What Is the Corporate Service Providers Act 2024?

The Corporate Service Providers Act 2024 (CSP Act) represents one of the most significant pieces of legislation to impact the corporate services industry in Singapore in recent years. Enacted by Parliament and brought into effect on 9 June 2025, the CSP Act establishes a comprehensive regulatory framework for all business entities that provide corporate services in or from Singapore.

Previously, corporate service providers were regulated under a patchwork of provisions, primarily through the Accounting and Corporate Regulatory Authority Act. The new standalone legislation consolidates and strengthens the rules, with a particular focus on anti-money laundering (AML), countering the financing of terrorism (CFT), and countering proliferation financing (CPF) obligations. If your company engages the services of a corporate secretary, registered filing agent, or nominee director service, the CSP Act directly affects you.

This guide explains what the CSP Act covers, who needs to register, the key compliance obligations, and what it means for Singapore businesses that rely on corporate service providers.

Why Was the CSP Act Introduced?

Singapore has long positioned itself as a premier international business hub. However, the ease of incorporating companies here has also attracted misuse — shell companies used for money laundering, terrorism financing, and other illicit purposes have drawn scrutiny from international watchdogs such as the Financial Action Task Force (FATF).

The CSP Act was introduced to strengthen Singapore’s defences against such misuse. By imposing stricter registration requirements, fit-and-proper standards, and robust AML/CFT obligations on corporate service providers, the Act ensures that the gatekeepers of company formation and administration are held to higher professional and ethical standards.

For business owners who engage corporate secretaries or filing agents, this means greater assurance that your service provider operates with integrity, transparency, and in full compliance with the law.

What Are “Corporate Services” Under the CSP Act?

The CSP Act defines “corporate services” broadly. Under the legislation, the following activities constitute corporate services when carried out as a business:

1. Formation of corporations — Incorporating companies, limited liability partnerships (LLPs), or other entities on behalf of clients.

2. Acting as or arranging nominee directors and shareholders — Providing nominee director services or arranging for individuals to serve as nominee shareholders.

3. Providing registered office or business addresses — Offering a registered address for companies to use as their official address with ACRA.

4. Designated activities related to accounting services — Certain bookkeeping and accounting activities carried out in conjunction with other corporate services for the same client.

5. Filing transactions with ACRA — Lodging documents, annual returns, or other filings with ACRA on behalf of companies, or acting as a company secretary by way of business.

This broad definition means that a wide range of service providers — from corporate secretarial firms to accounting practices — may fall within the scope of the CSP Act.

Who Needs to Register Under the CSP Act?

Any business entity that carries on a business of providing one or more of the above corporate services in or from Singapore must register with ACRA as a Registered Corporate Service Provider (Registered CSP). This requirement applies regardless of whether the entity files transactions with ACRA on behalf of its clients.

Key Points on Registration

The registration obligation is mandatory — operating without registration is a criminal offence. All existing Registered Filing Agents (RFAs) under the previous ACRA regime were automatically transitioned to become Registered CSPs when the Act took effect. New entrants to the corporate services industry must apply for registration with ACRA before commencing business. The registration requirement extends to entities providing corporate services from Singapore to overseas clients, not just those serving local companies.

Exemptions

Certain entities are exempt from the full registration requirements. Public Accounting Entities (PAEs) that are already registered under the Accountants Act and only carry out designated activities related to accounting services do not need to apply separately as Registered CSPs. However, they must still provide ACRA with details of their Registered Qualified Individuals (RQIs). Law firms providing corporate services incidental to their legal practice may also fall under different regulatory arrangements.

The Registered Qualified Individual (RQI) Requirement

One of the centrepieces of the CSP Act is the Registered Qualified Individual (RQI) requirement. Every Registered CSP must have at least one RQI who is responsible for ensuring the firm’s compliance with the Act.

Who Can Be an RQI?

To qualify as an RQI, an individual must hold relevant professional qualifications — for example, qualifications as a lawyer, accountant, or corporate secretary. They must have completed mandatory AML/CFT/CPF training as specified under Section 9 of the CSP Act. They must also meet fit-and-proper criteria, including having a clean disciplinary and criminal record.

