Who must register as a CSP
Business entities providing corporate services in and from Singapore by way of business must register with ACRA. Covered services include forming entities; acting or arranging for directors or nominee shareholders; transacting with ACRA for others or as a company secretary by way of business; providing registered-office or business addresses; and carrying out designated transactions for customers in connection with accounting services. Each registered CSP must have at least one Registered Qualified Individual (RQI). Registration applies to business entities, including registered sole proprietors, rather than individuals acting as authorised employees of a CSP.
Accounting services and designated activities
The accounting categories are financial accounting, internal audit, management accounting and taxation. Not every provider of these services must register. Registration is required where the entity also conducts designated activities for the same client in connection with those accounting services. Designated activities are buying or selling real estate; managing client money, securities or other assets; managing bank, savings or securities accounts; organising contributions to create, operate or manage companies; and creating, operating or managing legal persons or arrangements, or buying and selling business entities.
Public accounting entities, landlords and company groups
A public accounting entity already registered under the Accountants Act and providing only designated activities related to accounting services is treated as a registered CSP without a separate application. It must give ACRA its RQI details; if no RQI is appointed, each key appointment holder who is also a public accountant is treated as an RQI. Address-service providers must register and appoint an RQI. In contrast, a landlord renting physical premises does not need CSP registration merely because the tenant uses that address as its registered office, where the contract genuinely reflects physical occupation rather than a mailing-address service. Company groups that do not provide corporate services by way of business need not register; their group secretaries may transact for group companies.
Unregistered operations and registration fees
Operating a corporate-service business without registration can attract a fine up to S$50,000, imprisonment up to two years, or both. After conviction, a continuing offence can attract a further fine up to S$2,500 per day. The stated CSP registration or renewal fee is S$400 for two years, with no one-year option. Question 15 asks about the RQI fee, but its answer repeats the CSP fee verbatim. Consequently, this document does not reliably establish the RQI fee, and the duplicated answer should not be converted into a separate RQI price claim.
Qualification routes and key appointment holders
The ISCA associate-member route requires at least two years of associate membership. Under the CSIS membership route, applicants must be associate members or fellows. Existing RQIs can retain registration until the next renewal but must meet the revised membership conditions before renewing on those routes; other existing routes are unaffected. The corporate-secretarial-agent route remains available, requiring both a corporate-secretarial business and service as a company secretary for at least three of the five years before application. Key appointment holders include sole proprietors; partners of partnerships or LPs; company directors, chairpersons and CEOs; LLP partners and managers; and anyone principally responsible for managing the corporate-service business regardless of title.
Mandatory training and internal controls
CSP key appointment holders and qualified individuals must complete the mandatory AML/CPF/CFT course within the six months before registration or renewal application. This is intended to keep knowledge of prevailing requirements current. The Guidelines for Registered CSPs provide a sample internal-policies, procedures and controls template, but providers must adapt it to their service types, scale and operational complexity. A template does not replace a proportionate operational system.
When a nominee director needs a CSP arrangement
An individual providing nominee-director services by way of business must have the acting arranged through a registered CSP. Employees appointed as directors of their employer or a related company do not require such an arrangement. Indicators of business activity include an enterprise established to provide the service, advertising or referrals, a purpose of gain, and systematic or continuing provision. The CSP must be satisfied that the proposed director is fit and proper before arranging the appointment.
Fit-and-proper assessment and continuing responsibility
The assessment considers fraud, dishonesty or relevant convictions in Singapore or elsewhere; undischarged bankruptcy anywhere; previous conduct and companies’ compliance history, including director disqualification; and competence, capacity and capability in light of experience and commitments, including existing directorships. CSP internal policies must include assessment procedures. The requirement is not retrospective for existing appointments, although periodic refreshing is recommended, especially for directors arranged for CSP clients. The CSP’s required assessment is made when arranging the acting; after appointment, the company should ensure all directors remain fit and proper. A CSP breach of the arrangement requirements can attract up to S$100,000 per breach, while directors committing Companies Act offences face the applicable penalties.
CDD timing is risk-based, not annual-return-based
Customer due diligence is required before forming entities, acting or arranging directors or nominee shareholders, providing addresses, or conducting designated accounting-related transactions. It is also required where the CSP suspects money laundering, proliferation financing or terrorism financing, or doubts previous CDD information. Customers need regular review at a frequency based on risk. Filing an annual return is not itself the timetable that determines those checks.
Screening, source of wealth and source of funds
Screen every customer, agent, connected party and beneficial owner against relevant ML/TF/PF information, to identify designated persons under United Nations Act regulations and terrorists or terrorist entities under the Terrorism (Suppression of Financing) Act. For enhanced CDD, source of wealth generally concerns the origin of paid-up capital and how wealth was acquired, while source of funds concerns the money involved in the CSP relationship. Relevant origins may include income, previous employment, businesses or family estates. Independent reliable evidence may come from company websites, audited statements, property or land registers, asset-disclosure and company registers, past transactions, and legal or beneficial ownership information.
Live-video identification for specified remote transactions
Additional measures apply to non-face-to-face incorporation, transfers of management or ownership, and sales of shelf companies. A shelf company is an incorporated company left dormant with inactive shareholders, directors and secretary, even if a customer relationship exists. When physical identification is unavailable, conduct a live video call with at least one proposed director who is not a nominee; or at least one proposed member holding at least 50% of voting rights; or an individual authorised representative of such a member where the member is a legal person. A third-party verification platform or notarised documents cannot substitute for the live call.
Permitted third-party reliance and group-wide programmes
CDD reliance is limited to advocates and solicitors under the Legal Profession Act, Singapore financial institutions, public accountants under the Accountants Act, and the CSP’s branch, subsidiary, holding company or other related corporation. Subject to those categories, a CSP cannot engage another CSP to perform CDD. The provider remains ultimately responsible despite third-party involvement. Group-wide programmes must manage and mitigate ML/TF/PF risks and enable information sharing within the group, including among subsidiaries.
Suspicious transaction reporting and management accountability
File a suspicious transaction report promptly, as soon as reasonably practicable after suspicion is established, and no later than five business days. Reporting is required where CDD cannot be performed or completed, or reasonable grounds indicate that property may be connected with ML/TF/PF. Reports must contain sufficient information. If a legitimate explanation means no STR is warranted, document the reasons for not filing. Registered CSPs and senior management may each face fines up to S$100,000 for each breach of the relevant detection and prevention requirements.
Transition from the RFA framework
Existing Registered Filing Agents transition to CSP registration for client filing until their current RFA registration expires. Existing corporate-service businesses that are not registered RFAs must register as CSPs within six months after the CSP Act commences. These are commencement-based transition provisions; the FAQ does not itself state the commencement date, so an exact calendar deadline should not be invented from its wording.
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 ↗