Singapore’s CSP Act Enters into Force
Last updated on 3 September 2025
As of 9 June 2025, Singapore’s Corporate Service Providers Act 2024 (CSP Act) and Corporate Service Providers Regulations 2025 are officially in force. The new framework mandates that any entity providing corporate secretarial services—such as company incorporation services in Singapore, nominee director or shareholder arrangements, registered office provision, or ACRA filings—must now register as a Corporate Service Provider (CSP) with the Accounting and Corporate Regulatory Authority (ACRA).
Transition Period
Entities not already registered as Registered Filing Agents (RFAs) must complete CSP registration by 9 December 2025, providing a six-month transitional window. After this date, only registered CSPs may legally conduct corporate services, with penalties of up to S$50,000 in fines or two years’ imprisonment for non-compliance or both.
Key Company, Foreign Company and LLP Obligations
From mid-June 2025, all newly incorporated companies, foreign companies and limited liability partnerships (LLPs) must:
- Maintain a Register of Controllers (RORC) from the date of incorporation and lodge updates in ACRA’s Central Registers within prescribed timelines.
- File details of the Register of Registrable Controllers (RORC) immediately upon incorporation.
- Create and maintain registers for Nominee Directors (ROND) and Nominee Shareholders (RONS) and file these with ACRA, disclosing nominee status and information on the particulars of nominators. The nominee status of directors and shareholders will be publicly available and will appear in the business profile of the relevant companies.
- Entities incorporated on or after 16 June 2025 must file immediately, while existing entities must submit these registers by 31 December 2025.
- Information on the particulars of the controllers and nominators in ACRA’s Central Registers will only be accessible to law enforcement agencies.
Obligations Of Registered Corporate Service Providers
Registered Corporate Service Providers (CSPs) must comply with strengthened requirements covering Anti-Money Laundering (AML), Countering the Financing of Terrorism (CFT), and Proliferation Financing (PF). These obligations include:
- Performing risk assessments using Singapore’s Proliferation Financing (PF) National Risk Assessment and implementing controls to mitigate exposure.
- Monitoring United Nations (UN) sanctions lists, subscribing to updates from the Monetary Authority of Singapore (MAS), and avoiding any dealings with UN-designated individuals or entities under applicable Singapore laws.
- Establishing and maintaining robust compliance frameworks, including regular audits, internal reporting procedures, and staff training, in line with ACRA’s Guidelines for CSPs issued on 9 May 2025.
- Non-compliance with these AML, CFT, and PF requirements can result in fines of up to S$100,000 per breach, including penalties applicable to senior management.
| Status of Parties to the Loan | TP Treatment | TPD Requirement | |
|---|---|---|---|
| Domestic Loan entered into before 1 January 2025 | Lender not in the business of borrowing and lending | Interest free loans permitted, subject to interest deduction restriction on the lender | Exempt from TPD |
| Lender in the business of borrowing and lending | • arm’s length interest rate; or • the indicative margin may be applied, provided that the principal value of the loan does not exceed the threshold of SGD 15 million — except in the case of domestic loans where both the lender and borrower are not in the business of borrowing and lending, in which case no threshold applies. | Exempt from TPD if the indicative margin is applied. Otherwise, TPD is required to substantiate the arm’s length interest rate. | |
| Domestic Loan entered into on or after 1 January 2025 | Lender and borrower are both not in the business of borrowing and lending | ||
| Either lender or borrower (or both) is in the business of borrowing and lending | |||
| Cross Border Loan | Whether or not the lender or borrower is in the business of borrowing and lending |
Key deadlines
| Deadline | Who It Applies To | What Must Be Done | What Happens If Missed |
|---|---|---|---|
| 9 June 2025 | All entities providing corporate services in Singapore (including those not currently RFAs) | CSP Act and Regulations come into effect. Entities providing corporate services must start complying with CSP registration, fit-and-proper requirements, and reporting duties. | Non-compliance can lead to prohibition from providing corporate services and penalties for continuing operations unlawfully. |
| 16 June 2025 | Companies, LLPs, and foreign entities incorporated on or after this date | Must maintain a RORC from incorporation and immediately file details for RORC, ROND, and RONS with ACRA. | Non-compliance may result in regulatory enforcement, including fines and additional compliance reviews before operations can proceed. |
| 9 December 2025 | Entities providing corporate services but not currently Registered Filing Agents (RFAs) | Must register with ACRA as CSPs by this date to continue operating legally. | Operating as a CSP without registration after this date can lead to fines of up to S$50,000 or two years’ imprisonmentor both. |
| 31 December 2025 | Existing companies, foreign companies and LLPs incorporated before 16 June 2025 | Must update and file their RORC, ROND, and RONS with ACRA by this deadline to align with the new filing regime. | Entities that fail to file by the deadline face enforcement actions and penalties, including fines and potential prosecution. |
In the months ahead, companies, foreign companies and LLPs must ensure that they update their registers, comply with filing timelines, and engage only with ACRA-registered CSPs. With the CSP Act now in effect, transparency, regulatory compliance, and robust risk controls are not optional—they are essential for operating in Singapore’s tightening corporate governance landscape.