Existing RQIs who were registered under the previous ACRA framework are automatically treated as registered under the CSP Act — there is no need for a fresh application. However, all RQIs must ensure they remain up to date with the ongoing training and compliance requirements.

AML/CFT Obligations for Registered CSPs

The CSP Act places significant emphasis on AML/CFT/CPF compliance. Registered CSPs must adhere to stringent obligations, including:

Customer Due Diligence (CDD): CSPs must conduct thorough due diligence on their clients before onboarding them. This includes verifying the identity of beneficial owners and understanding the nature of the client’s business. Companies that have engaged a corporate service provider may be familiar with these checks, as they align with the requirements under the Register of Registrable Controllers framework.

Ongoing Monitoring: CSPs must continuously monitor client relationships and transactions for suspicious activity.

Record-Keeping: Detailed records of all client engagements, due diligence, and transactions must be maintained for prescribed periods.

Suspicious Transaction Reporting (STR): CSPs are required to file STRs with the Suspicious Transaction Reporting Office if they encounter any transactions that raise red flags.

Risk Assessment: Each CSP must conduct regular risk assessments of their business and clients to identify and mitigate AML/CFT risks.

These obligations mirror international best practices and bring Singapore’s corporate services sector in line with FATF recommendations.

Fit-and-Proper Requirements for Nominee Directors

The CSP Act introduces enhanced scrutiny for nominee director arrangements. Under Section 15 of the Act, Registered CSPs that provide nominee director services must conduct a thorough assessment to confirm that the proposed nominee director meets fit-and-proper standards before the appointment is made.

This is particularly relevant for foreign entrepreneurs who require a local resident director for their Singapore company. The CSP Act ensures that nominee directors are not merely names on paper but individuals who have been properly vetted and are capable of discharging their duties.

Failure to conduct proper assessments can result in fines of up to S$100,000 for the CSP.

Penalties for Non-Compliance

The CSP Act carries substantial penalties for non-compliance:

Operating without registration: A fine of up to S$50,000, imprisonment for up to two years, or both. A continuing offence attracts a further fine of up to S$2,500 per day.

Providing false or misleading information to ACRA: Fines of up to S$25,000.

Failure to conduct fit-and-proper checks on nominee directors: Fines of up to S$100,000.

Breach of AML/CFT obligations: Various penalties depending on the specific provision breached, including fines and potential deregistration.

These penalties underscore the seriousness with which Singapore treats corporate governance and the prevention of corporate misuse.

What This Means for Singapore Business Owners

If you are a director or shareholder of a Singapore company, the CSP Act has several practical implications:

Choose your service providers wisely. Ensure that your corporate secretary, filing agent, or nominee director provider is a Registered CSP with ACRA. You can verify this through ACRA’s public register.

Expect more thorough due diligence. When engaging a corporate service provider, be prepared for more detailed Know-Your-Customer (KYC) checks. This is not mere bureaucracy — it protects your company and Singapore’s business reputation.

Review your nominee director arrangements. If your company uses a nominee director, ensure the arrangement complies with the new fit-and-proper requirements.

Stay compliant. The CSP Act complements existing compliance requirements under the Companies Act. Maintaining good corporate governance is more important than ever.

Conclusion

The Corporate Service Providers Act 2024 marks a significant step forward in Singapore’s ongoing efforts to maintain a clean, transparent, and well-regulated business environment. By raising the bar for corporate service providers through mandatory registration, qualified individual requirements, and robust AML/CFT obligations, the Act strengthens the integrity of Singapore’s corporate ecosystem.

For business owners, the key takeaway is simple: work with reputable, registered corporate service providers who take compliance seriously. Whether you need assistance with company incorporation, ongoing filing requirements, or nominee director services, choosing a Registered CSP ensures your company is in safe hands.

If you have questions about how the CSP Act affects your business, or if you need assistance with any corporate secretarial matter, do not hesitate to contact Raffles Corporate Services for professional guidance.

— The Editorial Team, Raffles Corporate Services