General requirements for registration and renewal as a filing agent

A person who wishes to register as a registered filing agent or have his registration renewed must satisfy two general requirements:  

First, he must be one of the following:

  • An individual or a partnership registered as carrying on business under the Business Names Registration Act 2014;
  • A company incorporated under the Companies Act 1967;
  • A limited liability partnership registered under the Limited Liability Partnerships Act 2005; or
  • A limited partnership registered under the Limited Partnerships Act 2008.

Second, he must meet at least one of the following criteria:

  • The person is a registered qualified individual who will carry out, or supervise the carrying out of, transactions with the Registrar;
  • The person is part of a partnership, limited liability partnership or limited partnership, in which at least one partner is a registered qualified individual who will be appointed to carry out, or supervise the carrying out of, transactions with the Registrar; or
  • The person employs or engages a registered qualified individual to carry out, or to supervise the carrying out of, transactions with the Registrar.
This means that when a person applies for registration or renewal as a filing agent, they will be required to appoint, employ or engage at least one registered qualified individual. If the person is themselves a registered qualified individual, they will have to appoint themselves as the registered qualified individual. 

Click here for more information on Filing Agent and Qualified Individual.

Other requirements to be satisfied before a person may be registered or renewed as a filing agent

Anyone seeking to register or renew their registration as a registered filing agent will be required to complete a mandatory training programme. This programme comprises a prescribed Anti-Money Laundering/Counter Financing of Terrorism (AML/CFT) course and an AML/CFT Proficiency Test, which must be completed prior to application. Registered filing agents must fulfil this requirement once every two years as a precondition for renewal.

ACRA may reject an application in the following circumstances:

If the person is an individual (that is, if they are a sole proprietor),

  • They have been convicted (whether in Singapore or elsewhere) of any offence involving fraud or dishonesty punishable with imprisonment for 3 months or more; or
  • They are an undischarged bankrupt, whether in Singapore or elsewhere.

If he is not an individual (that is, they are not a sole proprietor),  

  • Any director, partner, or individual directly or indirectly taking part in or concerned with the management has been convicted (whether in Singapore or elsewhere) of any offence involving fraud or dishonesty punishable with imprisonment for 3 months or more; or
  • Any director, partner, or individual directly or indirectly taking part in or concerned with the management is an undischarged bankrupt, whether in Singapore or elsewhere. 

ACRA may also reject an application if we are not satisfied that the person is a fit and proper individual to be registered, or that any of their directors, partners, or individuals directly or indirectly taking part in or concerned with their management are fit and proper persons.

In addition, ACRA shall reject an application if the person’s previous registration as a registered filing agent has been cancelled as a sanction imposed by ACRA due to either:

  • A breach of a term or condition of registration, or
  • A failure to pay a financial penalty imposed because of a breach of such a term or condition

    • and less than 2 years have elapsed since the date on which the registration was cancelled.

Legal obligations of a registered filing agent

From the time of registration or renewal, a registered filing agent will be required to comply with the legal obligations contained in:

  • Part 6A of the ACRA Act 2004;
  • The ACRA (Filing Agents and Qualified Individuals) Regulations 2015, including the terms and conditions of registration contained in the First Schedule of the Regulations. The first set of terms and conditions cover the establishing of internal policies, procedures and controls to ensure the proper use of the filing number, and having oversight over the qualified individuals and employees. The second set of terms and conditions cover the FATF’s requirements for the prevention of money laundering and terrorism financing; and
  • Breach of these terms and conditions may subject the registered filing agent to sanctions imposed by the Chief Executive of ACRA under Part 6A of the ACRA Act 2004. These sanctions include cancellation or suspension of registration, restriction of use of the electronic transaction system, financial penalties of up to $25,000 per breach, and censure.
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