Crucial Update: Singapore CSP Regulations 2025 and What You Must Do Now

June 9, 2025

Singapore’s Corporate Service Providers (CSP) Act 2024 was passed by Parliament on 2 July 2024, and the Singapore CSP Regulations 2025 will come into effect on 9 June 2025, marking a significant step in strengthening the nation’s anti-money laundering, countering proliferation financing and countering the financing of terrorism (AML/CPF/CFT) framework. The Accounting and Corporate Regulatory Authority (ACRA) has released the AML/CFT Guidelines for Registered Corporate Service Providers (CSP Guidelines) to guide compliance with these new requirements.

The Singapore CSP Regulations 2025 establish the compliance framework for AML and corporate governance. For Corporate Service Providers (CSP) in Singapore, these changes underscore the need for robust compliance measures to meet heightened regulatory expectations and maintain Singapore’s reputation as a trusted global financial hub.

This article outlines the top 3 things you need to know about the CSP Guidelines, and offers practical steps for CSP to prepare.

1. Mandatory Registration as Corporate Service Providers (CSP) with ACRA

All business entities providing corporate services in or from Singapore must register with ACRA as registered CSP, regardless of whether they file transactions with ACRA, and have at least one registered qualified individual (RQI).

Entities offering the following services are required to register as CSP:

Business entities formation;
Acting as or arranging nominee directors or shareholders;
Transacting with ACRA on behalf of other persons or as a secretary of a company by way of business;
Providing registered office addresses or a business address; or
Carrying out transactions for customers for any of the designated activities relating to the provision of accounting services (refer to the details below).

Designated Activities and Accounting Services: If a business entity provides any of the following designated activities while providing accounting services (e.g. financial accounting, internal audit, management accounting service or taxation service) to the same customer, then the business entity needs to be a registered CSP:

buying or selling of real estate;
management of client monies, securities or other assets;
management of bank, savings or securities account;
organisation of contributions for the creation, operation or management of companies;
creation, operation, or management of legal persons or arrangements, or buying and selling of business entities.

Transition Period The existing registered filing agent (RFA) would transition to CSP and be granted registration as a CSP to perform filing for their clients, until the expiry date of their current RFA registration. Non-registered RFAs must register with ACRA as CSP within six months of the Singapore CSP Regulations 2025 commencement on 9 June 2025.

2. Nominee Director and Shareholder Requirements

The Singapore CSP Regulations 2025 also address the issue of nominee directors, individuals who act as directors on behalf of others. Under the new regulations, persons are prohibited from acting as nominee directors by way of business unless their appointments are organised by a registered CSP. This targets predominantly ‘freelance’ nominee directors who now must ‘register’ themselves with a CSP. Additionally, these CSP must assess the nominee directors as fit and proper for their roles. This ensures that only qualified individuals serve as nominee directors, reducing the risk of misuse and enhancing corporate governance.

Determine Whether the Person is Fit and Proper

CSP should assess whether a person is fit and proper at the time of arrangement based on their criminal record, bankruptcy status, conduct history, competency and capacity, etc, and periodically refresh the assessment to ensure that the directors remain fit and proper after the appointment. Another significant aspect of the new CSP Regulations is the requirement for nominee directors and nominee shareholders to disclose their nominee status and the identities of their nominators to ACRA. This increased transparency is intended to prevent the concealment of true ownership and control, thereby enhancing the integrity of corporate structures in Singapore.

3. AML/CPF/CFT Obligations Under Singapore CSP Regulations 2025

CSP obligations under Part 4 of the  Singapore CSP Regulations 2025 and the CSP Guidelines are largely similar to the old registered filing agent regime. Key differences in AML/CPF/CFT obligations between the CSP Guidelines and the previous AML/CFT Guidelines for Registered Filing Agents Guidelines (RFA Guidelines) are summarised below:

Obligations	RFA Guidelines (Old)	CSP Guidelines
Risk Assessment	Required.	Required.
Customer Due Diligence (CDD) Measures	Required.	Required.
Customer screening	Required.	Required.
Remote Transactions	–	Required. New! See below section 3a.
Record Keeping	Required.	Required.
Ongoing Monitoring	Required.	Required.
Internal policies, procedures and controls	Required.	Required. New! Internal policies, procedures and controls in respect to access to ACRA electronic transaction system (Refer to 3b section below)
Audit and compliance management	Required.	Required.
Hiring and training of employees	Required.	Required.
Provision of information	–	New! (Refer to 3c section below)
Reporting of suspicious transaction	Required. Suspicious Transaction Report (STR) should be lodged no later than 15 business days.	Required. New! STR should be lodged no later than 5 business days. For higher risk cases, STR are to be filed within 1 business day.

