What a buyer or tenant can expect of a property agent in Singapore

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Kooky

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A buyer or tenant who engages a property agent in Singapore is not relying on goodwill alone. The standard of work is written down. The Council for Estate Agencies (CEA), the statutory body that licenses agencies and registers their salespersons, describes the Code of Ethics and Professional Client Care as the code that sets the standard of performance expected of estate agents and salespersons when they carry out business and deal with clients and the public. Its practice guidelines then turn that standard into day-to-day conduct: which checks are made on a property, how an offer travels, what has to be said about a family tie to the other side.

This guide follows those documents from the client's chair. It covers where the duties sit, how to confirm who the agent is, the rule that an agent serves one side only, what counts as a conflict and how it is declared, how the buyer's agent and the seller's agent work together, the checks that come before any money is paid, the handling of offers and documents, and the routes open when the service falls short. The prescribed agreement forms and the question of who pays commission are separate subjects and are left aside here.

CEA's codes of conduct page; the checklist for the buyer's property agent, completed private homes, updated 21 June 2022; CEA's register page, updated 4 September 2026.

Where the duties are written down

Two codes are prescribed under the Estate Agents (Estate Agency Work) Regulations 2010, according to CEA's page on codes of conduct. The Code of Ethics and Professional Client Care applies to estate agents, meaning the licensed agencies, and to the real estate salespersons registered through them. The Code of Practice for Estate Agents applies to the licensed agencies and deals with how they are run: management and supervision, the estate agent card, claims and complaints, and the retention of documents and records.

CEA lists twelve topics in the Code of Ethics. They are knowledge of and compliance with the relevant laws, practice circulars and guidelines; due diligence and compliance with the law and statutory requirements; a general duty to clients and the public; a prohibition on bringing discredit or disrepute to the industry; a duty to clients in relation to the signing of documents; obligations in respect of agreements; obligations in conveying offers and counter-offers; interpretation or translation if necessary; duties in respect of advertisements; the duty to avoid conflicts of interest; recommending professional advice where appropriate; and safeguarding confidential information. CEA's page states that a failure to observe the Code may lead to disciplinary action by CEA or by a Disciplinary Committee.

The detail comes from the practice guidelines. The fullest of them is the Professional Service Manual, issued by CEA as Practice Guidelines in version 1.0 on 1 January 2014. It runs to 39 pages in five sections that follow a transaction in order: establishing the relationship between client and agent, providing professional advice, marketing and advertising, communicating offers, and completing the transaction. The manual says it may be referred to in investigations and disciplinary proceedings. It is the source of the numbered paragraphs quoted in this guide, and its date matters: where a procedure may have changed since 2014, the point is flagged or left out.

Confirming who the agent is

Every property agent in Singapore must be registered with CEA through a licensed property agency, and each has a unique registration number of the pattern R123456A, CEA's register page says. The same page states that it is an offence for an individual to carry out estate agency work without valid registration.

The check runs through the CEA Public Register, and the page describes it as a search by phone number: the number of the person the client is dealing with, or the number shown in the advertisement. A profile confirms four things. It shows whether the registration is valid, the residential property transactions the agent has facilitated in the last two years together with which party the agent represented in each, any industry accolades and awards, and any disciplinary records. For a buyer choosing between agents, the second item is the practical one, since it shows whether the agent has worked for buyers or for sellers over those two years.

Two further identifiers are within the client's reach. The Professional Service Manual of 2014 requires the estate agent card to be displayed at all times when estate agency work is being conducted, at paragraph 3.6.3; the Code of Practice makes the card a matter for the agency. And advertisements must show the agent's name, CEA registration number and phone number together with the agency's name and licence number. The manual applies the register check to agents as well: under paragraph 1.2.2 a salesperson checks the register for the salesperson on the other side and reports an unregistered one to CEA.

When the agent asks for identity documents in turn, that is part of the same framework. CEA's page on buying or selling says agents may ask for an NRIC, FIN or passport number and may take photographs or photocopies when necessary, that the information must not be used for other purposes or shared with parties not involved in the transaction. CEA's consumer page on engaging a property agent adds that the Customer's Particulars Form is mandatory.

