Singapore’s corporate service provider (CSP) sector faces substantial regulatory changes with the implementation of the Corporate Service Providers Act 2024 (CSP Act) and the related Corporate Service Providers Regulations 2025 (CSP Regulations). This regulatory development, overseen by the Accounting and Corporate Regulatory Authority (ACRA), reinforces Singapore’s dedication to preventing financial crimes, including money laundering, terrorism financing, and proliferation financing for weapons of mass destruction.
Scope of the CSP Act
The introduction of the CSP Act 2024 and CSP Regulations 2025 represents an important step in strengthening Singapore’s position as a reputable and secure financial center. This legislation will address existing compliance gaps, raise professional standards across the industry, and ensure Singapore’s framework aligns with global best practices.
Source: ACRA Announcement – News Detail (June 2024)
Who Must Comply with the CSP Act?
The CSP Act defines a “corporate service” to include:
- Forming corporations or legal entities for clients,
- Acting, or arranging for another person to act, as directors, secretaries, or partners, professionally
- Providing registered office or business addresses
- Performing specific accounting services such as managing client money, securities, and real estate transactions.
Any business providing these services in Singapore or from Singapore falls under the CSP Act and is classified as a Corporate Service Provider. This broad definition captures all entities engaged in corporate service activities, regardless of their primary business focus.
Also Read: Setting Up a Subsidiary in Singapore: A Step-by-Step Guide
Key Changes and Compliance Obligations for Corporate Service Providers (CSPs)
Mandatory ACRA Registration for All CSPs
From 9 June 2025, all business entities providing corporate services in or from Singapore must register with ACRA as a registered CSP under Section 7 of the CSP Act 2024. This requirement applies regardless of whether they file transactions with ACRA on behalf of their clients.
- The Act significantly expands the regulatory scope beyond the previous framework. While only Registered Filing Agents (RFAs) were previously regulated, the new legislation now requires registration for all entities that provide corporate services commercially.
- Each registered CSP must designate at least one Registered Qualified Individual (RQI) who possesses relevant qualifications and has completed mandatory AML/CFT/PF training as specified in Section 9 of the CSP Act 2024.
- Entities not currently registered as RFAs have until 9 December 2025 to complete their registration during the six-month transition period. Non-compliance constitutes a serious offence under Section 7(4) of the CSP Act 2024, with penalties including fines up to S$50,000 and imprisonment for up to two years.
Enhanced AML/CFT/PF Obligations
All registered CSPs must comply with comprehensive AML/CFT/PF obligations that exceed previous requirements.
CSPs must conduct thorough Customer Due Diligence (CDD) before providing services, which includes identifying and verifying customer identity, beneficial owners, and the purpose of business relationships. Section 20 of the CSP Regulations 2025 requires ongoing monitoring and updated client documentation throughout the relationship.
Regular risk assessments are mandatory under Section 19 of the CSP Regulations 2025. CSPs must evaluate risks associated with their customers, operating countries, products, services, and transactions to identify and address potential money laundering, terrorism financing, and proliferation financing threats.
Section 33 of the CSP Regulations 2025 mandates that registered CSPs develop, implement, and maintain adequate internal policies, procedures, and controls to prevent financial crime. These requirements encompass comprehensive record-keeping systems, staff training programs, and independent audit functions.
CSPs must file Suspicious Transaction Reports (STR) promptly when they suspect any property or transaction may be connected to money laundering, terrorism financing, or proliferation financing activities.
Also Read: Tax Strategies for Businesses in Singapore
Stricter Nominee Director and Shareholder Requirements
The new legislation introduces heightened oversight and transparency for nominee arrangements.
Only ACRA-registered CSPs may arrange for persons to act as nominee directors commercially. Before any appointment, the CSP must conduct a thorough assessment to confirm that the proposed nominee director meets “fit and proper” standards. CSPs that fail to complete this assessment face fines up to S$100,000 under Section 15 of the CSP Act 2024.
The CSP Act increases transparency through mandatory disclosure requirements. Nominee directors and nominee shareholders must disclose their nominee status to ACRA and identify their nominators as specified in Section 20 of the CSP Regulations 2025. These disclosure requirements prevent the concealment of true ownership and control structures, thereby strengthening corporate governance standards.
Increased Penalties for Non-Compliance
The CSP Act establishes substantially higher penalties for violations.
- Failure to Register as a CSP: Operating a corporate services business in Singapore without proper CSP registration constitutes an offence. Convicted parties face fines up to S$50,000, imprisonment up to two years, or both. Continuing offences incur additional daily fines up to S$2,500 after conviction.
- Breaches of AML/CFT/PF Obligations: Penalties for non-compliance with anti-money laundering, counter-terrorism financing, and proliferation financing obligations have increased substantially. Registered CSPs face fines up to S$100,000 for each breach. Senior management failing to ensure compliance also faces fines up to S$100,000 per breach. ACRA may impose additional regulatory sanctions, including suspension or cancellation of CSP registration in severe cases.
- Nominee Director Violations: Individuals acting as nominee directors commercially without arrangements through a registered CSP face fines up to S$10,000. Registered CSPs that arrange nominee directors without conducting proper “fit and proper” assessments face fines up to S$100,000.
- Register Maintenance Offences: Companies must maintain accurate registers of registrable controllers, nominee directors, and nominee shareholders. Maximum fines for non-compliance have increased from S$5,000 to S$25,000.
- False Information Provision: Providing false or misleading information to the Registrar constitutes an offence punishable by fines up to S$25,000.
Reference: Singapore Statutes Online – CSP Act 2024 (Uncommenced)
Impact on Businesses Using Corporate Service Providers (CSPs)
Businesses engaging corporate secretarial services or other corporate services will experience enhanced due diligence requirements from their CSPs.
Rigorous Customer Due Diligence from Your CSP
Your CSP must now collect more detailed information about your business, beneficial owners, and nominee arrangements to comply with new regulations. You will need to provide extensive documentation regarding beneficial ownership and nominator details to meet ACRA’s disclosure requirements.
Your CSP will conduct more thorough vetting and ongoing monitoring to fulfill their expanded AML/CFT/PF obligations, which may involve additional questions and requests for updated information.
Verifying Your CSP’s Registration and Compliance
You must verify that any corporate service provider you engage is ACRA-registered and compliant with the CSP Act 2024 and CSP Regulations 2025.
While the primary compliance responsibility lies with the CSP, confirming your service provider’s legitimacy and regulatory adherence protects your company’s standing.
Working with a non-compliant CSP could expose your business to risks, including reputational damage and complications with regulatory filings.
Also Read: Singapore Offshore Company Formation Guide 2025
Why the CSP Act Matters for Singapore’s Business Ecosystem
The introduction of the CSP Act 2024 aligns with Singapore’s global reputation as a clean and credible financial hub. The legislation aims to:
- Prevent shell company misuse
- Boost international investor confidence
- Align with Financial Action Task Force (FATF) standards
- Strengthen ACRA’s ability to act against rogue providers
Ultimately, the Act raises the bar for professionalism in the corporate services industry and reinforces Singapore’s commitment to transparency and governance.
Working with HC Consultancy – ACRA-registered CSP
With over 20 years of experience, HC Consultancy is an ACRA-registered corporate service provider in Singapore. We are a full-fledged consulting firm specializing in corporate secretarial services, accounting, tax advisory, immigration services, work pass applications, litigation support, legal advisory, and dispute resolution. Our integrated approach provides both operational and legal support for businesses setting up their operations in Singapore, ensuring full compliance with the CSP Act requirements.
