Nominee Director Rules Have Changed
What Singapore Companies Must Do Now
Singapore tightened its nominee director rules through two 2025 measures: the Companies and LLPs (Miscellaneous Amendments) Act 2024, effective 16 June 2025, which introduced mandatory registers of nominee directors and shareholders (ROND and RONS); and the Corporate and Accounting Laws (Amendment) Act 2025, which added further director and corporate service provider obligations. If your company relies on a nominee director to meet the Singapore resident director requirement, the informal version of that arrangement no longer holds up, and the filing deadline has already passed.
These changes apply whether your company was incorporated last month or ten years ago. ACRA applies these rules to every nominee director arrangement, regardless of when the company was set up.
This article covers the changes, the risk of ignoring them and your next move.
What actually changed and when
Two separate pieces of legislation reshaped how nominee director Singapore arrangements work.
The Corporate Service Providers Act 2024, in force from 9 June 2025, governs how a nominee director can be appointed. The Companies and Limited Liability Partnerships (Miscellaneous Amendments) Act, in force from 16 June 2025, governs what companies must file once that appointment is in place.
Together, they close the gap that lets a director sit on paper while carrying real legal exposure underneath. Full detail sits on ACRA's Corporate Service Providers Act page, linked above.
Both changes affect any foreign owned company meeting its Singapore resident director requirement through a nominee, not only companies incorporating for the first time. If you set up your subsidiary years ago and never revisited the arrangement, the same obligations now apply to you, and to your Singapore company secretary, who will typically be the first person asked whether the company is compliant.
Informal arrangements no longer hold up
Until recently, a company could ask a friend, an employee or a contact to act as nominee director informally, with no oversight involved. That is now unlawful when done "by way of business".
Nominee director appointments must be arranged through a corporate service provider that is registered with ACRA. That provider is required to assess the nominee as fit and proper before the appointment goes ahead, and to keep records showing that assessment took place.
This closes a common shortcut. For example, a Chief Financial Officer setting up a Singapore subsidiary would sometimes ask a local contact, an accountant or an employee of the parent company to sit as director purely to satisfy the paperwork. That contact rarely understood the legal liability they were taking on, and the company rarely checked. That shortcut is gone now. The nominee director must now come through a registered corporate service provider.
This is separate from the role of a Singapore company secretary, whose duties have not changed under these amendments. The two roles are often confused, but only one of them has just been rewritten.
The new filing duty: ROND and RONS
Every company using a nominee director or nominee shareholder must now file that status with ACRA's central registers, known as ROND and RONS. Once filed, a director or shareholder is a nominee appears on the company's public Business Profile. The identity of the actual nominator, called the nominator, stays restricted to authorities only.
Existing companies had until 31 December 2025 to lodge this information. From that point onward, any change to a nominee arrangement must be filed within two business days. Full requirements are set out in ACRA's Registers of Nominee Directors and Nominee Shareholders FAQ.
The penalties
The penalties for getting a nominee director Singapore arrangement wrong scale with who is at fault.
Acting as a nominee director outside a registered corporate service provider: fine up to S$10,000.
A registered CSP that fails to properly assess a nominee as fit and proper: fine up to S$100,000.
A company that fails to file or update its ROND/RONS register: fine up to S$25,000.
Providing corporate services without CSP registration at all: fine up to S$50,000, imprisonment up to two years, or both.
That last penalty applies to the provider, not the company, but it is a fair test of whether the corporate service provider you are using is registered at all.
What to do now
If you have not filed your nominee director register, lodge immediately. Every day past the deadline adds to your exposure.
Check whether your current nominee was arranged through a registered corporate service provider, rather than an informal contact. Confirm whether your company qualifies for an exemption. Put an internal process in place so any change to your nominee director arrangement is filed within two business days, not caught later during a review.
If you want the wider compliance picture, our guides on common mistakes when setting up a company in Singapore and how not to end up in ACRA's naughty corner cover the ground either side of this update.
How CSLB is responding
From 1 September 2026, if you have engaged our services of nominee director our office will be responsible for the preparation of the unaudited financial statements at an additional cost to the client. Additionally, corporate service provider will now carry personal and financial exposure for a nominee who has not been properly assessed, so we are building that step into every engagement as standard.
If you currently use CSLB Asia for nominee director services, you will hear from us directly about how this affects your account.
Frequently asked questions
What is a nominee director Singapore?
A nominee director is someone appointed to meet Singapore's resident director requirement on behalf of another party, known as the nominator, while carrying full legal responsibility for the role themselves.
Can I still use a nominee director?
Yes, but only through a corporate service provider registered with ACRA. Informal arrangements, such as asking a friend or employee, are no longer allowed if done by way of business.
What is the deadline to file my nominee director register?
Existing companies had until 31 December 2025 to lodge nominee status with ACRA's central registers. Any changes after that must be filed within two business days.
Will my nominee director's identity be public?
The fact that a director is a nominee appears on your company's public Business Profile. The identity of the nominator is restricted to authorities.
What happens if I do not comply?
Penalties range from S$10,000 for an informal nominee arrangement to S$100,000 for a corporate service provider that fails its fit and proper assessment, with unregistered providers facing fines up to S$50,000 and up to two years in prison.
Do all foreign companies need a Singapore resident director?
Yes. Every Singapore company, including a wholly foreign owned subsidiary, must have at least one Singapore resident director. A nominee director is one way of meeting that resident director requirement without relocating an existing director.
Is a nominee director the same as a company secretary?
No. A Singapore company secretary handles statutory filings and corporate administration. A nominee director fulfils the resident director requirement and carries the same legal duties as any other director. The two are separate roles with separate obligations, and conflating them is a common, avoidable mistake.
How to check if your nominee director's CSP is registered
Before relying on anyone to act as your nominee director, verify their provider directly.
Go to bizfile.gov.sg and select the Entity tab.
Enter the provider's UEN and set "Keyword match type" to "UEN (including previous UEN)." If you only have a name, use "Name containing" instead.
If several similarly named entities appear, or the trading name does not match, cross-check the registered address against the address on the provider's own website.
Open the matching result and click "More information."
Scroll to "Corporate service provider information." A registered provider will show "CSP registration status: Registered," along with their CSP number, registration date and expiry date.
This check on Bizfile is free and requires no login.
Next Steps
Nominee director Singapore rules will keep tightening as ACRA increases oversight of corporate service providers. Staying ahead of them is cheaper than catching up.
If you’re not sure where your nominee director arrangement stands? Book a complimentary call and we will tell you exactly what you need to fix.