Do nominee directors have to disclose who they represent?

Depends entirely on jurisdiction. In the UK, nominee directors are still directors, so their name goes on the public register. But the PSC register requires disclosing the beneficial owner separately. The nominee doesn't "represent" in a legal sense—they're just a warm body.

Short answer: no, the nominee director doesn't have to publicly announce who they're a nominee for. But that doesn't mean the info stays hidden from the government. Anti-money laundering rules usually force disclosure to the registrar or a central database, just not to the general public.

following. also curious if this changes for LLCs vs corporations.

Nominee directors are a joke in most common law countries. You're on thee hook for fiduciary duties but you're just a puppet. And yes, you usually have to signn something saying who you're acting for—but that document isn't filed publicly. It sits in a drawer somewhere until a regulator asks for it.

That's not quite right. In the UK, the PSC register requires the company to identify anyone with significant control. The nominee director isn't the one disclosing—the company is. The nominee just has to not lie about it if asked.

I looked into this for a Wyoming LLC. The registered agent has to know the beneficial owner, and the nominee director (if you use one) usually signs an agreement that discloses the principal to the agent. But Wyoming doesn't have a public beneficial ownership registry, so it never sees the light of day. Not legal advice, obviously.

"Duty to disclose" usually means to the company or the court, not to the world. If you're trying to staay private, the real risk isn't the nominee—it's the registered agent getting subpoenaed or a data leak. Nominee directors are just one layer.

So basically the nominee director is a speed bump, not a wall.

Speed bump is generous. In some places they're legally required to disclose to the registry but the registry doesn't publish it. So it's a speed bump with a private filing cabinet.

OP, that lawyer was probably talking about the nominee's duty to the company—if there's a conflict of interest, they have to disclose who they're acting for to the board. Not to the public. There's a big difference between "disclose" and "publish."

Also worth noting: some jurisdictions (looking at you, Delaware) don't even require nominee disclosure to the state. It's all contractual. So "have to" depends on where you incorporate.