"By Right No — But If You Go By Left, Who Would Know?"

The most quietly devastating line in CNA's report is not the one about going "by left". It is a senior agent explaining why he would help.

"I think it's common, and will be very easy for senior agents to just park a few deals under them," he said — adding that sellers may not care whose name a transaction is recorded under once the deal itself is done.

Then: "I'm not sure whether everyone will be helping, but I'm sure it's very easy to help them. There's no incentive not to help."

That is the whole problem in seven words. A team leader who does forty deals a year loses nothing by lodging one small one under a quiet team member's name. The team member keeps their licence and stays on the roster. The relationship is preserved. Nobody in the room is worse off.

The only party with an interest in this not happening is the consumer, who is not in the room.

The rule is straightforward. To renew, a salesperson needs at least three transactions over a three-year registration cycle — an average of one a year — or must pass a refresher examination instead.

CEA has built in accommodations. Newly registered agents are not required to complete any transactions in their first year; from the second year they need at least two over the remaining two years, or the exam. Agents unable to meet the requirement because of extenuating circumstances — serious medical issues, or complex transactions that legitimately take longer — may be considered for waivers case by case. Further details of the refresher exam, which CEA has said will focus on practice-related knowledge essential for conducting estate agency work, are expected by the first half of 2029.

The intent is a floor, not a cull. A licensed professional should have done the job at least occasionally.

What CNA has surfaced is that the floor is measured in a unit — a lodged transaction — that can be transferred between people who agree to transfer it.

The reporting quotes a senior agent saying it would be "very easy" to clock three transactions over three years, and that he did not know of any agent who would need help. That is a reasonable view from the top of the market. It is not what the roster looks like.

We hold the CEA salesperson roster joined to our own record of transactions, so we counted how many deals each agent has in the trailing three years — the same window length the rule uses.

17,633 agents — 46.1% of the 38,217 on the roster — sit below three transactions in three years. 12,182, or 31.9%, have no recorded transaction at all in that window. At the other end, 6,792 agents did twenty-five or more.

That distribution is the story. This is not an industry with a thin tail of inactive members. It is an industry where roughly one in three registered salespersons has not visibly transacted in three years, sitting alongside a top group doing volume that would be a full career for someone else.

It also lines up with what CEA has said about itself. Its 2024 Public Perception Survey found about 40% of agents do not complete even one transaction a year — measured differently, from a different source, and landing in the same place.

Two problems compound here.

The first is what counts. In our own data a transaction is a transaction, whether it is a room rental worth a few hundred dollars a month or a landed sale worth several million. The part-time agent in CNA's report went straight to that: a small deal, a room rental, and "you got one count already". A bar defined by count is cleared most cheaply at the bottom of the market.

The second is who counts. CEA's position is clear — the transaction should be lodged by "the property agent on each side of a transaction who interacted directly with the client and undertook most of the estate agency work", and submitting false or misleading information is an offence.

The agents CNA spoke to did not dispute the rule. They disputed that it is provable. Multiple people work a listing; teams contain senior and junior members; an agent who lodged a deal can say they contributed marketing ideas. One suggested that a co-operating inactive agent should "at least show up once or twice so that the client knows" — a description of how to manufacture the appearance of involvement, offered by someone who said he would not do it himself.

There is a real cost to the borrower, and it is worth noting because it is the only genuine brake in the system: the commission gets lodged under the inactive agent's name, so they carry the income tax on it. As one agent put it, an inactive agent has to weigh whether it is worth paying more income tax just to maintain the licence — and he expected most would eventually drop out anyway.

A rule whose main enforcement mechanism is that cheating is mildly tax-inefficient is not a strong rule.

Days before CNA's report, The Straits Times ran a forum letter arguing that transaction numbers alone may not be the best measure of property agents' competence.

Put the two pieces together and you get a fairly complete critique. The forum letter says a count is the wrong measure. The CNA reporting says a count is the wrong unit, because it can be moved between people. Same rule, attacked from opposite ends, and both attacks land.

