Unit 3.1 Paper 2

Regulation of the Real Estate Agency Industry for the RES Exam

Last reviewed 12 October 2026

Unit 3.1 is the largest single source of questions in Paper 2, and most of them come down to knowing who regulates what and which figure attaches to which breach. The Council for Estate Agencies (CEA) is a statutory board under the Ministry of National Development, established on 22 October 2010 under the Estate Agents Act 2010 to licence estate agents, register salespersons, set standards of conduct and discipline those who fall short. Figures below are as at October 2026.

Key points

CEA is a statutory board under MND, established 22 October 2010 under the Estate Agents Act 2010.
CEA licenses agents, registers salespersons, sets CPD and disciplines breaches — it never fixes commission rates.
A salesperson must be at least 21, hold 4 O-level passes, pass the RES exam and register through one licensed estate agent only.
Out of the industry more than two years means retaking the RES course and examination; less than that means meeting CPD.
CPD is 16 hours a calendar year: at least 12 Structured (4 Prescribed Essentials, 8 Professional Competencies) and 4 Self-directed; components cannot substitute.
From 1 January 2027 licences and registrations run three years, with a Currency Requirement of three qualifying transactions or a Refresher Exam.
A Letter of Censure carries up to $5,000; a Disciplinary Committee up to $100,000 for a salesperson and $200,000 for an agency — per breach for AML matters from 1 July 2025.
Appeals go to the MND Appeals Board: Notice of Appeal within 14 days, Petition within 21 days after that, decision final.

The Estate Agents Act and the regulations beneath it

The Estate Agents Act 2010 is the parent statute. It creates CEA, requires estate agents to be licensed and salespersons to be registered, and sets out the offences a court can punish. Beneath it sit the Licensing and Registration Regulations 2010, the Estate Agency Work Regulations 2010, the Dispute Resolution Schemes Regulations 2011 and the Prevention of Money Laundering, Proliferation Financing and Terrorism Financing Regulations 2021. CEA then issues practice guidelines and circulars, which are not legislation but bind licensees and registered salespersons through the Code of Ethics itself.

Three definitions in section 3 do most of the work. Estate agency work is work for a client in the course of business, or for any fee, introducing the client to a third person who wishes to acquire or dispose of property, negotiating that transaction, or work following such an introduction. Property means an interest in land whether in Singapore or elsewhere, including a building completed, under construction or yet to be built, so marketing foreign property is regulated. An estate agent carries on that business and must be licensed; a salesperson does the work for an estate agent and must be registered.

Section 4 lists who falls outside the Act, and examiners favour it because the exclusions are counter-intuitive.

Executors, administrators, trustees, liquidators, receivers and assignees of bankrupts acting in that capacity
Practising solicitors who merely introduce a third person and do no other estate agency work
Appraisers valuing under the Appraisers Act, and anyone acting in connection with a mortgage or charge
Publishers of advertisements who do no other estate agency work
A vendor or purchaser acting for themselves — including a developer selling its own units and an owner selling or renting out personally
Employees acting within the scope of their employment, which is why a developer’s in-house sales staff need not be registered
The Government and statutory bodies performing a public function

What CEA does, and what it does not do

CEA licenses estate agents, registers salespersons, sets the entry and continuing education requirements, promotes the integrity and competence of the industry, takes enforcement and disciplinary action, and educates consumers. It also administers the Dispute Resolution Scheme framework and publishes the Public Register.

What CEA does not do appears almost every paper. CEA does not fix or prescribe commission rates, and issues no guidelines on commission amounts: commission is freely negotiated between client and estate agent and recorded in the estate agency agreement, so any option asserting a regulated or recommended rate is wrong. CEA also does not award compensation — its disciplinary process punishes misconduct, so a consumer seeking money must use the Dispute Resolution Scheme or the courts — and it does not adjudicate commission splits between agencies.

Licensing an estate agent and registering a salesperson

An estate agent must be registered with ACRA, be fit and proper, carry valid professional indemnity insurance, have standard operating procedures for training, complaints handling and confidentiality, and appoint a Key Executive Officer. The KEO needs four GCE O-level passes or an equivalent, a pass in the Real Estate Agency examination within the preceding two years, the position of sole proprietor, director or partner of the agency, at least three years’ estate agency experience, and either at least 30 transactions in the last three years or three years managing a licensed agency. The indemnity minimum rises with headcount, and the $100,000 sub-limit per salesperson is a ceiling within the policy, not a multiplier of the total cover.

For a salesperson the requirements are an age of at least 21, four GCE O-level passes or an equivalent, a pass in the RES examination, registration through one licensed estate agent, not being a licensee or KEO of another agency, not holding a moneylender’s licence or working for one, being fit and proper, indemnity cover valid for at least a year from commencement, and MediSave contributions up to date. Three years’ experience is a KEO requirement, not a salesperson one, and there is no freelance registration outside an estate agent. Someone out of the industry for more than two years must retake the RES course and pass the examination again; someone lapsed for less need only meet the CPD requirement.

