Strengthening Corporate Transparency in Singapore

Singapore continues to grow as a leading global business hub, and with that comes a stronger emphasis on good corporate governance. As part of efforts to enhance transparency, the Accounting and Corporate Regulatory Authority (ACRA) has introduced the Central Registers of Nominee Directors and Nominee Shareholders.

These new requirements take effect on 16 June 2025, and all relevant companies must comply by 31 December 2025.

1. What Are These Registers?

Since 2017, companies have had to maintain a private Register of Nominee Directors, and since 2022, a Register of Nominee Shareholders. These registers record the details of the nominators: the individuals or entities who appoint nominee directors or shareholders.

This obligation extends to foreign companies as well through the Companies and Limited Liability Partnerships (Miscellaneous Amendments) Act 2024. These private registers are kept either at the company’s registered officer or with its Corporate Service Provider (CSP).

2. New Changes From 16 June 2025

While companies will continue keeping their private registers, they must now also submit this information to ACRA, forming the Central Registers of Nominee Directors and Nominee Shareholders.

Once filed, the nominee status of directors and shareholders will be publicly visible in the company’s Business Profile. However, full details of the nominators will only be accessible to law enforcement agencies.

3. Exemptions

Some companies are not required to maintain these registers and may notify ACRA of their exemption through BizFile.

Companies exempted from the requirement to maintain the Registers of Nominee Directors and Nominee Shareholders are:

1. a public company which shares are listed for quotation on an approved exchange in Singapore;  
2. a company that is a Singapore financial institution;  
3. a company that is wholly owned by the Government;
4. a company that is wholly owned by a statutory body established by or under a public Act for a public purpose;  
5. a company that is a wholly-owned subsidiary of a company mentioned in sub-paragraph (1), (2), (3) or (4);   
6. a company which shares are listed on a securities exchange in a country or territory outside Singapore and which is subject to — 

            (i) regulatory disclosure requirements; and

           (ii) requirements relating to adequate transparency in respect of its beneficial owners, imposed through stock exchange rules, law or

                other enforceable means.

Foreign companies that are exempted to maintain the Registers of Nominee Directors and Nominee Shareholders are:

1. a foreign company that is a Singapore financial institution;

2. a foreign company that is a wholly-owned subsidiary of a foreign company that is a Singapore financial institution;

3. a foreign company which shares are listed on a securities exchange in a country or territory outside Singapore and which is subject to —

             (i) regulatory disclosure requirements; and

            (ii) requirements relating to adequate transparency in respect of its beneficial owners, imposed through stock exchange rules, law or other enforceable means.

4. A foreign company which shares are listed for quotation on an approved exchange in Singapore, such listing being a primary listing.

4. Information To Be Filed

For individual nominators, the required information includes their full name, any aliases, residential address, email, contact number, nationality, identification (IC or passport) number, date of birth, and the dates on which the director or shareholder became and, if applicable, ceased to be the nominee. For corporate entity nominators, the information required includes the entity’s name, UEN (if any), registered office address, email, contact number, legal form, the jurisdiction and statute under which it is incorporated, details of the relevant corporate registry and registration number (if applicable), as well as the dates on which the director or shareholder became and, if applicable, ceased to be the nominee.

5. Penalties For Non-Compliance

Failure to lodge information with ACRA may lead to prosecution, and offenders can face a fine of up to $25,000 upon conviction.

6. How A Corporate Service Provider Can Help

Ensuring compliance with these new transparency requirements may feel overwhelming, especially for companies unfamiliar with nominee reporting obligations. Working with a Corporate Service Provider (CSP) can greatly simplify the process. From maintaining private registers to handling ACRA filings, a CSP provides the expertise and administrative support companies need to stay compliant and avoid penalties.