What the CSP Act 2024 actually does
Act 27 of 2024 repealed prior filing-agent registration and replaced it with full licensing administered by ACRA. Commenced 9 June 2025 with transitional provisions to 8 December 2025. The Act: (1) requires every CSP to be licensed by ACRA; (2) requires every nominee-director arrangement to be arranged through a licensed CSP; (3) establishes a Central Register of Nominee Directors and Nominee Shareholders; (4) introduces fines up to S$100k per corporate offence and S$50k per individual; (5) codifies fit-and-proper requirements; (6) imposes specific AML obligations beyond prior MAS Notice baseline.
The Central Register of Nominee Directors
Every nominee director must be flagged as a nominee on ACRA's register at appointment. The nominator's identity must be disclosed to ACRA. Disclosure is not publicly searchable but is available to ACRA, IRAS, SPF Commercial Affairs, STRO, and foreign competent authorities under TIEA/MLAT. The S$50k individual fine attaches specifically to non-disclosure or false disclosure — multiplied per company.
What 'carrying on business as a CSP' means
Captures any person providing (by way of business) incorporation services, director services, secretary services, registered-office address, or nominee shareholder arrangements. The October 2025 enforcement guidance confirmed: any fee-based arrangement, even nominal, is presumed 'by way of business' and requires licensing.
Pathways for UAE founders without SG PR or EP
Pathway 1 — EP: Cleanest. Founder applies for Employment Pass (S$5,600 minimum salary, COMPASS test). 6-12 weeks. Founder becomes sole director, no nominee.
Pathway 2 — Trusted SG-resident director: Co-founder or senior employee already SG-resident. No CSP, no fine exposure.
Pathway 3 — CSP-arranged nominee: Standard outsourced. Licensed CSP, Central Register flag, nominator disclosure, EDD on founder. Pricing has risen — clean files S$4,500-S$8,000/year (vs S$2,000-3,500 in 2024); PEP/higher-risk-jurisdiction files S$10,000+.
Pathway 4 — Move structure out of Singapore: ADGM, DIFC or Hong Kong increasingly chosen by UAE founders without a specific SG driver.
Tax residency considerations
A Singapore Pte Ltd is tax-resident in Singapore if control and management are exercised in Singapore. A board comprising only a nominee acting on founder instructions risks the company being treated as NOT SG-resident, and being resident in the founder's UAE. Can be a feature (UAE-Singapore DTA) or a bug (loss of SG treaty network). IRAS e-Tax Guide on Certificate of Residence (September 2024 update) is explicit: strategic decisions must be made in SG.
Practical actions for UAE founders
(1) Verify your CSP's licence on ACRA's published list. If unlicensed, migrate within 90 days. (2) Confirm Central Register filing — transitional period closed 8 December 2025. (3) Review the nominee agreement against new standards. (4) Reconsider Pathway 1 if you have meaningful SG presence — EP may now be cheaper over 3 years than CSP fees. (5) Run tax residency analysis explicitly.