How to Set Up a Register of Nominee Directors

Last updated on October 24, 2025

The Register of Nominee Directors is a register recording a company’s nominee directors and the particulars of their nominators. Since 31 March 2017, all companies (unless exempted) have been required to maintain such a register under the Companies Act.

On 16 June 2025, new obligations were introduced requiring companies (and foreign companies) not only to maintain private registers, but also to file nominee director information with ACRA’s central registers.

This article sets out these obligations and is intended for company secretaries, small business owners, corporate service providers or in-house compliance staff who are responsible for maintaining the Register of Nominee Directors. It covers both local and foreign companies, and addresses the new filing obligations as of 16 June 2025.

Check out our other article if you are looking for information on setting up a Register of Controllers.

Alternatively, if you just need our template Register of Nominee Directors, skip to the bottom of this article!

This article will cover the following:

Who is a Nominee Director?

A nominee director is a director who is:

“accustomed or under an obligation whether formal or informal to act in accordance with the directions, instructions or wishes of any other person.”

In practice, a nominee director often serves at the behest of a nominator (e.g. a shareholder, corporate investor) and is expected to vote or act in line with that nominator’s instructions.

A nominee arrangement may arise, for example, when a foreign investor appoints a local resident to satisfy the “resident director” requirement under the Companies Act, or when a major shareholder nominates someone to represent its interest.

New Filing and Compliance Obligations Relating to the Register of Nominee Directors, Etc.

At the outset, it is important to outline the changes that have been introduced (as of 16 June 2025), which are summarised below:

Central Register Filing

Companies and foreign companies must submit the information from their private Register of Nominee Directors to the Accounting and Corporate Regulatory Authority’s (ACRA) Central Register of Nominee Directors by 31 December 2025 (for existing entities).

After this initial submission, any update to the private Register must be filed with ACRA within 2 business days.

For companies (or foreign companies) incorporated or registered on or after 16 June 2025, nominee director information must be filed with ACRA at the time of incorporation/registration (i.e. together with initial corporate filings).

Once filed, the nominee status (i.e. that a director is acting as a nominee) will be publicly disclosed on the company’s business profile. Full particulars of the nominators (e.g. identity, address) in ACRA’s Central Register will only be accessible to law enforcement agencies.

Foreign companies must maintain a Register of Nominee Directors

Prior to the amendments in 2025, this requirement primarily applied to local companies; foreign companies (i.e. branches) were not required.

Foreign companies registered in Singapore are now required to maintain a Register of Nominee Directors at their Singapore-registered office or at their corporate service provider’s office.

Increased penalties

The maximum fines for offences relating to the Register of Nominee Directors (and other related registers, e.g. controllers, nominee shareholders) have been raised from S$5,000 to S$25,000.

There is also a new offence for providing false or misleading information (without due diligence) in response to ACRA’s production/inquiry requests. The maximum fine for the offence is S$25,000.

Corporate Service Providers (CSPs) Regime

The Corporate Service Providers Act 2024 requires entities providing corporate services (including arranging or acting as nominee directors) to be registered as CSPs & comply with fit-and-proper, anti-money laundering and counter terrorism financing requirements.

CSPs will play a larger role in facilitating nominee arrangements and the required disclosures.

Disclosure Obligations by Nominee Directors

Nominee directors must disclose to their companies:

Their status as a nominee director;
The particulars of their nominator (as required below).

They must also notify changes (e.g. if they cease to be a nominee or the nominator’s particulars change) within the prescribed timelines:

For a company incorporated on or after 16 June 2025: The director who is a nominee on the date of incorporation must disclose on the date of incorporation. For a director who becomes a nominee after the date of incorporation, they must disclose within 30 days after the director becomes a nominee.

For a company incorporated on or after 31 March 2017 but before 16 June 2025: the nominee (who is a nominee on the date of incorporation) must disclose within 30 days from incorporation. A director who becomes a nominee after the date of incorporation must disclose within 30 days after the director becomes a nominee.

For a company incorporated before 31 March 2017: the nominee must disclose within 60 days after 31 March 2017 (i.e. by 30 May 2017).

For any new appointment or change: within 30 days.

Do note that the filing of the Register of Nominee Directors information to ACRA is the company’s obligation, not the nominee director’s.

What Particulars Must be Recorded in the Register of Nominee Directors?

