Version and three distinct registers
Version 2.0 was issued on 16 June 2025 under Part 11A of the Companies Act 1967 and the 2017 register regulations, reflecting amendments commencing that day. A register of nominee directors is separate from nominee shareholder and registrable controller registers. A person can belong to any, all or none of these categories; nominee status alone does not establish registrable control. The company register obligations began on 31 March 2017, while central nominee director registration began on 16 June 2025.
Which companies are exempt
Exemptions cover SGX-listed public companies, Singapore financial institutions as defined in the Fourteenth Schedule, companies wholly owned by Singapore’s Government or a statutory body established under a Singapore public Act for a public purpose, wholly owned subsidiaries of those four categories, and overseas-listed companies subject to both regulatory disclosure and adequate beneficial-owner transparency requirements. Comparable substantial-shareholder disclosure can meet the overseas-listing condition. Section 5B governs wholly owned subsidiary status, including specified nominee and subsidiary holdings. Winding up, receivership, judicial management or striking off does not itself create an exemption.
Nominee status and directors’ duties
A director is a nominee when accustomed or formally or informally obliged to follow another person’s directions, instructions or wishes. The arrangement may arise under contract, trust or an informal understanding. A shareholder-appointed director who follows that shareholder’s wishes is an example; an ordinarily resident director appointed to meet the local-residence requirement would generally also qualify. Nominees must disclose their status and their nominators’ particulars, cessation and changes. Company register exemptions do not remove the director’s information duty: an exempt financial institution nominating a director to a non-exempt company must still be identified in that company’s register.
Disclosure deadlines depend on incorporation date
For companies incorporated from 31 March 2017 to before 16 June 2025, a director who is a nominee at incorporation must notify and supply particulars within 30 days after incorporation; becoming a nominee later starts a 30-day period from that event. For companies incorporated on or after 16 June 2025, an existing nominee must provide the information on incorporation day; a later nominee still has 30 days. For companies incorporated before 31 March 2017, the guidance specifies 30 days where the director becomes a nominee after that date. Cessation of nominee status and changes to previously supplied particulars must each be notified within 30 days of the event.
Individual and legal-entity nominators
For an individual, record full name, aliases, residential address, email, contact number, nationality, identity-card or passport number, date of birth and the date the director became that person’s nominee. For a legal entity, record name, ACRA UEN if any, registered-office address, email, contact number, legal form, formation jurisdiction and statute, applicable corporate register name and registration/identification number, and the nominee commencement date. Legal form means the entity type, such as private company; statute means the legislation under which it was formed. ACRA and UK Companies House illustrate register names. Commencement and cessation dates are actual event dates on or after 31 March 2017, not simply the date of entry.
Seven-day updating, location and custody
Enter information and updates received from nominee directors within seven days, and document when they were received. Keep the register at the company’s registered office or the registered office of an appointed registered corporate service provider. State where it is kept in the annual return; the guidance separately says companies need not lodge, notify or update ACRA with the address of that location. A resigning service provider should hand the register back to the company, which may appoint a replacement. Electronic or paper records are permitted, provided the prescribed Seventh Schedule form is met; formatting can differ from Annex A.
No information received and restricted inspection
A company that has received no nominee-director information may record a dated statement to that effect. The private register and its particulars must not be disclosed to or inspected by the public, including company members; auditors have no entitlement to access. In contrast, the Registrar, ACRA officers and public agencies or their officers can require the register, related records and supporting documents, inspect them and make copies. Examples include the Police, Commercial Affairs Department, CPIB and IRAS. Companies must cooperate with those requests.
Documents supporting accurate particulars
The guidance gives NRIC copies for Singapore citizen or PR nominators; passport and residential-address evidence such as a utility bill for foreign individuals; and a foreign entity’s registration certificate plus address evidence if its registered office is not shown on the certificate. Retain emails or letters through which nominee directors supplied the information entered in the register. These examples support the accuracy and updating of the register and must be furnished when requested by the authorised agencies.
Central filing and public nominee status
The June 2025 guidance requires existing companies to file all private-register information with ACRA by 31 December 2025. Companies incorporated on or after 16 June 2025 must file nominee director and nominator information at incorporation. Thereafter, updates must be filed within two business days after the company enters or updates the private register. The director’s nominee status becomes publicly available, including in business profiles, but complete information in ACRA’s central register is accessible only to public agencies administering or enforcing written law. These are the transition dates stated in this version of the guidance.
How Annex A records changes
The template separates date of entry, nominee director’s name, nominator particulars and remarks. It illustrates individual and foreign corporate nominators, cessation and a corporate address change with both new particulars and the change date. Thus an entry date, the relationship’s commencement/cessation date and a particulars-change date represent different events. Some printed cessation examples place a 2017 entry beside a 2025 or 2026 cessation date; those inconsistent sample dates should not be treated as a filing timeline. Use actual event dates and the operative deadlines above.
Official source
This article independently explains the substantive contents of the official PDF, including the relevant conditions, procedures and annexes. The linked document remains the authoritative source for its original wording, and later changes should be checked separately.
Read the official PDF ↗