3a. New! Remote Transactions

For customers not physically present for identification, CSP must implement additional measures to mitigate higher risks, including obtaining additional documents, and conducting and maintaining records of live video calls with:

at least one proposed director (who is not a nominee);
member with at least 50% voting rights; or
an authorized representative of a proposed member (for legal person),

to verify customer’s identity.  When conducting a live video call for remote transaction, at the minimum, the CSP should take and retain a screenshot of the video call.

All proposed directors must consent to act as a director and they must sign Form 45: Consent to Act as Director and Statement of Non-Disqualification to Act.

3b. New! Internal Policies, Procedures and Controls in Respect to Access to ACRA Electronic Transaction System

In addition to maintaining an effective internal policies, procedures and controls (IPPC) for preventing ML/PF/TF, registered CSP must put in place effective IPPC to ensure that only authorized employees or registered QIs engaged or appointed by the registered CSP are allowed to access the electronic transaction system. In addition, the IPPC must ensure that the transaction with ACRA on the electronic transaction system relates to a customer of the registered CSP and is authorized by that customer.

3c. New! Provision of Information

Under the CSP Guidelines, the registered CSP must maintain information regarding its customers and transactions with ACRA.

Information on customers:

The total number of customers for which corporate services were provided;
A list of the nationalities of the customers;
A list of the places of residency of the customers who are individuals;
A list of the places of incorporation or formation of the customers that are not individuals.

Information on transactions with ACRA as of 1 Jan of each year:

The total number of ACRA transactions;
The type of ACRA transactions;
The total number of ACRA transactions carried for persons who are not citizens or permanent residents of Singapore;
The total number of company incorporations, and registrations of businesses, limited liability partnerships and limited partnerships, carried out for persons who are not citizens or permanent residents of Singapore;
The total number of ACRA transactions carried out for PEPs and customers from or in relevant countries or are high risk.
The total number of company incorporations, and registrations for businesses, limited liability partnerships and limited partnerships, carried out for PEPs and customers from or in relevant countries or are high risk.

How Corporate Service Providers (CSP) Can Prepare for the Corporate Service Providers Regulation Effective from 9 June 2025

To align with the Singapore CSP Regulations 2025, businesses must take proactive steps to prepare for the impending legislation of the CSP Bill to ensure compliance and mitigate potential risks.

Step 1—Register with ACRA

If your entity provides corporate services, ensure it is registered with ACRA as a CSP before the deadline. Review ACRA’s Bizfile portal for registration procedures and requirements.

Step 2—Conduct a Compliance Gap Analysis

CSP should perform a comprehensive review of their current practices and policies to identify gaps related to registration, AML/CPF/CFT, and compliance with the Singapore CSP Regulations 2025. Internal policies, procedures, and controls should be updated accordingly to address any identified deficiencies.

Step 3—Strengthen Nominee Arrangements

CSP should review nominee director and shareholder arrangements to ensure compliance with fit-and-proper assessments and disclosure requirements, as well as update registers and file the necessary information with ACRA accordingly.

Step 4—Invest in Staff Training

It is also important to develop training programs for staff to enhance awareness of the new requirements and instil a culture of compliance within the organization.

Step 5—Leverage Technology Solutions

CSP are advised to adopt advanced AML/CPF/CFT software to streamline screening, CDD, ongoing monitoring, and risk assessment and mitigation — key obligations under the Singapore CSP Regulations 2025. By taking these proactive measures, CSP can better position themselves to navigate the complexities of the regulatory requirements and foster trust with clients and regulators alike.

Conclusion on the New Singapore CSP Regulations 2025

The Singapore CSP Regulations 2025 mark a significant step forward in Singapore’s efforts to bolster corporate governance and compliance. By mandating registration, enforcing AML/CPF/CFT obligations, regulating nominee directors, enhancing disclosure requirements, and increasing fines, the legislation aims to create a more transparent and accountable corporate environment. These changes not only protect the integrity of the financial system but also reinforce Singapore’s reputation as a premier destination for international business.

The Singapore CSP Regulations 2025 reinforce the city-state’s commitment to corporate transparency. As the implementation of the CSP Bill progresses, it will be crucial for CSPs and businesses to stay informed and compliant with the new regulations. In doing so, they will contribute to a safer, more transparent, and reputable corporate landscape in Singapore.

Stay informed with more updates via our News & Insights section.

References

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