Quick answer
When a company secretary stops responding, do not begin with an emotional dispute. Begin with a deadline and access review. Confirm the company’s current ACRA profile, upcoming filings, tax notices, registered office mail, Corppass access and ownership records. Then send a written request with a clear response date and prepare a replacement if the risk cannot be controlled.
- Check deadlines before deciding whether the problem is urgent.
- Download current ACRA records and preserve emails, invoices and prior filing acknowledgements.
- Send one consolidated written request instead of scattered messages.
- Do not assume that non-response automatically removes the existing secretary from ACRA records.
- Plan the replacement and transfer before access to records is lost.
First decide whether this is an emergency
The situation is urgent when an annual return, officer change, share transaction, tax filing or bank request is already overdue or due soon. It is also urgent when the registered office is receiving legal or government notices that directors cannot access. A routine question about wording can wait; an unreviewed ACRA deadline cannot.
Create a one-page status sheet. List the company’s FYE, AGM and annual return position, the last known tax filing, current directors and shareholders, registered office, secretary shown on ACRA, and any transaction waiting to be filed. This prevents the recovery effort from becoming a long argument about service quality while a real deadline continues to run.
The first 48-hour recovery checklist
| Area | What to check | Why it matters |
|---|---|---|
| ACRA profile | Obtain a current business profile and confirm officers, shareholders, address and FYE. | Shows what the public register currently says. |
| Bizfile evidence | Collect acknowledgements for annual returns and recent changes. | Confirms whether promised filings were actually completed. |
| Registered office mail | Retrieve ACRA, IRAS, court, bank and vendor correspondence. | Some notices have response dates independent of the secretary dispute. |
| Corppass and portals | Confirm who controls Corppass, myTax Portal, CPF and bank administration. | Prevents operational lockout. |
| Internal records | Locate constitution, resolutions, registers, share certificates and contracts. | Reduces dependence on one service provider. |
| Payment history | Review invoices, engagement terms and unpaid fees. | A commercial dispute may be contributing to the non-response. |
Send a structured written request
Send one email that identifies the company, UEN, urgent deadline and the exact documents or action required. Give a reasonable response date. Ask the provider to confirm whether it remains instructed, whether any filing is pending, and who holds the original or electronic records.
A useful request separates urgent action from the broader transfer. For example: “Please confirm by tomorrow whether the annual return has been filed and provide the acknowledgement. By Friday, please provide the full statutory file and a list of outstanding items.” This makes it easier to show what was requested and whether the provider responded.
Keep the tone factual. Accusations do not update ACRA. The goal is to preserve evidence, secure records and protect the company’s deadlines.
What directors can verify without waiting
Directors can obtain current public information and review their own company emails, accounting records and bank statements. They can also confirm whether ACRA officer changes were reflected and whether annual return status is current. Where the company has Corppass access, authorised users may be able to view tax and other government matters directly.
However, do not create duplicate or conflicting filings simply because the provider is silent. Share transfers, allotments, constitution changes and officer cessations need correct effective dates and supporting approvals. If the underlying facts are uncertain, engage a replacement CSP to reconstruct the file before submitting anything.
Replacing the secretary without losing continuity
A replacement provider should first assess the current record, not simply submit an appointment. Confirm the resignation or withdrawal date of the outgoing secretary, the appointment date of the incoming secretary, and whether the company will remain compliant throughout the transition. Officer changes generally need to be reported within 14 days.
The company should also decide who will receive registered office mail, keep the private registers, prepare annual filings and respond to banks or auditors during the transfer. If services were bundled under one provider, changing only the secretary may leave the registered office, accounting or nominee director arrangement unresolved.
Recovery workflow when no transfer arrives
Freeze the facts
Save current profiles, emails, invoices, portal screenshots and available corporate records.
Identify missing records
Separate documents that can be downloaded, reconstructed or must be obtained from the outgoing provider.
Appoint competent support
Give the replacement provider the timeline and all available source documents.
File urgent corrections
Address overdue or inaccurate public information with proper approvals.
Build a new master file
Keep future acknowledgements, resolutions and registers in a company-controlled location.
Board-level escalation and evidence
If the provider still does not respond, the board should record the problem formally. A short directors’ resolution or minute can note the attempts made, the deadlines at risk, the decision to appoint replacement support and the authority given to retrieve or reconstruct records. This creates a clear basis for later filings and avoids leaving the recovery entirely in informal WhatsApp messages.
Where money, original documents or access credentials are disputed, separate the commercial dispute from statutory action. The company may need legal advice on recovery, but it should still protect time-sensitive filings using the best available evidence. Keep a chronology of requests, courier records, delivery confirmations and any response from the outgoing provider.
After the immediate crisis is resolved, change the control model. Company records should be stored in a company-controlled drive, filing acknowledgements should be copied to at least one director, and recurring deadlines should be visible outside the provider’s internal system.
Frequently asked questions
Can a company operate if its secretary is not responding?
The company still exists, but directors should quickly check whether filings, registered office mail, records or transactions are affected. The statutory responsibilities do not pause because the service provider is silent.
Does an unresponsive secretary automatically cease to hold office?
No. The public record must be checked and any appointment or withdrawal should be properly documented and reported through Bizfile.
Can a new provider file without the old provider’s permission?
A replacement may be able to assist based on proper company approvals and available records, but the exact transaction and effective dates must be verified. Missing documents may need reconstruction.
What should I do if the registered office provider also holds the mail?
Request immediate access to all government, legal, banking and tax correspondence and arrange a replacement address if the service is ending.
What should I send ProSec for an urgent review?
Send the current business profile, constitution, recent invoices, engagement letter, email history, known deadlines, annual return status and all available resolutions or filing acknowledgements.
Official sources
These sources support the regulatory points in this guide. Check the current official page and the company’s own documents before acting.
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