Nominee Directors in Singapore: The Crackdown, New Rules, and How to Stay Compliant
Last Updated: June 2026
Nominee directors are still legal in Singapore, but the rules around them tightened sharply between 2024 and 2026. A nominee director is a director accustomed or under an obligation to act on another person’s instructions, and that role is now wrapped in a far stricter compliance regime than it was a few years ago.
The biggest shift: the Corporate Service Providers Act 2024 came into force on 9 June 2025. From that date, a nominee director provided by way of business must be arranged through a registered corporate service provider (CSP) and assessed as fit and proper. The casual handshake arrangement is gone. A compliant 2026 setup runs through a licensed CSP and is properly recorded.
Key Takeaways
- Nominee directors remain legal in Singapore as long as the arrangement is compliant with the current rules.
- The Corporate Service Providers Act 2024 took effect on 9 June 2025 and reshaped how nominee directors may be supplied.
- A nominee director provided by way of business must now be arranged through a registered CSP and assessed as fit and proper.
- The company must keep a Register of Nominee Directors (ROND) and a Register of Nominee Shareholders (RONS) and lodge the particulars with ACRA.
- A nominee must inform the company of their nominee status and who they act for, so the register is accurate.
- A nominee director still carries the full statutory and fiduciary duties of any director, so the personal liability does not disappear.
What Are the New Rules for Nominee Directors in Singapore?
The new rules do not ban nominee directors. They govern who may supply one, how the person is vetted, and how the arrangement is recorded. The aim is transparency: regulators want to know who is really behind a company, even when a named director is acting on someone else’s instructions.
In short, three things now apply. First, a nominee director supplied as a business service must come through a registered CSP. Second, the nominee and the CSP must meet a fit-and-proper standard. Third, the company must disclose the nominee in a register and lodge those details with ACRA. The basic appointment mechanics for any director still apply on top of this, and the ACRA guidance on appointing directors and key officers sets out the underlying requirements.
If you are weighing whether you even need a nominee, our overview of nominee director services for foreign entrepreneurs explains where the role fits, and the wider picture of opening a business in Singapore as a foreigner covers the local-director requirement that drives most nominee arrangements.
Must a Nominee Director Now Be Appointed Through a CSP?
Yes. Since 9 June 2025, a nominee director provided by way of business must be arranged through a registered corporate service provider. “By way of business” is the key phrase: it captures the firms and individuals that supply nominee directors commercially, which is how almost every legitimate nominee arrangement is set up in practice.
The practical effect is that you can no longer rely on an unlicensed intermediary or an informal contact to put a name on your board. The CSP must be registered, and the individual proposed as nominee must be assessed as fit and proper before the appointment. This protects the company too, because a vetted provider is accountable to the regulator and has to keep proper records. Before you sign, our note on what to check before engaging a CSP lists the questions worth asking.
What Changed Under the Corporate Service Providers Act?
The Corporate Service Providers Act 2024 created a licensing regime for the firms that register companies, act as filing agents, and supply nominee directors and shareholders. Passed in 2024 and in force from 9 June 2025, it moved corporate service provision from a lightly governed activity into a registered, supervised one.
Three changes matter most for nominee arrangements:
- CSPs must be registered with ACRA to provide corporate services by way of business, including supplying nominee directors.
- A person supplied as a nominee director by way of business must be assessed as fit and proper, so unsuitable individuals are filtered out.
- CSPs face stronger anti-money-laundering and customer-due-diligence duties, which means more verification of who is really behind a company.
This sits within the broader Companies Act framework, and the Companies Act 1967 remains the source of the director duties that apply regardless of the nominee label. For the licensing detail and how it changes the CSP relationship, see our guide to the new CSP Act and what clients should check.
What Is the Register of Nominee Directors (ROND) Obligation?
Companies must maintain a Register of Nominee Directors (ROND), and a matching Register of Nominee Shareholders (RONS), and lodge the particulars with ACRA’s central register. The register records who the nominee is and who they act for, so the people pulling the strings are identifiable to the authorities.
The obligation has two sides. The nominee must inform the company of their nominee status and identify their nominator. The company must then record those particulars and lodge them with ACRA. The ACRA guidance on the Registers of Nominee Directors and Shareholders sets out exactly what must be captured and kept up to date.
