Singapore’s Corporate Service Provider Act: A Quiet but Significant Shift
In June 2025, Singapore’s Corporate Service Provider (CSP) Act came fully into force—without much media fanfare, but with serious implications for company formation, nominee arrangements, and transparency obligations in one of the world’s most respected corporate jurisdictions.
While the act targets a specific layer of the ecosystem—namely, the service providers who assist with company incorporation, directorships, and ongoing compliance—its ripple effects are already being felt by foreign investors, holding companies, family offices, and multinational groups using Singapore-based structures.
What the CSP Act Really Changes
The CSP Act establishes a formal licensing regime for all entities offering corporate secretarial services, including law firms, trust companies, and business consultancies. More importantly, it introduces a new layer of accountability for the individuals behind companies formed or managed through CSPs.
From now on:
- All CSPs must be registered and supervised by the Accounting and Corporate Regulatory Authority (ACRA).
- CSPs are required to perform enhanced due diligence on clients, including verifying beneficial owners, and must keep proper records.
- Where nominee directors are used, the identity of the nominator must be disclosed to ACRA—a major shift in a market that previously allowed these relationships to remain private.
For firms that rely on nominee structures to maintain discretion or support layered ownership across jurisdictions, this new disclosure obligation marks a turning point.
Why It Matters to International Clients
Many international clients—whether holding companies, investment platforms, or family offices—set up Singapore entities using local directors or nominee arrangements. These setups are not inherently suspicious; they’re often used for regulatory simplicity, residency requirements, or operational efficiency.
However, under the CSP Act, the visibility of those behind these structures has increased. Clients must now ensure their arrangements are both legitimate and well-documented, with appropriate governance frameworks in place. Attempts to obscure control, ownership, or activity are more likely to trigger regulatory scrutiny.
Bolster Group regularly supports clients in reviewing these structures to ensure that local compliance aligns with global privacy and risk management goals—particularly where cross-border interests are involved.
A Signal of What’s to Come
The CSP Act isn’t just a domestic housekeeping measure. It’s part of a broader push by Singapore to tighten anti-money laundering (AML) protections and reinforce its credibility as a transparent, well-regulated financial centre.
Coming in the wake of a major money laundering investigation in 2023, the act is designed to:
- Raise standards across the professional services sector
- Bring nominee relationships into the light
- Empower ACRA and MAS to hold service providers accountable for weak client onboarding or risk oversight
For groups accustomed to operating through offshore intermediaries or layers of SPVs, Singapore is drawing a clear line: substance, traceability, and documentation now matter more than ever. This doesn’t diminish Singapore’s role as a trusted corporate hub—but it does mean that operating here will require more rigour.
What Should Companies Be Doing Now?
Companies with existing nominee arrangements should take this opportunity to review and formalize their governance structures. If a local director has been appointed through a CSP, the client must ensure that the identity of the nominator is now on file with ACRA. Contracts, board procedures, and internal controls should be updated to reflect this change.
For new incorporations, businesses should prepare for tighter onboarding and background checks, and anticipate more direct questions from CSPs about control, ownership structure, and source of funds.
At Bolster Group, we assist clients by liaising with registered CSPs, preparing necessary documentation, and identifying where restructuring or disclosure adjustments may be required. This is especially relevant for groups managing sensitive investments, reputational risk, or family wealth across multiple jurisdictions.
Singapore remains one of the most efficient and respected jurisdictions for corporate structuring—but the rules are evolving. The CSP Act doesn’t close doors—it simply requires that they be opened with clarity, control, and purpose.
If your Singapore structure involves nominee relationships or external directors, now is the time to ensure it is aligned with the new regulatory expectations. Bolster Group can help you adapt with precision, while maintaining discretion and strategic control.