Singapore Nominee Director Nominator Disclosure: Information Required

Identify whose particulars belong in the disclosure

Start with the person or legal entity whose directions the director follows. Under ACRA’s nominee-director guidance , a director is a nominee where accustomed or obliged, formally or informally, to act according to another person’s directions, instructions or wishes. A payment contact or incorporation coordinator is not automatically the nominator. Identify the underlying arrangement before requesting identity documents.

For a non-exempt Singapore company, the Register of Nominee Directors (ROND) records that relationship and the nominator’s particulars. Do not substitute the nominee director’s personal information for the nominator’s information. A shareholder and a nominator need not be the same person. If the arrangement is unclear, obtain confirmation from the director before selecting an individual or corporate information set.

When preparing a new entity, align the proposed director and nomination details with the underlying company registration requirements in Singapore so the incorporation record and disclosure concern the same company and people.

Prepare the individual or corporate information set

For Singapore nominee-director nominator disclosure, prepare the relevant information set below, together with the director’s name and the nomination dates. These are the required particulars in ACRA’s register requirements , checked on 21 October 2026. Complete one relationship record for each nominator; do not compress several nominators into a single name field.

For a locally registered corporate nominator, ACRA’s adding-nominators instructions allow the filer to retrieve entity details using its UEN. For a foreign entity, prepare the foreign business registration number and legal name. Check retrieved information against your evidence rather than treating successful retrieval as confirmation of the nomination itself.

The information set and its evidence travel differently: the company keeps supporting documents with its private register, while the Central ROND receives the particulars. A handoff should preserve both, with a clear record of who received the information.

Keep evidence separate from the central submission

Keep supporting documents with the private ROND ; they are not uploaded with the central filing. Evidence examples in ACRA’s supporting-document guidance include NRIC copies for Singapore citizens or permanent residents, and a passport plus residential-address evidence for a foreign individual. For a foreign legal entity not registered in Singapore, retain its registration certificate and separate registered-office evidence if the certificate omits the address.

Keep the director’s email or letter supplying the particulars as well. This connects the identity evidence to the nomination and records receipt. The private register may be electronic or hard copy and kept at the company’s registered office or its appointed registered corporate service provider’s office. A corporate service provider (CSP) can assist, but the company remains responsible for compliance.

Central filing does not make the nominator public. ACRA’s public-information explanation says the current director’s nominee status appears in the Business Profile, marked “ND”. The nominator’s name and details, nomination date and historical arrangements remain private. Private does not mean unavailable to the authorities. Keep the material ready for lawful agency access, rather than circulating the register as a general company attachment.

Record the dates that start each disclosure clock

Track the event date, the company’s receipt date and the register-entry date separately. Under ACRA’s current company guidance , a nominee at incorporation of a company formed on or after 16 June 2025 must disclose that fact and the nominator’s particulars on incorporation day. A director becoming a nominee later has 30 days from becoming one; changes to particulars or cessation must also be notified within 30 days of the relevant event.

• Record when the company receives the director’s information. The company must enter the information or update its private ROND within seven days after receipt.
• Record when the private register is entered or updated. The central update is due within two business days after that entry or update.
• For incorporation now, prepare the central information for submission on incorporation day; the later-update timetable does not replace that initial obligation.

The 30-day period is the director’s notification limit, not a waiting period for the company . Once information arrives, calculate the company’s own deadline from receipt. Agree prompt internal reporting as a practical safeguard, rather than adding all three periods to invent one combined allowance.

Resolve mismatches before handing over the record

Use the following handoff checks as a preparation control, rather than as additional statutory fields. Each connects a common information defect to the record that needs attention. The aim is to establish what is true before making matching entries in different places.

An authorised filer uses Bizfile’s “Update Registers of Nominee Directors and Nominee Shareholders” eService for later changes. ACRA’s editing instructions require review, declaration and submission, with successful submission confirmed in the Bizfile Inbox. Retain that confirmation alongside the corresponding private-register update. Broader central nominee-register filing and maintenance duties continue after the information packet has been handed over.

For a mistake already submitted, correct the private record as appropriate and update the central particulars through the same eService. ACRA says a separate Notice of Error is unnecessary. Flag a missed deadline immediately to the responsible company officer; a correction should not be described as erasing the earlier delay.

Release the nominator record only when it reconciles

Release a nominator packet when the relationship is identified, the correct individual or entity particulars are supported, and the actual nomination date is distinguishable from receipt and entry dates. Name the person responsible for the private register and the person responsible for the central submission, then obtain completion evidence from both.

If identity, instructions or dates remain disputed, escalate those precise facts for review. If a deadline has already passed, prioritise correction and filing while resolving the breach; do not hold the whole matter until the next annual compliance cycle.