What Actually Changed on 9 June 2025: From RFA Registration to Service-Based CSP Registration
Before 9 June 2025, Registered Filing Agents (RFAs) were registered under section 31 of the old Accounting and Corporate Regulatory Authority Act.
The Corporate Service Providers Act 2024 (Act 22 of 2024), together with the Corporate Service Providers Regulations 2025, replaced that framework on 9 June 2025 with something considerably broader. Registration now attaches to whether a firm provides a "corporate service" by way of business, not whether it files anything (with limited exceptions, including deemed registration for some accounting entities and Minister-ordered exemptions). That's a wider net: it catches registered-office providers, standalone corporate secretarial firms, and nominee-director arrangers who never touched ACRA's filing system.
We think that's the real story here, more than the deadline framing most coverage leads with: a specific population of firms fell under CSP registration for the first time.
Where the fuller picture already exists
CSIS, the profession's own body, ran its 9th Corporate Service Providers Conference on 10 July 2024. ACRA's Chief Executive gave the opening address to more than 540 CSP representatives, and senior ACRA officers used the day to walk attendees through the incoming CSP Bill and the new Bizfile portal directly — confirmed in ACRA's own account of the conference. If you weren't there, or don't have a colleague who was, that's the most complete account of this transition outside the statute itself.
The transition window and the numbers
Firms already registered as RFAs were automatically treated as registered CSPs — but only for the ACRA-filing service itself, and only until their old RFA registration expired. A firm that also provided registered-office, nominee-director, or other corporate-secretarial work on the side had no automatic cover for that work; it's exactly the kind of firm this piece is written for. ACRA's own step-by-step guide confirms as much: even an automatically-converted RFA still has to separately tell ACRA which corporate services it actually provides.
Firms that weren't already required to be registered filing agents, but were already providing a corporate service before the section 7 commencement date, had a separate six-month window to register for it. A firm that applied within that window can keep operating lawfully under section 42(2)(b) until registration is granted, or the application is finally refused — including after any appeal — or withdrawn. A firm that started providing a corporate service only after that date had no window at all; it needed to be registered from day one.
If your firm falls into one of the newly-covered categories, never registered, and never applied within that window, the exposure is real: a fine of up to S$50,000, up to two years' imprisonment, or both, plus up to S$2,500 for each day the offence continues after conviction. Separately, a registered CSP that arranges a nominee director without being satisfied they're fit and proper — a duty that applies only to a CSP registered for that specific service, and includes taking reasonable steps to check they aren't disqualified and weighing the factors set out in the Regulations — faces a fine of up to S$100,000 under section 16(3). The Act goes further still: under a new Companies Act section 145A, a person who acts as a nominee director by way of business must themselves be a registered CSP, or have that role arranged by one — with two exceptions: someone acting as nominee director of their own employer or a related company, and a nominee director who was already acting for that company before 9 June 2025. Breach carries a fine of up to S$10,000, plus up to S$1,000 for each day a continuing offence carries on after conviction. Part 11A of the Companies Act separately carries fines of up to S$25,000 for failing to comply with duties around the register of controllers or nominee arrangements — keeping the register, sending required notices, updating particulars — under provisions amended by a separate 2024 Act, in force from 16 June 2025; we haven't confirmed what the fine was before that amendment.
If you're not sure where your firm stands
CSIS is the first place to ask a person. If you'd rather check yourself: ACRA's own step-by-step guide to checking if you must register walks through the six services, and Bizfile's entity search lets you check whether a specific firm is actually registered, free. We'll keep this page updated as ACRA issues further guidance — the six-month transition window is closed, but the interpretation questions around it aren't.