Telling ACRA When Your CSP or RQI Details Change

If you are a registered corporate service provider, changes to your firm’s particulars must be filed with ACRA as soon as they happen. If you are a registered qualified individual, you have 14 days. Those are two different standards, and mixing them up is where firms get caught.

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.

The Corporate Service Providers Act 2024 turned a voluntary filing-agent scheme into a licensed regime. One consequence that firms underestimate is that ACRA now holds a live record of who you are, what services you offer, who your RQIs are and how to reach them. That record is the basis on which ACRA supervises you, and it is the record a compliance reviewer will open first.

So the obligation is not administrative housekeeping. A stale record is a supervisory finding waiting to happen, and at renewal time it is the thing that stalls your application.

What actually has to be reported

Four separate categories, each with its own trigger, its own timing and its own eService. They are not interchangeable.

There is no fee for any of these, and processing is immediate. The cost of getting them wrong is entirely downstream.

The trap in the CSP firm particulars row

Read that first row again. It says business address, and it excludes the registered office address.

Those are frequently the same address for a small CSP, which lulls people into thinking one filing covers both. It does not. Changing your registered office is a Companies Act 1967 filing about your company. Changing your CSP business address is a CSP Act filing about your regulated business. If you move premises you do both, and you do them separately.

The same logic applies to your service scope. If your firm starts offering a corporate service it was not offering when it registered, that is a change to the types of corporate services provided and it needs to go in. Firms tend to file diligently when they add a service line formally, and not at all when a service creeps in because a client asked and someone said yes.

Why the RQI deadline is the one to write down

The 14-day window for RQI particulars is the only hard clock in this whole area, and it belongs to the individual, not the firm.

That last point matters more than it sounds. Only the RQI can file their own updates. A practice manager cannot do it for them, the firm’s company secretary cannot do it for them, and no amount of internal delegation moves the obligation. If an RQI changes their residential address or picks up a new professional qualification, that person logs in and files it.

The categories are broad. Name, identification type and number, nationality, address, contact number, email address, qualifications and the documents evidencing those qualifications. In practice the ones that slip are address changes (nobody thinks of ACRA when they move house), email changes (people update their work signature and forget the regulator), and qualifications.

Qualifications deserve a line of their own. Adding a professional membership or completing a qualifying course is good news, so nobody thinks of it as a change requiring notification. It is one, and it is also the category ACRA will care about most at renewal, because your qualification record is what your continued eligibility rests on. Keeping it current is not a favour to ACRA. It is you protecting your own registration.

If you are an RQI who also holds company appointments

Most RQIs are also directors, partners or company secretaries of something. That creates an overlap ACRA handles with a rule that catches people out.

The RQI update lodgement is the right route for your RQI qualifications and the documents supporting them. It is not the route for your general personal details if you hold appointments in other entities. Those go through the update position holder information eService instead, which pushes the change across your appointments rather than only against your RQI record.

Use the wrong one and you end up with a correct RQI record and a stale officer record, or the reverse. Both are wrong. If you are unsure which applies to you, file the position holder update first and then check your RQI profile to confirm it carried through.

Key appointment holders: the two-step nobody expects

Changes to a CSP’s key appointment holders are the only item on the list that requires two separate actions.

1. File the change in Bizfile through the Appoint or Withdraw Position Holder transaction, exactly as you would for any company you act for.
2. Separately notify ACRA of the change in key appointment holder using ACRA’s FormSG submission.

Step one updates the company record. Step two tells the regulator that the people responsible for the regulated business have changed. Doing step one and stopping there is the single most common failure in this area, because step one feels complete. The Bizfile transaction goes through, you get an acknowledgement, and nothing tells you there is a second action outstanding.

If your firm has a checklist for officer changes, this is the line to add to it.

Who is allowed to file

Note that RQIs appear on the CSP side as well. An RQI can file changes to the firm’s particulars. That is worth knowing in a small practice where the RQI is often the person who actually understands Bizfile.