One agent, one side

CEA's consumer page on engaging a property agent states the rule in two parts: an agent represents only one party, and being appointed by both sides of the same transaction is an offence. The agent collects commission only from the party represented. The 2014 Professional Service Manual, at paragraph 1.3.6, gives the legal reference as Regulation 5 of the Estate Agents (Estate Agency Work) Regulations 2010 and extends the ban to collecting a fee from more than one party in any form, a share of a co-broking fee included.

The manual closes several side doors that matter to a buyer. An agent may not act as attorney for a client the agent is acting for in the transaction (paragraph 1.5.1). Members of the seller's agent's team must not represent buyers for that property, unless the buyer had engaged them before the property was marketed to that buyer (paragraph 1.8.5). An agent who is personally a party, for instance as the seller of the flat being viewed, must disclose that upfront, act only for himself or herself, and collect no commission from the other side (paragraph 1.4.1).

What remains allowed is narrow. CEA's consumer page says an agent may help the other party with paperwork only with the client's consent, and must state clearly that he or she neither acts for that party nor collects fees from it. A buyer or tenant who has not engaged an agent, and who is dealing with the seller's or landlord's agent, is therefore dealing with someone whose duties run to the other side.

Conflicts of interest: what is declared, and how

The Code of Ethics lists a duty to avoid conflicts of interest, and CEA's consumer page says agents must disclose conflicts of interest and referral fees. The 2014 manual sets the order of things at paragraph 1.3.1: an agent does not accept or continue an appointment that creates a conflict or a potential conflict, and any conflict is disclosed promptly and fully.

Paragraph 1.3.2 says when a potential conflict is taken to exist. It does so where the other party, or the other party's agent, is the agent's spouse or former spouse, parent or parent-in-law, sibling or sibling-in-law, or child or child-in-law. Business ties count too: partners, employees, and certain links with a company. Paragraph 1.3.3 adds any relationship that could affect the transaction, to be disclosed in advance, and gives the example of a referral fee paid by a bank.

Some disclosures must be in writing. Under paragraph 1.3.4 that is the case where the other party's agent comes from the same agency, and where there is an overriding fee or a commission-sharing arrangement between the two. Under paragraph 1.3.5 the agent discloses the conflict and obtains the client's informed written acceptance before continuing, or stops acting. A note to the paragraph says that writing includes email and SMS. The manual's own example fits a buyer's case: a buyer's agent whose husband acted for the seller.

Two agents, one deal: co-broking from the buyer's side

Co-broking, as CEA's consumer page describes it, is two agents representing opposing parties working together and sharing a commission. The arrangement is strictly between the agents. CEA notes that it lets buyers see more listings through the agents' networks.

The 2014 manual adds how the two agents behave towards each other and towards their clients. Co-broking fees are agreed between the agents upfront; where the agents on both sides are each paid commission by their own client, no further co-broking fee is payable (paragraph 1.8.3). The buyer's agent seeks information on the property from the seller's agent or the seller (paragraph 3.2.1). The seller's agent, when asked, conveys material matters, and the manual names caveats, defects, unauthorised works and the Housing and Development Board's minimum occupation period (paragraph 3.8.3).

CEA's consumer page puts the same duty in the buyer's or renter's terms: the agent should make reasonable efforts to obtain requested property information from the other side and pass it on. Its example is whether the seller or landlord has experienced harassment by loan sharks. The traffic has a limit on both sides, since each agent protects the confidential information of his or her own client when answering the other.

What the agent verifies about the property

Due diligence is the second topic of the Code, and the 2014 manual gives it content. On the buyer's or tenant's side, the agent verifies that the counterparty is the owner (paragraph 1.7.1). Agents on both sides run a title search through the Singapore Land Authority's INLIS service and give the client a copy; for a sublet, the head lease and the landlord's consent are checked (paragraph 1.7.2). The basic particulars are verified against the listed sources: tenure, floor area, service and conservancy charges, upgrading works and approved use (paragraph 1.7.3). Paragraph 3.2.2 states the general rule, which is to take reasonable steps to verify information with reliable sources.

