Corporate Transparency and Nominee Registers

Singapore's Companies and Limited Liability Partnerships (Miscellaneous Amendments) Act 2024 strengthens the information that companies, foreign companies and limited liability partnerships (LLPs) keep and file about controllers and nominee arrangements. ACRA states that the Act took effect on 16 June 2025 and was intended to improve corporate transparency and combat money laundering, terrorism financing and threats to the integrity of the international financial system (ACRA — Companies and Limited Liability Partnerships (Miscellaneous Amendments) Act 2024, accessed 18 Aug 2026). The changes sit alongside, but are distinct from, the Corporate Service Providers Act 2024: one changes entity registers and disclosure duties, while the other regulates businesses providing corporate services. The regime does not mean that every controller's detailed personal information is publicly searchable; public business profiles and agency-accessible central registers expose different levels of information.

Register of Controllers and annual verification

Companies, foreign companies and LLPs must keep a Register of Controllers from the date of incorporation or registration, removing the earlier 30-day grace period, and must check annually with each registrable controller whether the particulars remain correct (ACRA — CLLPMA Act 2024, accessed 18 Aug 2026). A controller is the person or legal entity with the relevant control relationship under the Companies Act or LLP framework; the register is not simply a list of every shareholder or every director. The annual check is an accuracy and update process, not an annual re-incorporation or a public vote on ownership. Companies should use the statutory definitions, notice process, register location and applicable exemptions, and keep evidence of the notices and responses. A controller's information belongs to the entity's compliance records even when the public cannot see all of the same particulars.

Nominee directors and nominee shareholders

The amendments expand nominee transparency. Foreign companies must maintain Registers of Nominee Directors, and companies and foreign companies must file nominee-director and nominee-shareholder information with ACRA's central registers (ACRA — Commencement of new requirements under the CLLPMA Act, accessed 18 Aug 2026; ACRA — CLLPMA Act 2024, accessed 18 Aug 2026). The nominee status of a director or shareholder is publicly available in the relevant company business profile, while detailed information about the nominators in ACRA's central registers is available only to public agencies for administration or enforcement of written law (ACRA — CLLPMA Act 2024, accessed 18 Aug 2026). This distinction matters: “publicly disclosed nominee status” does not mean “the full nominator identity is open to anyone.” The transparency mechanism targets hidden control and nominee arrangements without making every register field a public database.

New and existing entities have different filing timing

New companies, foreign companies and LLPs incorporated or registered from 16 June 2025 must submit controller and nominee information on the date of incorporation or registration, where the relevant register and filing obligation applies (ACRA — Commencement of new requirements under the CLLPMA Act, accessed 18 Aug 2026). Existing entities were given a transition window: ACRA's 9 June 2025 announcement stated that existing companies, including foreign companies, had until 31 December 2025 to submit nominee-director and nominee-shareholder information. Foreign companies must also declare in annual filings whether they are exempt from maintaining specified registers and, if not exempt, where those registers are maintained (ACRA — CLLPMA Act 2024, accessed 18 Aug 2026). A response about a company created before the effective date must therefore distinguish the historical transition deadline from the ongoing register and annual-verification duties.

Penalties and the boundary with CSP regulation

The amendments increased maximum fines for offences involving the relevant controller, nominee-director and nominee-shareholder registers from S$5,000 to S$25,000 per applicable offence on conviction, according to ACRA's legislative summary (ACRA — CLLPMA Act 2024, accessed 18 Aug 2026). The penalty is a compliance consequence, not a statement that every register error is automatically a criminal offence without the statutory elements and process. The CLLPMA regime also should not be merged with CSP registration. A company may have its own register duties even if it does not provide corporate services to customers; a CSP may help maintain or file records but does not erase the company's responsibility. For a practical answer, identify the entity type, incorporation date, controller or nominee arrangement, exemption, filing timing and whether the question concerns the private register, an ACRA central register or a public business profile.