RES registration application fee $60, GST exempt, paid by the estate agent; annual registration fee $280, or $140 for a part year beginning after 30 June
Estate agent licence application fee $120, GST exempt; annual licence fee from $330 for 1 to 10 salespersons, with $280 added per practising partner in a partnership
PII minimum cover: $100,000 (sole proprietor, 1 salesperson), $200,000 (1–10), $300,000 (11–30), $400,000 (31–50), $600,000 (51–500), $1 million (over 500)
Acting as an estate agent without a licence, s 28(2): up to $75,000 and 3 years, plus $7,500 a day for a continuing offence
Acting as a salesperson without registration, s 29(3), or employing one, s 39(2): up to $25,000 and 12 months
False documents in a licence application, s 33(6), or a registration application, s 34(7): up to $50,000 and 3 years
Obstructing CEA or its inspector, or refusing to attend a hearing, s 64(1): up to $50,000 and 24 months

CPD and the move to a three-year cycle from 2027

Since 1 January 2026 the requirement has been 16 training hours per calendar-year cycle for KEOs and salespersons: at least 12 hours of Structured Learning, comprising at least 4 hours of Prescribed Essentials and at least 8 hours of Professional Competencies, plus 4 hours of Self-directed Learning under Generic Competencies Plus, verified or approved by the KEO. The Prescribed Essentials topic is set yearly; for 2026 it is Prevention of Money Laundering, Proliferation Financing and Terrorism Financing, taken as a course of at least four hours.

The trap is substitution. Each component carries its own minimum, so surplus Professional Competencies hours do not cure a shortfall elsewhere and a plan totalling 16 or even 18 hours can still fail. Newly registered salespersons are exempt in their first cycle. Where the requirement is unmet, section 32A lets CEA refuse to renew the registration; a shortfall is not itself an offence and does not make a registration lapse mid-year.

On 28 July 2026 CEA announced that from 1 January 2027 licence and registration validity moves from one year to three, the first cycle running to 31 December 2029. Annual fees are unchanged, but the application fee becomes payable once every three years. A new Currency Requirement accompanies the change: at least three qualifying transactions within the three-year period, or a pass in a Refresher Examination whose details are due in the first half of 2029. Qualifying transactions are not limited to residential work — commercial, industrial, foreign and collective-sale deals count. A new salesperson is exempt in the calendar year of joining and then needs two transactions across the remaining two years. Non-compliance means ineligibility to renew, and a return requires retaking the RES course and examination.

Discipline: Letters of Censure, Disciplinary Committees and appeals

For less serious breaches CEA may issue a Letter of Censure, with or without a financial penalty of up to $5,000. The framework came in with the Estate Agents (Amendment) Act 2020 and has been operational since 30 July 2021. The penalty is normally per case, but for anti-money laundering, proliferation financing and terrorism financing breaches committed on or after 1 July 2025 it applies per breach, so three such breaches can attract up to $15,000. A Letter of Censure does not suspend a registration, and CEA does not need the recipient’s agreement to issue one.

Serious matters go to a Disciplinary Committee of at least three persons nominated from CEA’s Disciplinary Panel. The respondent files an Admission or Defence within 14 days of service of the charges. The Committee may revoke or suspend a registration or licence, impose or vary conditions, reprimand, order costs from a $2,000 base, and impose a financial penalty of up to $100,000 on a salesperson and $200,000 on an estate agent — per case, but per breach for AML, PF and TF breaches from 1 July 2025. What it cannot do is imprison anyone: a custodial sentence follows only from conviction in court.

An appeal against a decision of CEA or a Disciplinary Committee goes to the Appeals Board appointed under the Ministry of National Development, not the High Court. The Notice of Appeal is due within 14 days of notification and the Petition of Appeal within 21 days after that deadline. The Appeals Board’s decision is final.

The Estate Agency Work Regulations: the prohibitions and their penalties

Regulation 3 requires licensees and registered salespersons to observe the Code of Ethics and Professional Client Care in the First Schedule; regulation 4 requires licensed estate agents to comply with the Code of Practice in the Second Schedule. The regulations then create the industry’s best-known prohibitions, set out below, and mixing up their figures is the commonest way to lose a mark in this unit. Unit 3.2 covers what each duty requires in practice; what matters here is the penalty attached to each. Two points of scope recur: the clients’ consent never cures dual representation, and the ban on handling transaction money is not confined to HDB deals. Separately, the Code of Practice requires an agency to keep its records for at least five years.