One of the agents CNA spoke to offered an alternative: require a minimum income instead of a minimum number of transactions, on the view that it would be harder to circumvent. That is not obviously right either — commission can be split and re-attributed too, and an income floor would penalise agents working the affordable end of the market hardest, which is not who anyone is worried about.

But it points at the real difficulty. Any measurable proxy for "is this person actually practising" can be satisfied by arrangement between two willing people. The only measure that cannot be lent is the one nobody has proposed: whether the agent can demonstrate current competence. Which is, in fairness, precisely what the refresher examination is supposed to be.

The rule exists because consumers reasonably assume a registered agent is a practising one. CEA's own survey found three in four consumers expect at least one transaction a year from their agent.

If an agent maintains registration on a deal someone else did, the licence stops carrying that information. It still tells you they passed an examination once and complete their annual training hours. It no longer tells you they have recently handled a transaction like yours.

The practical response is not to become suspicious of every agent. It is to stop treating registration as a proxy for experience and ask the direct question instead: how many transactions have you personally closed in the last twelve months, and how many were in this segment — this town, this flat type, this price band?

An active agent answers that instantly. It is a fair question, and the answer is more informative than any registration status.

This is a slow-moving change, which is part of why the workaround conversation is happening now rather than later.

Registrations are moving from one-year to three-year validity, and the transaction requirement is assessed over that three-year cycle. Newly registered agents complete no transactions in their first year; from their second year they need at least two over the remaining two years, or the exam.

CEA has said further details of the refresher examination will be announced by the first half of 2029. One senior agent told CNA he assumed passing it would not be easy — which, if true, is the design working: the exam is meant to be the harder path, so that transacting is the natural one.

The practical effect is a long runway during which quiet agents decide whether to get active, sit an exam, arrange a favour, or leave. On our numbers, that decision is in front of a very large number of people.

Everything about the rule and the behaviour — the three-transaction requirement, the refresher examination alternative, the first-year exemption for new agents, the two-transactions-over-two-years position from year two, the case-by-case waivers, the first-half-of-2029 timeline for exam details, CEA's statement on who should lodge a transaction and that false or misleading submissions are an offence, and every quoted agent — comes from CNA's reporting, linked below. The competence-measurement argument comes from a Straits Times forum letter. Those are the reporters' and correspondents' facts, attributed rather than claimed as ours.

The distribution is ours: the CEA salesperson roster as we hold it, joined to our own transaction record, counted by trailing three-year deal count. 38,217 salespersons, bucketed as shown.

The caveats are in the reality-check section above and they matter — chiefly that our transaction record is not CEA's, which makes the 46.1% an upper bound, and that the trailing window is not aligned to any individual agent's registration cycle. We publish aggregate distributions only: no individual agent is identified and no agent earnings are shown.

The news:

• CNA — Property agents may 'borrow' transactions to meet new requirement for registration renewal, despite the rules, 10 August 2026.
• The Straits Times — Forum: Transaction numbers alone may not be best measure of property agents' competence, 6 August 2026.

The data:

• PropKaki — the CEA salesperson roster joined to our transaction record, counted by trailing three-year deal count. Aggregate distribution only.

Related:

• Three Deals in Three Years: Singapore Just Put a Floor Under Its Property Agents — our commentary on the rule itself.

This is commentary by the PropKaki Editorial Desk on reporting by CNA and a forum letter published by The Straits Times. The quotes and the account of what agents described belong to those newsrooms; the roster analysis, the framing and the opinions are ours.

To be explicit about something this piece could easily be misread on: we are not alleging that any identified agent has done anything improper. The practices described are ones agents described to a newsroom, in general terms, and the agents quoted were describing what is possible — one expressly said he would not do it. Our own data shows how many agents sit below a threshold; it shows nothing whatsoever about whether any of them has borrowed a transaction, and we would not publish that if it did.

It is opinion and general information, not legal, financial or career advice. Agents with questions about their own renewal position should work from CEA's published requirements.

Published 12 August 2026.