Register of Nominee Directors (RND) - Updated Under the CSP Act 2024

🧾 What Is a Nominee Director? 

A nominee director is a director who acts on behalf of another person — the nominator — rather than in their own personal capacity. These arrangements are legitimate but now face enhanced transparency requirements under the Corporate Service Providers Act 2024 (CSP Act). 

📌 Key Changes Introduced by the CSP Act 2024 

Effective 28 October 2024, the CSP Act introduces new transparency measures: 

✅ Mandatory Filing of the RND with ACRA 

• Companies are now required to lodge the Register of Nominee Directors with ACRA via BizFile+. 

• The filing must be done within 2 business days after a nominee director is appointed or if there are any changes. 

• This register must include: 

• The identity of the nominee director 

• The name and details of the nominator 

• The date the nominee relationship began (or ended) 

• Basis of control/influence 

  
  

This change transforms the RND from a private internal record into a regulator-visible register, strengthening Singapore's AML and corporate transparency framework. 

📋 Filing and Maintenance Obligations 

Action	Deadline
Appointment of nominee director	RND must be filed with ACRA within 2 business days
Change in nominator or termination of arrangement	Update RND and notify ACRA within 2 business days
Maintenance of internal RND	Must still be maintained and available for inspection by authorities

🛡️ Responsibility Under the CSP Act 

• Nominee directors must disclose their status and nominator details to the company. 

• Companies must file the RND with ACRA promptly and ensure it is accurate. 

• Corporate Service Providers (CSPs) involved in the arrangement must: 

• Conduct Customer Due Diligence (CDD) 

• Maintain supporting documents (e.g., nominee agreements) 

• Retain records for at least 5 years 

⚠️ Penalties for Non-Compliance 

Offence	Penalty
Failure to file RND with ACRA	Fine up to S$5,000 per breach
Late or inaccurate filing	Administrative penalties; possible enforcement
CSP failing to comply with nominee disclosure duties	Regulatory action and licence risk

✅ Best Practices for Compliance 

• Use written nominee agreements that clearly identify nominators. 

• Maintain a complete and updated RND internally and in BizFile+. 

• Ensure timely filings with ACRA (within 2 business days of any change). 

• Work with a registered and CSP Act-compliant provider. 

🔍 Summary: Before vs After CSP Act 

Requirement	Before CSP Act	After CSP Act (2024)
Maintain RND internally	✅ Required	✅ Still required
File RND with ACRA	❌ Not required	✅ Mandatory
Penalties for non-filing	Not applicable	Fines and enforcement apply
CSP due diligence on nominee setups	Best practice	✅ Mandatory by law