What goes wrong in practice

The employee who left three months ago still has filing access. Employee particulars and employee filing access run through the same eService, and firms update the first while forgetting the second. Someone who no longer works for you should not be able to file for your clients. This is the finding that turns a routine compliance review into an uncomfortable one. Our note on managing CSP employee filing access in Bizfile covers the mechanics.

The RQI whose email bounces. ACRA communicates through the Bizfile inbox and by email. An RQI with a dead email address does not see endorsement requests, does not see renewal reminders and does not see compliance correspondence. Endorsements in particular are time-boxed, so a bounced email can cause a firm-level application to lapse. If you want to understand how much rides on notifications actually arriving, read our piece on the ACRA alerts companies miss and what they cost.

The service scope that drifted. Your registration records the corporate services you provide. If the reality has moved on and the record has not, you are operating outside what ACRA thinks you do. Check the scope against your actual engagement letters once a year. Our guide on whether you need to register as a CSP sets out which activities bring a firm inside the regime in the first place.

Everything gets fixed the week before renewal. This is the classic. A firm ignores particulars for two years, then discovers at renewal that the record has to be clean before the renewal will proceed, and spends a fortnight filing changes it should have filed as they happened. See renewing CSP registration for why the renewal eService will send you back to fix things first.

A practical routine that prevents all of this

You do not need a compliance system. You need four habits.

1. On the day anyone joins or leaves the firm, update employee particulars and filing access together, in the same sitting.
2. On the day an RQI tells you anything has changed about them, remind them the 14-day clock is theirs and ask them to confirm when they have filed.
3. On the day the firm changes address, adds a service line or changes its nature of business, file the CSP information update before you update your website.
4. Once every quarter, open your CSP profile and your RQI profiles in Bizfile and read them. Ten minutes. You will find something.

The fourth habit is the one that pays. Records do not go stale in a single dramatic moment. They go stale one small unnoticed change at a time.

Frequently asked questions

How long do I have to tell ACRA about a change to my RQI particulars?
Fourteen days from the change. That applies to your name, identification type and number, nationality, address, contact number, email address, qualifications and the supporting documents for those qualifications. Only you can file it, through the General Lodgement eService in Bizfile. There is no fee and processing is immediate.

Is there a deadline for CSP firm particulars?
ACRA’s standard for firm particulars is as soon as possible rather than a fixed number of days. Treat that as stricter than a deadline, not looser: with no date to point to, you cannot argue you were still within time. File the change when it happens.

Does my registered office change need a separate CSP filing?
Possibly not, but do not assume. The CSP notification covers your business address and specifically excludes the registered office address. If those are the same premises and you move, you file the company law change and the CSP change separately. Check both records afterwards.

Do I have to pay to update my particulars?
No. Updating CSP or RQI particulars is free and takes effect immediately. The cost arises only if you do not do it, through compliance findings, a stalled renewal or a lapsed endorsement.

What if my RQI has left the firm?
That is not a change of particulars. It is a withdrawal, filed through the appointment process rather than the update lodgement. See our guide on appointing and withdrawing RQIs for the correct route and the endorsement steps that follow.

Can my firm file an RQI’s personal update on their behalf?
No. RQI particulars can only be filed by the RQI personally, using their own Singpass login. The firm can remind, chase and diarise, but it cannot file. Build that into your internal process rather than assuming an administrator can clear it.

Keeping your regulated record clean

Raffles Corporate Services is itself a registered CSP, so this is not theory for us. We maintain our own particulars on the same discipline we apply to our clients’ statutory records: file it the day it changes, then check the record afterwards to confirm it landed.

If your firm is registered under the Corporate Service Providers Act 2024 and you are not confident your ACRA record reflects reality, the fix is usually an afternoon rather than a project. Our Corporate Service Providers Act 2024 compliance FAQ covers the wider obligations, and the eligibility and requirements guide covers what you had to satisfy to get registered in the first place, which is also what you must continue to satisfy.

You can reach us through Raffles Corporate Services, see ACRA’s own corporate service provider pages for the official position, or read more on Singapore corporate secretarial practice at Singapore Secretary Services.

The Editorial Team, Raffles Corporate Services