The particulars to be recorded are set out below, depending on whether the nominator is an individual or a legal entity.

If the nominator is an individual:

Full name
Aliases, if any
Residential address
Email address and contact number
Nationality
Identity card / passport number
Date of birth
Date on which the director became the individual’s nominee

If nominator is a legal entity:

Name of the entity
Unique Entity Number (UEN) / registration number (if any)
Registered office address
Email address and contact number
Legal form (e.g. company, trust, partnership)
Jurisdiction and statute under which it is formed
Name of the corporate entity register (if any)
Registration/identification number on that register (if applicable)
Date on which the director became the entity’s nominee

Importantly, please note that these particulars are about the nominator, not about the nominee director.

Once submitted to ACRA’s central register, the nominee status is publicly visible and will appear in the business profile of the relevant companies. However, complete information on the particulars of nominators in ACRA’s Central Registers will only be accessible to law enforcement agencies.

How to Maintain or Key in Particulars into the Register of Nominee Directors

The process is as follows:

At the outset (or upon appointment), the company may include a statement such as: “As of [date], the company has not received any information on nominee directors of the company.”
As and when a nominee director discloses his/her status and nominator particulars, input them into the Register.
On any change (appointment, cessation, change in nominator particulars), update the private Register and file an update to ACRA within two business days.
Maintain documentary proof (correspondence, notices, declarations) to support the entries, in case of inspection of the Register.

Because ACRA’s central register is synced with the Register of Nominee Directors, care must be taken to align entries and avoid discrepancies.

How is the Register of Nominee Directors Stored? In What Format Must It be Stored?

The Register of Nominee Directors must be kept at the company’s registered office, or if a registered filing agent / corporate service provider is engaged, at its registered office.

In the case of foreign companies, the Register must be maintained in Singapore at either their Singapore-registered office or at their registered corporate service provider.

In terms of format, the Register may be kept in either hard copy or electronic form (soft copy). When uploading the electronic form to ACRA, use the “Update Registers of Nominee Directors and Nominee Shareholders” eService on BizFile.

What are the Filing Deadlines for the Register of Nominee Directors?

Initial Filing Deadline (for existing companies)

Existing companies (local and foreign) must submit all current information to ACRA by 31 December 2025.

Filing at Incorporation (for companies on/after 16 June 2025)

For companies (and foreign companies) incorporated or registered on or after 16 June 2025, the Register of Nominee Directors (if there are any nominee directors) must be filed with ACRA at the time of incorporation/registration.

Ongoing updates

As noted above, any change (e.g. appointment, cessation, change in nominator particulars) must be reflected in the private Register of Nominee Directors and filed with ACRA within 2 business days.

Inspection of the Register of Nominee Directors

ACRA and certain enforcement agencies may demand production or inspection of the Register and supporting documents.

With the new amendments, responses to such demands must include correct information – as highlighted earlier, false or misleading responses (without due diligence) are now a specific offence punishable with a fine of up to $25,000.

The maximum fine for non-compliance with obligations pertaining to the Register of Nominee Directors (e.g. failing to maintain, failing to submit, failing to update) has increased from $5,000 to $25,000.

Companies Exempted From Maintaining a Register of Nominee Directors

Certain companies remain exempt from having to maintain, and to file, a Register of Nominee Directors. These include:

Public companies listed on a Singapore stock exchange, and their wholly-owned subsidiaries;
Singapore financial institutions, and their wholly-owned subsidiaries;
Companies wholly owned by the Singapore Government (or by statutory bodies), and their wholly-owned subsidiaries; and
Companies whose shares are listed on foreign stock exchanges and subject to regulatory disclosure regimes (subject to conditions).

The complete list of exempted criteria can be accessed here. Exempted entities should notify ACRA of their exempt status via the “Update Registers of Nominee Directors and Nominee Shareholders” eService on Bizfile.

Foreign companies that are exempted from the register must also declare in their annual filing whether they are exempt, and under which category, or where their private register is maintained.

Template for Register of Nominee Directors

For your convenience, we’ve prepared a Register of Nominee Directors template according to the prescribed requirements for your use.

Grab your copy here:

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Reminder: if your company is required to maintain a Register of Nominee Directors, it will also be required to maintain a Register of Controllers. Feel free to check out our guide on setting up a Register of Controllers here.

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