Some checks concern the client rather than the property. The agent records the client's name, verifies the NRIC or passport details and confirms legal age; the manual notes at paragraph 1.6.2 that contractual capacity at 18 does not extend to sales, purchases or mortgages of land, or to leases of more than three years. For a foreign buyer, the agent checks whether approval under the Residential Property Act is needed and raises it before the Option to Purchase or the sale and purchase agreement is signed (paragraphs 2.2.3 and 2.2.4). On financing, the manual's example at paragraph 2.2.8 is a buyer who should hold a bank's letter of offer, or an in-principle approval, before signing the option.

For a flat sold on the HDB resale market, paragraph 2.2.6 has the buyer's agent advise on eligibility and go through the buyer's checklist before the option is exercised, including the limits on the loan and on the use of Central Provident Fund savings. One protection concerns the client's own credentials: an agent must not use a client's Singpass password to reach HDB's electronic services without written consent, and then only for that transaction (paragraph 1.7.1).

Before the option fee: the buyer's agent checklist

For private homes, the checks have been gathered into checklists. CEA's page on buying or selling encourages their use before any contract is entered into and lists four for the buying side: a buyer's checklist and a buyer's property agent checklist, each in a version for completed and for uncompleted private residential property. They sit alongside CEA's standard templates for the Option to Purchase and the sale and purchase agreement of a resale private home.

The checklist for the buyer's property agent on a completed home is three pages long and was updated on 21 June 2022. It was drawn up by the Digitalised Property Transactions Workgroup under the Real Estate Industry Transformation Map. Its Section A lists eleven things to verify before the option fee is paid, viewing originals where available:

1. the names of the client and of the seller;
2. their NRIC or passport;
3. the ACRA registration number or UEN, where the seller is a company;
4. ownership of the property, its specifications (address, tenure, area), restrictions and third-party caveats;
5. the approved use of the property;
6. the absence of unauthorised additions or alterations;
7. outstanding property tax owed by the seller;
8. the buyer's stamp duty liability;
9. associated costs, such as service charges and maintenance fees for strata-titled property;
10. the client's financial plan: loan amount and period, CPF savings to be used, and the cash required;
11. the seller's bankruptcy status.

Six additional safeguards follow. A foreign client is advised to obtain an approval-in-principle for restricted residential property before signing. The agent obtains the approved plans from the Building and Construction Authority and compares them with the home as built, advising an inspection by a qualified professional if needed. Where it is unclear whether the seller is a property trader for income tax purposes, the seller's written confirmation is obtained, because the buyer must otherwise withhold tax. A cheque for conveyancing money made out to the seller's law firm carries the suffix "-CVY". Where a power of attorney is used, the powers granted are checked. And the client is told the results.

The checklist's own introduction asks buyers' agents to review it before advising clients: it is encouraged, not mandatory. The duty of due diligence in the Code of Ethics applies whether or not the checklist is used.

Tenants: eligibility, passes and the money

A tenant's agent works under the same Code, and several of the 2014 manual's paragraphs are written for leases. The counterparty is verified as the owner, and on a sublet the head lease is checked. For the letting of an HDB flat, paragraphs 2.2.9 and 2.2.10 have the agent check the eligibility of owner and tenant, make sure HDB's approval is in place, explain the terms of the tenancy and have the tenancy agreement stamped. Agents are not to facilitate sublets of HDB rental flats.

A foreign tenant will be asked for original documents. Paragraph 1.6.3 of the manual describes three checks: the original pass is examined, it is cross-checked against the passport and the person, and its validity is verified online with the Immigration and Checkpoints Authority or the Ministry of Manpower. The manual, as issued in 2014, describes failing to carry out all three as an offence punishable with six to 24 months' imprisonment and a fine of up to S$6,000; the figure is the 2014 manual's, was not checked against the statute for this guide and may have changed since.

On money, CEA's consumer page is specific. In HDB rentals an agent must not handle rental deposits or monthly rent, and rent is paid directly to the landlord. There is one reimbursement case that tenants meet: stamp duty on a lease, for private and HDB property alike, which the agent may pay first and then recover, but must not collect before stamping. The manual treats that advance as the single exception to its rule against lending to clients.

