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Rehabilitation guidelines
Learn about CEA's fit and proper criteria for real estate salespersons and estate agents, rehabilitation guidelines, and assessment factors.
Last updated 19 August 2025
Fit and proper criterion
Under Section 3(2) of the Estate Agents Act 2010 (EAA), the Council for Estate Agencies (CEA) may determine that a person is not "fit and proper" after considering relevant facts or matters, including statutory presumptions.
A person is presumed not "fit and proper" if they:
Have been convicted of an offence involving dishonesty or fraud
Have had a civil judgement entered against them involving fraud, dishonesty or breach of fiduciary duties
Have been convicted of any offence under the EAA
Are an undischarged bankrupt, in liquidation, or have made a composition or arrangement with creditors
The assessment extends beyond these criteria. We will consider all relevant facts and circumstances that may affect a person's suitability to hold a real estate salesperson (RES) registration or estate agent's (EA) licence, including:
Criminal convictions under any law
Civil judgements
Enforcement or regulatory actions by CEA or other regulatory or enforcement bodies
Other pertinent facts or circumstances, even without formal legal proceedings
If we determine a person is not "fit and proper", we may revoke or suspend their RES registration or EA licence under Sections 54 and 55 of the EAA, and reject renewal applications for subsequent registration or licence periods
Rehabilitation
Rehabilitation refers to the process for individuals deemed not “fit and proper” to reflect, change, and improve to ensure that they pose no risk to consumers upon returning to estate agency work.
For consumer protection, we will verify that all applicants are fit and proper before granting RES registration or EA licences, as per Section 3(2) of the EAA. Applicants deemed to be not fit and proper must demonstrate sufficient rehabilitation before consideration for registration or licensing.
CEA evaluates rehabilitation based on three key factors:
Time factor – Adequate time must pass between the conviction/ decision date and new application. This is to allow for meaningful rehabilitation.
Make rehabilitation efforts: The applicant must demonstrate active steps toward improvement, such as:
Voluntary participation in counselling or psychiatric treatment
Completion of relevant professional development courses
Engagement in community service or charitable activities
3. Show evidence of remorse: The application must demonstrate sustained good behaviour and remain offence free during the rehabilitation period.
Meeting any or all of the rehabilitation criteria does not guarantee automatic approval. We will evaluate each application holistically based on the prevailing eligibility criteria and the quality and extent of the rehabilitation efforts.
Case examples
Here are some case examples to show how we treat convictions to assess if applicants are “fit and proper”. You may use these examples to determine if you have sufficiently rehabilitated from any offence committed.
We will assess each application based on its own facts and circumstances.
Offences which involve an indicative rehabilitation period of 12 - 18 months
Examples of such offences include, but are not limited to the:
Personal Data Protection Act
Protection from Harassment Act
Road Traffic Act (e.g., driving without a valid licence)
Case example 1
RES A and RES B were convicted of one charge each under Section 267B of the Penal Code 1871 for committing affray and sentenced to a fine of $3,000 each by the State Courts. They were drunk and had intentionally disturbed public peace by fighting in a group with other persons, outside of conducting estate agency work.
CEA found them to be not fit and proper as the offences involved aggression and showed a lack of self-control in public. The inclination to behave in such manner could reasonably undermine the professionalism and reputation of the industry, in particular the need to safeguard public safety and interest.
CEA rejected both their applications to renew their registrations.
Offences which may involve an indicative rehabilitation period of 18 – 36 months
Examples of such offences include, but are not limited to:
Offences under the Estate Agents Act
Offences under other Acts such as the Employment of Foreign Manpower Act, Protection from Harrassment Act and Customs Act
Offences under the Penal Code such as Cheating offences, Voluntarily Causing Hurt, Voyeurism, and Outrage of Modesty
Case example 2
RES C was convicted of one charge under Section 148(2) of Women’s Charter, two charges under Section 9(1)(d) and one charge under Section 9(1)(a) of Remote Gambling Act 2014. RES C was sentenced to a total fine of $63,000 and 18 months’ imprisonment by the State Courts for these offences.
RES C represented a tenant and found a property in Geylang which the tenant was keen on. The tenant asked RES C to rent the premises on his behalf, claiming he would sublet to work permit holders and would pay him a monthly fee of $1,000 for his assistance. RES C agreed and the tenancy agreement was signed.
Shortly after, the tenant confessed to RES C that he was using the premises as a brothel. RES C did not report this to the authorities and instead renewed the tenancy of the unit for another year for the operation of vice activities within the unit.
In the course of investigations, RES C was also found to have been involved in illegal remote gambling. The total value of the illegal bets placed was over $1.3 million.
RES C’s scant regard for the law undermines the professionalism and reputation of the industry, in particular, the need to safeguard public law and order. The offence under the Women’s Charter involved vice and was conducted in the course of estate agency work. In addition, RES C facilitated the exchange of over $1.3 million in illegal bets, which is a considerable sum in relation to his misconduct.
CEA revoked RES C’s registration after he was convicted and sentenced by the Courts.
Frequently asked questions
Here are some frequently asked questions on the rehabilitation guidelines.
1. Does the fit and proper criteria only refer to what is set out in Section 3(2)(a)(i) to (iv) of the EAA?
No. Sections (3)(2)(a)(i) to (iv) of the EAA provides four presumptions where an individual is deemed by the EAA as being not “fit and proper”. Apart from this list, we will consider all other relevant facts and matters when determining if an individual is “fit and proper”.
2. What are the other relevant facts or matters which CEA uses to determine if an individual is fit and proper?
We will consider the relevance of any offence or misconduct to estate agency work, and if there is any disregard for the law (especially laws related to property transactions). We take a firm stance towards errant RESs regardless of whether the offence is committed in a professional or personal capacity. Other than convictions or legal proceedings, there may also be other facts and circumstances which, when considered holistically, render a person to be not “fit and proper”.
3. How does CEA assess if there is sufficient rehabilitation for an applicant?
We assess if there is sufficient rehabilitation based on the facts and circumstances of each case. Where an individual is assessed to be not “fit and proper” in light of convictions or other misconduct, we will take into account the severity, intent, and consequence of the offences or relevant acts, as well as taking reference from other similar cases where appropriate.
4. Can I apply to register at any time? Do I have to do anything during the rehabilitation to prove that I am sufficiently rehabilitated?
Yes, you may apply for registration/ licence at any point in time if you feel that you have been sufficiently rehabilitated. However, you will have to show that you are sufficiently rehabilitated and provide supporting information and documents to demonstrate this. We will assess your application based on the facts and circumstances involved to determine if you are fit and proper to be registered/ licenced.
Please note that all other prevailing criteria for registration/ licensing must also be satisfied.
5. Can I appeal against CEA’s decision?
Yes. You may submit an appeal for us to reconsider its decision within 14 days after being notified of our decision to reject your registration/ licensing application or renewal, or to revoke or suspend your registration/ licence.
Alternatively, you may lodge an appeal with the Ministry of National Development (MND) Appeals Board.