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The register of members lists the shareholders of a Singapore company, with the shares each one holds. A local company's version is electronic and sits on ACRA's Bizfile. It updates when you file a share issue or transfer, and the company must put changes in within 14 days.
Checked against ACRA's registers guidance and company type pages.
What is the register of members?
Under the Companies Act, shareholders are called members. The register is the proof of who they are. ACRA names the electronic version the Electronic Register of Members, or EROM, for local companies. For foreign companies the matching record is a public register of members.
A secondary source we read says sections 196A to 196D of the Act govern the electronic register. We could not open the statute to confirm, so check those sections on Singapore Statutes Online if you need the legal wording.
What does the register show?
ACRA's pages treat the register as the place stakeholders look to verify a company. At minimum you should expect to see each member and the shares they hold. For the legal rules on who may hold shares and in what form, read the shareholder requirements.
How do you keep it up to date?
ACRA's rule covers every electronic register: update any change within 14 days. Share events that trigger a filing include:
| Event | Where to start |
|---|---|
| New shares issued | Issue new shares |
| Shares sold or gifted | Transfer shares |
| A member changes name or address | File the change on Bizfile |
| Registers kept away from the registered office | Update the registers address on Bizfile |
When the register is stored away from the registered office, ACRA tells companies to update the registers address on Bizfile, so a reader knows where to look.
Who can read it?
The public can read all registers except the register of registrable controllers and the nominee registers. A Business Profile, which costs S$5.50, includes the owners alongside the position holders. See our business profile guide.
What are the member limits?
The number of members depends on company type.
| Company type | Member limit |
|---|---|
| Exempt private company | 20 individuals |
| Private company limited by shares | Up to 50 |
| Public company limited by shares | No limit |
The shareholder cap for a private company is also reflected in Bizfile: it warns when a private company goes above 50. The full set of company types is in company types in Singapore.
How is it different from the register of controllers?
They answer different questions. The register of members says who is on the share record. The register of registrable controllers says who has significant interest in or control over the company, which can include people behind a nominee or a holding structure. Nominee shareholders, who vote or take dividends for someone else, must also be recorded in a separate private register. Our registrable controllers guide explains the timelines for those.
A founder who holds shares through a nominee, for example, will appear on neither the public members list nor the register of directors, but should appear as a controller. That is why the controllers register matters.
What are the common mistakes?
Owners sell shares with a signed form but never file the update. A company issues shares to a new investor and forgets to add them. Or the register address changes and the Bizfile record stays old. Each leaves the public record wrong, and a wrong record can slow a bank account, a loan or a sale.
Where does the secretary come in?
Updating the registers is normal secretary work. See what a corporate secretary does. If you want a provider to maintain the records, use the quote form on this page. We are an independent guide, not ACRA, and may earn a referral fee when a request becomes a client.
Sources
- ACRA, maintaining company registers: https://www.acra.gov.sg/how-to-guides/setting-up-a-local-company/maintaining-company-registers (EROM, deadlines, nominee registers).
- ACRA, company registers: https://www.acra.gov.sg/manage/companies/legal-requirements-common-offences/maintaining-local-companys-information-registers/company-registers/ (14 days, public access).
- ACRA, choosing a company type: https://www.acra.gov.sg/register/business/registering-different-business-structures/local-company/choosing-a-company-type/ (member limits).
- ACRA, updating an entity's information: https://www.acra.gov.sg/resources/guides-forms/updating-entitys-information (registers address update).
- ACRA, types of information products: https://www.acra.gov.sg/resources/buying-business-information/types-of-acra-information-products/ (Business Profile fee).
