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Downloading Lists of Your RQIs and CSP Employees

Colleagues discussing documents in a meeting

A registered corporate service provider can export its registered qualified individual list and its authorised employee list straight out of Bizfile, in CSV or XLSX, from the same eService used to manage filing access. It takes under a minute, it costs nothing, and it is the single best compliance control a small CSP can run.

Most firms discover the export by accident, usually while doing something else. That is a shame, because the export is not a convenience feature. It is the only practical way to see your authorised population as a list rather than as a series of individual screens.

A list can be compared against payroll. Screens cannot.

What you get, and why it is useful

Two separate exports, chosen by tab:

Each exported row carries:

Column What it tells you What to check it against
Name Who is on the list Your payroll or HR system
Appointment status Whether the person is currently active Your own view of who is still with the firm
Mobile number The number ACRA will use Current staff contact records
Email address The address ACRA will use Whether the mailbox still exists and is read
Appointment date When they came on to the list Their start date and their AML training date
Withdrawal date When they came off Their last working day

That last pairing is the reason the export earns its keep. Appointment date against training date tells you whether anyone was granted filing access before they were trained. Withdrawal date against last working day tells you whether any leaver stayed authorised. Neither question can be answered by looking at the screens one person at a time, and both are questions an inspection will ask.

Who may download the lists

Authorised position holders of the CSP, such as directors, and RQIs of the firm. You will need Corppass credentials to log in as a Business User. An employee who merely holds filing access cannot pull the list, which is consistent with the general position that filing access lets a person act for clients but not administer the firm’s own register.

If you have not set up Corppass for the firm, or you are not sure which e-services your staff can reach, deal with that first. Our guides to the Business User login route and to assigning Corppass e-service roles safely cover the access layer that sits underneath everything in this article.

The steps, in order

  1. Go to Bizfile, select Login, and choose Business User so you are routed through Corppass.
  2. On the profile selection page, position holders select the CSP firm from their entities. RQIs select the corporate service provider tab, pick the firm from the drop-down list if they serve more than one, and proceed to the dashboard.
  3. Open the Manage filing access for RQIs and CSP employees eService. The dashboard shortcut to your RQIs and authorised employees goes to the same place, as does the “Manage” menu under the corporate service provider grouping.
  4. Choose the tab for the list you want: registered qualified individuals, or authorised CSP employees.
  5. Select Export and choose CSV or XLSX.
  6. Save the file into your compliance folder with the date in the filename, not into a downloads directory where it will be lost by Friday.

Pick XLSX if a human is going to read it and CSV if you are going to compare it against another system. If you are doing the payroll comparison described below, CSV is the better choice, because it will open cleanly in whatever you are already using.

Turn the export into an actual control

The download is trivial. The discipline around it is what matters. A workable quarterly routine, which takes about fifteen minutes:

  1. Export both lists on a fixed date each quarter. Fix the date, because a control that happens “when someone remembers” is not a control.
  2. Compare the employee list against payroll. Anyone on the ACRA list who is no longer on payroll is a leaver whose filing access was never withdrawn. Withdraw it the same day and record why it was missed.
  3. Compare payroll against the ACRA list in the other direction. Anyone filing for clients who is not on the list should not be filing at all. That is the more serious finding of the two.
  4. Check every appointment date against the person’s AML, terrorism financing and proliferation financing training record. A grant that predates the training is a gap, and it is better that you find it than that ACRA does.
  5. Check contact details are alive. A bounced email address on the record is a notification you never received.
  6. Check the RQI list separately. RQIs are registered in their own right, and a firm that has quietly dropped below the RQI coverage it needs has a structural problem, not an administrative one.
  7. Save the export and a one page note of what you found and fixed. The note is what turns a spreadsheet into evidence that the control operated.

If that sounds like more process than a six person firm needs, consider what the alternative looks like when someone asks you to prove, two years after the event, that a particular person was authorised on a particular date.

What goes wrong in practice

The export is pulled and never read. A file in a folder is not a review. If nobody compares it against something, you have downloaded a list and learned nothing.

The list is treated as personal data with no handling rules. These exports contain names, mobile numbers, email addresses and appointment histories of identifiable individuals, which is personal data under the Personal Data Protection Act 2012. Do not email it to a personal account, do not leave it on a shared drive that the whole office can read, and do not keep copies indefinitely because they were easy to make. The PDPC sets out the obligations, and a CSP that handles client due diligence material is expected to know them.

Comparing against the wrong staff list. Payroll is the right comparator because it is maintained by someone whose job depends on getting it right. An informal team roster is not.

Mistaking Corppass for the CSP list. They are different registers maintained by different people for different purposes, and they drift. Reconciling both is part of the quarterly job. The transaction history in Bizfile is the third leg of that reconciliation: it shows what was actually filed, by whom, and when, which is what the access lists are supposed to predict.

Finding a problem and fixing it silently. If a leaver was authorised for four months after departure, check the transaction history for that window before you close the point. The withdrawal is the fix for the future. The transaction check is the fix for the past.

Frequently asked questions

What file formats can I export in?
CSV or XLSX. Choose XLSX for a document a person will read and CSV if you are going to compare the data against payroll or another system. There is no fee for either.

Does the export include people who have left?
Yes. The file carries appointment status and a withdrawal date, so departed staff appear with their withdrawal recorded. That is precisely what makes the export useful as an audit record rather than just a current headcount.

Can an employee with filing access download the list?
No. The eService is available to authorised position holders of the CSP, such as directors, and to the firm’s RQIs. Filing access lets a person file for clients; it does not let them read or administer the firm’s own authorised population.

How often should we pull the lists?
Quarterly is a sensible baseline for most firms, plus an ad hoc export whenever there is a wave of joiners or leavers. The value comes from comparing the export against payroll and training records, not from the download itself.

Is the export the same thing as our statutory client list?
No. Maintaining client lists is a separate obligation for CSPs with its own requirements. The RQI and employee exports tell you about your own people, not about the entities you act for.

Can I use the export to prove someone was authorised on a given date?
It is good evidence, because it carries appointment and withdrawal dates, but keep the transaction acknowledgements too. A dated export plus the original acknowledgement is a much stronger record than either alone.

The ten minute habit worth having

There is no elegant way to say this: the export exists, it is free, and most CSPs have never opened it. The firms that do run it quarterly are also the firms that never have an awkward conversation about a leaver who kept filing.

If you want the underlying mechanics, read our companion pieces on managing employees’ filing access as a registered CSP and on updating CSP employees’ particulars. For the wider obligation set the lists sit inside, see our Corporate Service Providers Act 2024 compliance FAQ, and the Act itself is on Singapore Statutes Online.

Raffles Corporate Services is a registered corporate service provider and runs this review on its own filings. If you would like a second pair of eyes on how your firm’s access lists are being maintained, that is a short conversation.

The Editorial Team, Raffles Corporate Services

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