Singapore’s Accounting and Corporate Regulatory Authority (ACRA) has introduced sweeping regulatory changes for 2025 that significantly impact Corporate Service Providers (CSPs), registered address providers, and nominee directors. These changes signal a new era of enforcement and personal accountability in corporate governance—non-compliance is no longer an option.
Mandatory CSP Registration – No More Exceptions
Under the new framework, all entities providing corporate services must register as CSPs, even if they only offer registered address services. This includes the obligation to appoint a Registered Qualified Individual (RQI) who meets competency and fit-and-proper standards.
Failure to register or appoint an RQI is now a criminal offence, with penalties of up to S$50,000 or two years’ imprisonment, and daily fines of S$2,500 for ongoing breaches.
Nominee Directors Under the Microscope
ACRA has also tightened its grip on nominee directorships:
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Nominee directors can only be appointed through registered CSPs.
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Those holding more than 50 directorships will undergo a capacity review.
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Directors with late filings or past compliance issues may be barred from new appointments.
In short, the days of passive or “sleeping” directors are over. All directors are expected to exercise active oversight or face serious consequences.
Landmark Rulings: Jail Time Now the Norm
Recent High Court rulings have set a precedent: nominee directors who fail to supervise company activities will now face mandatory jail sentences. One such director who oversaw 384 companies without due diligence received a 10-month prison sentence after some entities were used in scam operations.
Other directors have been fined, disqualified, or jailed for offences such as:
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Failing to file annual returns or hold AGMs.
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Allowing companies to be used for money laundering.
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Relinquishing control over bank accounts to third parties.
These cases are no longer isolated; they form part of an escalating pattern of strict enforcement.
AML/CFT Compliance Expectations Have Risen
CSPs now face stricter anti-money laundering and counter-terrorism financing (AML/CFT) obligations, with:
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Fines up to S$100,000 per breach
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Requirements for stronger Customer Due Diligence (CDD)
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Enhanced risk assessments and internal controls
MAS Notice 626, while originally directed at banks, is being used as a benchmark for CSPs in shaping internal procedures and staff training.
Immediate Actions for Directors & CSPs
To navigate this new regulatory environment, consider taking the following steps:
- Register as a CSP and appoint your RQI immediately.
- Audit your nominee directorships—withdraw from inactive or high-risk appointments.
- Strengthen KYC and AML policies; use MAS 626 as a guideline.
- Protect your Singpass—never share credentials.
- Insist on indemnities and security deposits from clients.
- Purchase D&O liability insurance to guard against personal legal exposure.
- Engage directly with clients—no outsourcing of responsibility.
Final Word: Directors Are Personally Accountable
As highlighted in the Inter-Ministerial Committee Report, every Singapore company must have a resident director who is fully accountable for its actions. Claiming ignorance is not a defence. Authorities are increasingly disqualifying, prosecuting, and jailing individuals who turn a blind eye.
With over 4,700 companies prosecuted in 2023 for tax filing failures alone, the trend is clear: enforcement is real, targeted, and rising.
Stay informed. Stay compliant. Stay protected.
If you need support in meeting your compliance obligations or reviewing your nominee arrangements, feel free to reach out to us on +65 9695 4688! The time to act is now.
Check out our website at https://ebos-sg.com/ to explore more articles and discover how our Cloud Accountant Services can support you on your business.
