Enhanced Monitoring Report on the Implementation of the Standard on Transparency and Exchange of Information on Request 2025

Singapore

Singapore joined the Global Forum in 2009. Singapore underwent its Second Round of EOIR Peer Review in 2018 (Singapore’s 2018 Report),1 which assessed its legal and regulatory framework in force as at 30 May 2018 and its practical implementation, including in respect of EOI requests received and sent, during the review period from 1 April 2014 to 31 March 2017. Singapore received an overall rating of Compliant and the individual Elements were rated as follows:

 

	A.1	A.2	A.3	B.1	B.2	C.1	C.2	C.3	C.4	C.5	Overall
Determinations	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	n.a.	C
Ratings	LC	C	C	C	C	C	C	C	C	C

Status of implementation of recommendations issued in the peer review report

Singapore received one in-box recommendation in relation to Element A.1.

This monitoring report assesses the actions taken by Singapore to address the recommendation issued in its EOIR Peer Review Report and the peer input received for the monitoring period 2023-2024.

The report concludes that the recommendation is “in the process of being addressed” and advises on actions required.

Element A.1: Availability of ownership information

1.Monitoring the implementation of the obligation to maintain a register of beneficial owners

 

Recommendation (A.1, practice)	Singapore should monitor the implementation of the obligation to maintain a register of beneficial owners and, if necessary, take further measures to ensure availability of beneficial ownership information as defined under the standard.
Underlying factor	In March 2017, Singapore introduced an obligation on all domestic companies, limited liability partnerships and registered foreign companies to maintain a register of their beneficial owners (“controllers”). Although the obligation seeks to ensure identification of beneficial owners in line with the standard, these changes are recent and their impact on the practical availability of beneficial ownership information in Singapore remains to be fully tested. (see paragraphs 80-92 of the Singapore’s 2018 Report for more information.)
Summary of actions reported	Since 2017, Singapore has implemented measures to enhance the availability of beneficial ownership (BO) information. Primarily regarding the filing of beneficial ownership information, Singapore’s supervisory mechanisms target the Corporate Service Providers, who are obliged under the anti-money laundering framework to conduct customer due diligence and identify beneficial owners of their clients, and who file approximately 80% of information to the central BO register. The remaining 20% are filed directly with the central BO register by individuals that are authenticated by Singapore’s national digital identity system known as SingPass. The supervisory mechanisms also target the accuracy of the information contained in the BO register. Singapore has emphasized education and enforcement, including the adoption of a risk-based approach to audits. Singapore introduced a central BO register on 30 July 2020 and passed various legislative amendments in 2022 and 2024 to increase the efficiency of the system in place. Amendments in July 2024 now require companies (including foreign companies) and Limited Liability Partnerships to maintain and file BO information from the date of incorporation or registration, removing the previous 30-day grace period. The level of sanctions was also increased. The filing rate increased from 64% in 2021 to approximately 91% by December 2024 (on BO information). In 2024, the Accounting and Corporate Regulatory Authority conducted 447 inspections and took enforcement actions in 4 cases.
Conclusion	Singapore has made significant progress in addressing the recommendation to monitor the implementation of the obligation to maintain a register of beneficial owners and to ensure the availability of BO information. The marked improvement in compliance rates, the expansion of inspections, and the enhancement of legislative obligations demonstrate a proactive approach to closing previous gaps in information availability. The removal of the grace period and the establishment of a central BO register ensures more immediate and centralized access to BO data. Some of the progress made is recent, as new legislation was passed in 2024, and the implementation of the resultant changes in practice need to be monitored. Particularly, since 2024, entities must now periodically (at least once every calendar year) give notices to each registrable controller whose particulars are entered in the register to require them to confirm whether any change has occurred, and failure may lead to financial sanctions. In conclusion, Singapore has made progress to address the recommendation. It should report further progress in its next self-assessment.
Status determined	In the process of being addressed
Actions required	In its next self-assessment, Singapore should – Provide updated statistics on the compliance of companies and limited liability partnerships with their obligation to provide beneficial ownership information to the authorities and the verification mechanisms taken to ensure that beneficial ownership information is accurate and adequate. Provide information on the implementation and enforcement of the new obligation introduced to ensure the updating of beneficial ownership information.

EOIR experience

Over the monitoring period 2023-2024, Singapore received 795 requests and sent 18 requests. India, Indonesia and France were the top three partners in respect of incoming requests. Viet Nam, China and Malaysia were the key partners in respect of outgoing requests. Singapore reported providing full and final responses in 95% of all the received requests and indicated 3.5% as pending requests.

Nine members provided peer input on Singapore. Peers have reported that their EOIR experience with Singapore is generally satisfactory.

New developments having a bearing on the EOIR standard

No recent developments that have a bearing on the EOIR standard (other than those reported to address recommendations) have been reported by Singapore or have otherwise come to light.

Next steps

Singapore should continue taking actions towards implementing the standard effectively.

The following next steps are expected from Singapore:

• Submit its next self-assessment in 2028 under the second round of enhanced monitoring.

Views/response of the monitored jurisdiction

Singapore appreciates the PRMG's assessment.

Singapore views that the recommendation has been fully addressed. The legislative amendments in 2022 and 2024 demonstrate Singapore’s continued commitment to maintaining high standards in our beneficial ownership framework, rather than a response to systemic deficiencies. These enhancements build on an existing framework that has already fully addressed the concerns raised in the original 2018 (Second Round) recommendation.

Singapore’s implementation and monitoring of beneficial ownership requirements are evidenced by the high 91% filing compliance rate to maintain and update the central BO register as of December 2024 and the expansion of inspections. The verification mechanisms to ensure the accuracy of information in the central BO register are comprehensive, covering both point-of-filing verification and post-filing measures such as risk-based inspections, investigations and enforcement actions. Singapore has been able to access and provide BO information when required.

Given the demonstrated robustness of our framework, comprehensive verification mechanisms and high compliance rate, Singapore’s view is that the 2018 recommendation has been fully addressed and the existing framework is effective to ensure the availability of beneficial ownership information. However, we note the position maintained by the PRMG on the need to continue monitoring new legislative amendments, which is consistently applied to all monitored jurisdictions.

Considering the PRMG's interest to continue monitoring implementation of the legislation that was passed in 2024, we will focus our subsequent updates on the implementation of the most recent July 2024 legislative enhancements. With further demonstration of our continued efforts, Singapore hopes that the recommendation will be considered fully addressed by the PRMG in the next Enhanced Monitoring Round.

Note

← 1.  OECD (2018), Global Forum on Transparency and Exchange of Information for Tax Purposes: Singapore 2018 (Second Round): Peer Review Report on the Exchange of Information on Request, Global Forum on Transparency and Exchange of Information for Tax Purposes, OECD Publishing, Paris, https://doi.org/10.1787/9789264306165-en.