New ACRA Central Registers for Nominee Directors & Shareholders: What Singapore Companies Must Do by 31 Dec 2025

Why this matters now

Singapore has introduced central registers for nominee directors and nominee shareholders to boost transparency. The rules kicked in on 16 June 2025 and add filing duties on top of your private registers. For many companies, this is a brand-new compliance step with hard deadlines.

What changed, in plain English

You must still keep your private registers of nominee directors and nominee shareholders.
In addition, you must file the same information with ACRA’s central registers.
Existing companies: file by 31 December 2025, then update within 2 business days whenever your private register changes.
New companies (incorporated on/after 16 June 2025): file the nominee details at incorporation, then keep them updated within 2 business days.

Note: These nominee registers are different from your Register of Registrable Controllers (beneficial owners). Each has its own definitions and timelines.

What counts as a “nominee”

A nominee director or nominee shareholder is someone who acts on another person’s instructions (the nominator). Companies must record both the nominee’s particulars and the nominator’s particulars in the private register and now lodge them with ACRA. Updated ACRA guidance widened/clarified certain definitions in June–July 2025.

Exact deadlines you need to track

Existing companies/foreign companies: lodge all current nominee info with ACRA’s central registers by 31 Dec 2025.
Companies incorporated on/after 16 Jun 2025: lodge nominee info at incorporation.
Ongoing changes: after you update your private register, file the change with ACRA within 2 business days.

What information must be kept and filed

ACRA’s guidance lists the particulars for nominees and their nominators (e.g., full name, ID details, residential/registered address, email and contact number, dates of nominee status). Keep the evidence that led you to record those details (e.g., emails/letters from the nominee).

Public vs non-public information

Once filed, the fact that a director or shareholder is a nominee will appear in the business profile. Full nominator details are not public; only public agencies can access them for enforcement.

Practical compliance steps (do this now)

Identify any nominee arrangements among your directors and shareholders, and obtain written confirmations.
Complete/clean your private registers with the expanded particulars (emails/contact numbers now required).
Update your Annual Return workflow to declare where the register is kept, as ACRA now expects this disclosure.
Train your directors/owners so they promptly tell you when a nominee arrangement starts, changes or ends.

Common pitfalls we’re already seeing

Treating “nominee” as just a label. ACRA’s definition matters; if instructions are given by another party, it’s likely a nominee situation.
Thinking the private register alone is enough. Central filing is now required and time-sensitive.
Missing the 2-business-day update rule after internal changes.
Mixing up nominee registers with the controllers (beneficial owners) register—they’re separate

How we help (end-to-end)

Diagnostics: we review your shareholding/director set-up to spot any nominee arrangements.
Register clean-up: update your private registers to ACRA’s latest formats (including new data fields).
BizFile lodgements: we prepare and file all initial submissions and set up change-of-particulars workflows so future updates are on time.
Policy & onboarding: templates so directors/shareholders must disclose nominee status from day one.
Ongoing company secretarial support: AR/AGM tracking, controllers register maintenance, and compliance reminders.

Conclusion: Don’t miss the 31 Dec 2025 cut-off

ACRA’s new central registers raise the compliance bar—and the filing clock is ticking. Get your nominee information complete, filed, and kept up-to-date to avoid penalties and last-minute scrambles.