This is a continuing duty, not a one-off form. If a nominator changes or a nominee steps in or out, the register must be updated. For the mechanics and the lodgment deadlines, our walkthrough of the new ACRA central registers and what companies must do covers the steps, and a good corporate secretarial service usually maintains these registers for you.
What Does a Compliant Nominee Arrangement Look Like in 2026?
A compliant arrangement in 2026 is documented, registered, and supervised from end to end. The chart below traces how the regime tightened over time, which explains why the bar is now where it is.
The timeline below shows the four steps that built today’s nominee director regime.
In practice, a compliant setup has these features:
- The nominee director is supplied by a CSP that is registered with ACRA, not by an informal intermediary.
- The individual nominee has been assessed as fit and proper before appointment.
- There is a written nominee agreement that sets out the relationship and the nominator’s identity.
- The nominee has disclosed their status and nominator to the company.
- The company keeps the ROND and RONS up to date and has lodged the particulars with ACRA.
- The nominee still discharges the real duties of a director and is not a name-only placeholder.
The arrangement also has to coexist with the ordinary rules of running a company. A nominee does not change the fact that a director carries real legal responsibilities, nor the office-holder constraints such as whether a sole director can also be the company secretary. Keeping the registers and filings current is easiest when it sits inside your monthly compliance routine.
Are Nominee Directors Still Legal?
Yes. Nominee directors are still legal in Singapore, provided the arrangement is compliant. What is no longer acceptable is an undocumented, unregistered, name-only appointment used to obscure who controls a company. The 2024 to 2026 changes did not outlaw the role; they closed the gap that let it be misused.
One point that has not changed: a nominee director still bears the full statutory and fiduciary duties of any director, and the personal liability that comes with them. That exposure is real and is the same whether or not the person acts on instructions. We cover it in detail in our companion post on the risks of being a friend’s nominee director, which is the right read if you have been asked to be one. If you are forming a company from scratch, the requirement first appears when you register the company and need a locally resident director.
Frequently Asked Questions
What are the new nominee director rules in Singapore?
Nominee directors remain legal, but a nominee supplied by way of business must now be arranged through a registered corporate service provider and assessed as fit and proper. The company must also keep a Register of Nominee Directors and lodge the particulars with ACRA. These changes came mainly from the Corporate Service Providers Act 2024, which took effect on 9 June 2025.
Must a nominee director be appointed through a registered CSP?
Yes. Since 9 June 2025, a nominee director provided by way of business must be arranged through a corporate service provider that is registered with ACRA. The proposed nominee must be assessed as fit and proper before appointment. You can no longer rely on an unlicensed intermediary or an informal contact to place a name on your board.
What changed under the Corporate Service Providers Act 2024?
The Act created a registration and supervision regime for firms that provide corporate services, including supplying nominee directors and shareholders. It requires CSPs to register with ACRA, requires nominees supplied by way of business to be fit and proper, and strengthens anti-money-laundering and customer-due-diligence duties. It was passed in 2024 and came into force on 9 June 2025.
Does the company have to record the nominee director in a register?
Yes. The company must maintain a Register of Nominee Directors (ROND), and a Register of Nominee Shareholders (RONS) where relevant, and lodge the particulars with ACRA’s central register. The nominee must inform the company of their nominee status and who they act for, and the company must keep those details current.
Are nominee directors still legal in Singapore?
Yes, nominee directors are still legal as long as the arrangement is compliant. What is no longer acceptable is an undocumented, unregistered, name-only appointment used to hide who controls a company. A nominee director also still carries the full statutory and fiduciary duties of any director.
How do I make sure my nominee arrangement is compliant?
Use a CSP that is registered with ACRA, confirm the nominee has been assessed as fit and proper, put the relationship in a written nominee agreement, ensure the nominee discloses their status and nominator, and keep the ROND and RONS lodged and current. A corporate secretarial provider can maintain the registers and filings for you so nothing lapses.
Talk to Us About a Compliant Nominee Arrangement
The rules governing nominee directors have moved a long way since 2017, and the 2025 CSP Act made a registered, fit-and-proper, properly recorded arrangement the only safe way to do it. If you need a compliant nominee director, or you want your existing arrangement reviewed against the new rules and your ROND and RONS brought up to date, talk to us. Excellence Singapore can set up and maintain a nominee arrangement that stands up to the current regime.