Reg 5 — acting for both vendor and purchaser, or both landlord and tenant, in the same property: up to $25,000 and 12 months
Reg 6 — introducing a client to a moneylender, or taking commission for doing so: up to $25,000 and 12 months
Reg 7 — holding or handling money for any party in the sale or purchase of any Singapore property, or the lease of HDB property: up to $10,000 and 6 months, plus $500 a day for a continuing offence
Reg 8 — using CEA’s name, symbol or mark without written permission: up to $10,000 and 6 months
Reg 9 — failing to display the estate agent card at all times while doing estate agency work: up to $10,000 and 6 months
Reg 10 and 11 — Forms 1 to 8 are prescribed for residential property; the requirement does not reach commercial, industrial, foreign, collective-sale or developer-sale work
Reg 12 — the client must be told immediately if the agent or salesperson becomes unable to perform the agreement

The Public Register and the Dispute Resolution Scheme

CEA’s Public Register lets a consumer confirm that a person is registered and see the residential transactions that agent completed in the past 36 months. Since 10 June 2026 it also publishes enforcement actions — Letters of Censure, Disciplinary Committee outcomes and court prosecutions — on a rolling three-year basis, attributed to the agency the agent was with when the breach occurred, together with any awards received. It is not a lifetime record, and it does not publish income, commission earned, client reviews or full NRIC numbers.

The Dispute Resolution Scheme is open to a client who signed an estate agency agreement with a licensed agency, for a dispute arising from that agreement’s terms, which is why commission claims qualify where a prescribed agreement exists. The client complains to the agency first, then requests the scheme. Mediation comes first, administered by CASE, the Singapore Institute of Surveyors and Valuers or the Singapore Mediation Centre, with the centre selected within four weeks of the request; if the matter is unresolved within six weeks of notice of the first session it may go to arbitration administered by SIArb or SISV, whose award is binding. Neither CEA nor the regulations set any monetary cap, so do not assume one. The scheme does not cover co-broking disputes between salespersons — those are for the agencies, their KEOs or the industry association — nor a landlord and tenant arguing over a deposit, which CEA treats as a private contractual matter outside its remit.

Terms to know

Estate agency work: Work for a client, or for a fee, introducing a party who wishes to acquire or dispose of property, negotiating that transaction, or carrying out work relating to it after the introduction.
Key Executive Officer (KEO): The individual responsible for managing and supervising a licensed estate agent, who must meet CEA’s examination, experience and transaction criteria.
Letter of Censure: An administrative sanction CEA may issue for a less serious breach, with or without a financial penalty of up to $5,000.
Disciplinary Committee: A panel of at least three persons nominated from CEA’s Disciplinary Panel that hears disciplinary charges and may fine, suspend or revoke.
Currency Requirement: From 1 January 2027, the obligation on a salesperson to complete three qualifying transactions in each three-year registration period or pass a Refresher Examination.
Professional indemnity insurance (PII): Cover a licensed estate agent must carry against claims arising from its estate agency work, at minimum limits set by CEA according to the number of salespersons.
Dispute Resolution Scheme (DRS): The mediation-then-arbitration scheme a client who signed an estate agency agreement may use for a dispute arising from that agreement.
Public Register: CEA’s searchable record of licensed agencies and registered salespersons, showing 36 months of residential transactions and three years of enforcement actions.

Frequently asked questions

Does CEA set commission rates for property agents in Singapore?

No. CEA states that there are no fixed commission rates and no prescribed guidelines on commission amounts. Commission is negotiated between the client and the estate agent and should be agreed before work begins, with the agreed terms set out in the estate agency agreement. In the RES examination, any answer that assumes a regulated or recommended rate is wrong.

Can a salesperson be registered with two estate agencies at the same time?

No. Registration must be submitted through one licensed estate agent, and the applicant must not be a licensee or Key Executive Officer of another licensed estate agent. There is no freelance registration outside an estate agent, whatever insurance the individual buys. A salesperson who moves agencies pays the $60 application fee again.

What happens if a salesperson does not complete the CPD hours?

Section 32A of the Estate Agents Act, inserted by the 2020 amendment, allows CEA to refuse to renew the registration of a salesperson who has not met the CPD requirement for the cycle. A shortfall is not a criminal offence and does not cause the registration to lapse automatically mid-year. Newly registered salespersons are exempt in their first CPD cycle.

Can a CEA Disciplinary Committee send a salesperson to prison?

No. A Disciplinary Committee may revoke or suspend a registration, impose conditions, reprimand, order costs and impose a financial penalty of up to $100,000 on a salesperson. Imprisonment can only be imposed by a court after a prosecution for an offence under the Estate Agents Act or its regulations.

Where does an appeal against a CEA disciplinary decision go?

To the Appeals Board appointed under the Ministry of National Development, not to the High Court. A Notice of Appeal is due within 14 days of being notified of the decision, and the Petition of Appeal within 21 days after that deadline. The Appeals Board’s decision is final.

Is the Estate Agents Act limited to property in Singapore?

No. Section 3 defines property as an interest in land whether in Singapore or elsewhere, including buildings completed, under construction or to be constructed. Marketing foreign property is therefore regulated estate agency work, and CEA’s Practice Guidelines on the Marketing of Foreign Properties impose additional due diligence and risk-advisory duties.

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