Offers, documents and copies

Three of the Code's twelve topics deal with paper: the signing of documents, agreements, and the conveying of offers and counter-offers. The 2014 manual's fourth section sets the handling of offers. Every offer is conveyed accurately, objectively and as soon as possible, in the order received, and none is withheld or screened out (paragraph 4.2.1). All verbal and written offers and expressions of interest are recorded in writing, with the date, the time, the name and number of the person making the offer and the amount; the records are kept for one year and shown on request (paragraph 4.2.2). The agent advises, the client decides, and offers are kept confidential (paragraphs 4.2.3 to 4.2.5).

A buyer sits on the sending end of that rule: the offer reaches a seller's agent who is bound to pass it on in the order received and to record it, even where it is below the seller's expectation.

Documents are explained before they are signed. CEA's consumer page says clients must be given enough time to read forms and must receive copies of all signed documents. The manual adds that the Option to Purchase, the sale and purchase agreement and the tenancy agreement are legal documents: the agent refers the client to a lawyer where uncertain, but still goes through the clauses and highlights the payments and the dates (paragraph 5.1.3). The payment schedule is explained (paragraph 5.1.2), as are the consequences of signing, such as the penalties for not proceeding (paragraph 2.4.1). Each signatory receives a copy immediately or as soon as possible, and documents carry the date on which they were signed (paragraph 5.1.4). An option shows only the mutually agreed price, and documents are neither post-dated nor back-dated (paragraph 2.4.2).

The Code's duties come down to a client who decides with the facts in hand: who is on the other side, what the checks found, and what each paper commits to.

Where the agent's role stops

The Code includes a duty to recommend professional advice where appropriate. The 2014 manual tells agents to advise clients to seek independent advice on matters outside an agent's expertise, naming solicitors, tax advisers and valuers (paragraph 2.1.2). It also draws a line that buyers meet early: an estimate quoted by a bank is not a market valuation, and any valuation cited is identified by its nature and its date (paragraph 2.1.4).

Money marks a second boundary. CEA's consumer page says agents should not handle transaction monies and that doing so is an offence that can lead to prosecution and fines. For a sale and purchase the page lists option fees, option exercise fees, down payments, stamp duties, deposits and sale proceeds, and legal fees. CEA encourages clients to pay each payee directly by verifiable means, such as a bank transfer, PayNow or a crossed cheque, and to pay commission to the agency, not to the individual agent.

Credit marks a third. Agents must not introduce, refer or recommend the services of any moneylender, CEA's page says, and the manual bars inducements in cash or in kind to win an engagement, while noting that lowering the commission is acceptable (paragraph 1.10.1).

Finally, the manual asks for more care with clients it calls vulnerable: those who are impaired, illiterate, in financial distress or without support. The agent considers involving the family and applies no pressure (paragraphs 1.9.1 to 1.9.3).

When the service falls short

CEA's page on dispute resolution encourages a client in dispute with a property agent to approach the agent's agency first. The Code of Practice lists claims and complaints among the matters each agency must provide for.

If that does not settle the matter, the route depends on what went wrong. A disagreement arising from the terms of an estate agency agreement signed with a licensed agency falls under CEA's Dispute Resolution Scheme: mediation, with a centre to be chosen within four weeks of the written request, and arbitration if the dispute is not resolved within six weeks of notice of the first mediation session. CEA states that it does not regulate the centres. A client who signed no agreement is outside the scheme as the page describes it.

Conduct is a different matter from money. A failure to observe the Code of Ethics may lead to disciplinary action by CEA or a Disciplinary Committee, CEA's codes page says, and the manual may be referred to in those proceedings. That is why the records described above matter to a client: the written disclosure of a conflict, the copy of the title search, the dated documents and the one-year record of offers are the papers against which an agent's conduct can later be read.

Some points stay open on the pages read for this guide. They list the Code's topics without paragraph numbers, they do not describe what the estate agent card shows, and they give no penalty amounts for acting for both sides or for handling transaction monies. The manual is dated 1 January 2014, and the pages do not say whether a later version replaces it.

Kooky, from Shaka

Kooky edits Agents Estate and builds Shaka, the payment router he made for real estate professionals. One payment comes in, and every agent, agency and party in the deal receives their signed share on closing date.

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