What changed, and when
The Corporate Service Providers Act 2024, together with the Corporate Service Providers Regulations 2025, came into force on 9 June 2025. It sits alongside the Companies Act 1967 and extends Singapore's AML/CFT/CPF (anti-money laundering, countering the financing of terrorism, and countering proliferation financing) framework to a broader range of corporate service activities than the previous Registered Filing Agents regime covered.
Who must register
Under the Act, a corporate service provider (CSP) is broadly any person carrying on a business of providing designated services in Singapore, including incorporating companies, acting as or arranging for someone to act as a director, secretary, or nominee, and creating or managing legal persons or arrangements. This can capture accounting firms once they carry out ACRA transactions on a client's behalf, not only dedicated secretarial firms. Only ACRA-registered CSPs may lawfully provide these services, and ACRA maintains a public register so clients can verify a provider's standing.
What registered CSPs must do
Registered CSPs must carry out Customer Due Diligence (CDD) before providing a designated service and before lodging a transaction with ACRA on a customer's behalf, with Enhanced Due Diligence required for higher-risk customers such as politically exposed persons. Where CDD cannot be completed, the CSP must decline the engagement and consider whether a Suspicious Transaction Report is warranted. CDD and related records must be kept for at least five years after an engagement ends. Each CSP must appoint a senior, suitably qualified individual responsible for AML/CFT compliance, and maintain a documented risk assessment and internal AML/CFT policies and procedures.
Nominee arrangements
The regulations also introduced a specific disclosure requirement for nominee directors and nominee shareholders: both the nominee's status and the identity of the person who appointed them (the nominator) must now be disclosed to ACRA — intended to prevent nominee arrangements being used to obscure who actually controls a company.
Sources
- Corporate Service Providers Act 2024 (Singapore Statutes Online)
- Corporate Service Providers Regulations 2025 (S 292/2025)
- ACRA — Guidelines for Registered Corporate Service Providers, acra.gov.sg
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