSP is broadly any person carrying on a business of providing any of the following services in Singapore:
- Incorporation of companies (and registration of LLPs, LPs, sole proprietorships)
- Acting as, or providing, a director or secretary
- Providing a registered office or business address
- Providing nominee shareholder services
- Performing filings with ACRA on behalf of clients (registered filing agent activity)
- Providing accounting and tax services in conjunction with the above
If your accountant only does bookkeeping with no ACRA filings, they generally fall outside the CSP regime. But the moment they file an annual return, lodge a director resolution, or provide an officer of the company, the Act bites.
Key Obligations Imposed on CSPs From 2025
1. Registration With ACRA
Every CSP must register with ACRA and renew that registration annually. ACRA publishes a public register of approved CSPs, so customers can verify their provider’s standing.
2. AML/CFT Customer Due Diligence (CDD)
CSPs must perform full CDD on each customer at onboarding and on an ongoing basis. Where a beneficial owner cannot be reliably identified, the CSP must decline the engagement. CDD records must be kept for at least five years after the engagement ends.
3. Designated Compliance Officer
Each CSP must appoint a senior management-level Compliance Officer responsible for AML/CFT compliance. The Compliance Officer’s name and qualifications must be disclosed to ACRA.
4. Periodic Risk Assessments
CSPs must maintain a documented business risk assessment, refreshed at least annually, that maps their customer base, the products they offer, and the jurisdictions they touch against money-laundering and terrorism-financing typologies.
5. Reporting of Discrepancies
If a CSP discovers a discrepancy between the company’s stated beneficial ownership and the information in its Register of Registrable Controllers (RORC), it must report the discrepancy to ACRA — even where the client objects.
The New Nominee Director Regime
The most far-reaching change in the CSP Act is the formalisation of the nominee director regime. Two new rules apply with immediate effect:
Fit-and-Proper Test
Any person acting as a nominee director “by way of business” must satisfy a statutory fit-and-proper test before accepting appointment. The test looks at criminal record, regulatory history, bankruptcy status, and financial soundness. Companies are no longer free to appoint just any local director to satisfy the Section 145 resident director requirement — the nominee must be supplied by a registered CSP and must pass the test.
Disclosure on the Register of Nominee Directors
Every nominee director relationship must be recorded on the company’s Register of Nominee Directors, with the nominator’s full identity. ACRA can inspect the register on demand, and inaccurate information attracts financial penalties on both the nominee and the company.
For a deeper dive on this, see our piece on the Nominee Director Singapore 2026: CSP Act, Fit-and-Proper Test & Liability Risks.
What This Means for the Average Singapore Company
If you are a Singapore private company using a corporate service provider — and almost every SME does — the CSP Act has three practical consequences:
| Touchpoint | What Changed | What You Need to Do |
|---|---|---|
| Onboarding | Heavier CDD: passports, address proof, source-of-funds questions, business model disclosure. | Have these ready before incorporation day. Delays in CDD now delay your ACRA filing. |
| Annual KYC refresh | Your CSP must re-verify your shareholders, directors and beneficial owners every year (sooner if there’s a change). | Set a calendar reminder, and respond promptly when your CSP asks for updated documents. |
| Nominee director arrangements | Tighter fit-and-proper requirements and a public-facing register. | Review whether you still need a nominee — many founders now relocate or appoint an EP holder as the resident director. |
| Beneficial ownership accuracy | Discrepancies must be reported to ACRA, with no client veto. | Keep your RORC aligned with reality — back-to-back agreements and silent shareholders are no longer practical. |
Penalties Under the CSP Act
The penalty regime is meaningfully stronger than the old registered filing agent rules. For the most serious breaches — failure to perform CDD, false declarations to ACRA, holding out as a CSP without registration — fines can reach S$100,000 per breach, with imprisonment for officers of the CSP up to two years. ACRA can also suspend or revoke a CSP’s registration, which is fatal to a corporate secretarial business.
Crucially, the CSP Act introduces parallel liability for the company that engages an unregistered CSP. Companies should check ACRA’s public register before signing any corporate secretarial engagement letter.
What Companies Should Do This Year
- Verify your CSP’s registration. Search the ACRA CSP register before renewing your engagement.
- Review your nominee arrangements. If your local director is a friend, family member or non-registered service, your structure is now exposed. Consider engaging a properly registered nominee.
- Update your RORC and Register of Nominee Directors. Run a side-by-side check at the next AGM. Read our RORC filing guide and the nominee directors register guide.
- Document beneficial ownership properly. Trust deeds, side letters and informal ownership arrangements that conflict with the official register must be resolved.
- Refresh your KYC promptly. Late responses to your CSP’s annual refresh requests can result in suspension of services and missed ACRA filing deadlines.
How Raffles Corporate Services Operates Under the CSP Act
Raffles Corporate Services is a registered corporate service provider under the CSP Act and acts as the registered filing agent, corporate secretary and (where the structure permits) nominee director for clients across Singapore, Asia and beyond. Our compliance team handles the ongoing CDD, RORC reconciliations and annual KYC refreshes so directors can stay focused on the business.
For a full picture of the annual filings your company still owes under the Companies Act, refer to our Singapore Company Compliance Calendar 2026 and our Annual Return Filing with ACRA guide. Founders new to Singapore can also benefit from our overview of converting a sole proprietorship to a Pte Ltd and the related immigration pathways.
— The Editorial Team, Raffles Corporate Services