Nominee director requirements under the CSP Act 2024 (2026)
The fit-and-proper assessment, ACRA disclosure and offences that now govern nominee directors in Singapore — what CSPs and nominees must do.
What are the nominee director rules under the CSP Act 2024?
The Corporate Service Providers Act 2024 tightened the rules around nominee directors — people who sit on a board on behalf of someone else. A registered CSP must not arrange for a person to act as a nominee director unless it is satisfied that person is fit and proper, and nominee arrangements must be transparent to ACRA.
The aim is to stop nominee arrangements being used to hide who really controls a Singapore company, while keeping the legitimate use of nominees available through accountable CSPs.
What is a fit-and-proper assessment for a nominee director?
Before arranging a nominee director, a CSP must take reasonable steps to assess that the person is fit and proper — looking at their conduct, competence, capacity and commercial integrity. In practice this means:
- Confirming the person is not disqualified from acting as a director under any law.
- Reviewing their compliance record and past conduct in companies where they previously served.
- Assessing whether they have the competency, capacity and capability to properly discharge a director’s duties.
- Considering their existing commitments, including how many other directorships they already hold.
Does nominee director status have to be disclosed to ACRA?
Yes. Nominee directors’ and nominee shareholders’ status, together with the identity of their nominators, must be disclosed and filed with ACRA. The fact that a director is a nominee is made publicly available on the register.
The full identity of the nominator is not public — it is maintained by ACRA and accessible only to public authorities for administering or enforcing the law. So transparency of nominee status is public, while the nominator’s details are protected but visible to regulators.
Can someone act as a nominee director without a CSP?
No — not by way of business. A person who acts as a nominee director by way of business without their appointment being arranged by a registered CSP commits an offence. This channels nominee arrangements through accountable, registered providers who have run the fit-and-proper checks.
What are the penalties around nominee directors?
The penalties fall on both sides of a non-compliant arrangement. The individual-side figure below is commonly cited by law-firm briefings; confirm the exact amount against the CSP Act as enacted before relying on it.
| Who | Failure | Maximum penalty |
|---|---|---|
| CSP | Arranging a nominee director without ensuring they are fit and proper | Fine up to S$100,000 |
| Individual | Acting as a nominee director by way of business without a registered CSP | Fine up to S$10,000 (commonly cited — confirm with ACRA) |
What should a CSP do before arranging a nominee director?
A CSP should build a repeatable process: run the fit-and-proper assessment, document the evidence, confirm the person is not disqualified, capture the nominator’s identity for ACRA disclosure, and retain the records. Because the fit-and-proper failure alone can cost up to S$100,000, this is not a step to improvise.
For the wider framework these rules sit within, see the CSP Act 2024 pillar guide and the AML/CFT obligations.
Frequently asked questions
Can a CSP arrange any nominee director?
No. A CSP must not arrange for a person to act as a nominee director unless it is satisfied, after a reasonable assessment, that the person is fit and proper.
Is nominee director status public in Singapore?
The fact that a director is a nominee is made publicly available. The nominator’s full identity is not public — it is held by ACRA and accessible only to public authorities.
What is the penalty for a CSP that fails to assess a nominee director?
A CSP that arranges a nominee director without ensuring they are fit and proper can be fined up to S$100,000.
Can I act as a nominee director without going through a CSP?
Not by way of business. Acting as a nominee director by way of business without being arranged by a registered CSP is an offence.
Sources
This article is general information for Singapore corporate service providers, not legal or professional advice. Verify against the primary sources above and your own professional judgement.