Last updated
A registrable controller is anyone with significant interest in, or significant control over, your Singapore company. You record them in a private register called the RORC, and since you also file the same details to ACRA's central register. Both steps have short deadlines.
Checked against ACRA's RORC guidance pages.
What is the Register of Registrable Controllers?
The RORC is a private register of the real people, or sometimes entities, who stand behind or direct the company. It exists so that the authorities can trace who stands behind a company even when the shares sit with a nominee or another company. ACRA says the requirement applies to companies, foreign companies and LLPs, unless exempt.
The public can see most company registers, but not this one. The register is kept at your registered office address or at your corporate service provider's office. A copy of the details also goes to ACRA's Central RORC, held by ACRA. For the public registers, see the register of members and register of directors.
Who counts as a registrable controller?
ACRA's page uses two phrases: significant interest in the business, meaning ownership, and significant control over the business. It does not print a percentage on that page. Our research found sites quoting different thresholds, so we do not give one number. Ask your corporate secretary to apply ACRA's detailed guidance and the statute to your structure, especially if shares pass through holding companies, trusts or nominees.
Three cases deserve attention:
- A shareholder who owns shares through another company.
- A person who controls decisions without owning many shares, for example through a veto.
- A nominee arrangement. The nominator, not the nominee, is the person to look for. The nominee director guide explains related duties.
What must the register contain?
ACRA lists the particulars to record.
| Controller | Particulars |
|---|---|
| Individual | Full name, aliases, residential address, email, contact number, nationality, ID or passport number, date of birth, date became a controller, date ceased |
| Corporate | Name, entity number, registered office address, email, contact number, legal form, jurisdiction of formation, registrar name, registration number, dates |
Keep the supporting evidence with the register, such as the controller's confirmation of their details.
What are the deadlines?
| Step | Deadline stated by ACRA |
|---|---|
| Set up the RORC | On the same day, for entities registered from |
| Update the private register | Within 7 days after the controller tells you of a change |
| File the update to the Central RORC | Within 2 business days after updating the private register |
| Annual notices to controllers | Once a year, to confirm details |
Companies also have to chase controllers: ACRA expects a company to identify controllers and send annual notices. If a controller does not respond, record what you did and when, and take professional advice.
Who is exempt?
ACRA lists exemptions for listed public companies, Singapore financial institutions, government-owned entities, wholly owned subsidiaries of exempt entities, and some foreign companies that meet transparency standards. Dormant companies and companies in winding up are not exempt. They must keep a RORC too.
What does the RORC have to do with nominees?
Companies must also keep a register of nominee directors, ROND, and a register of nominee shareholders, RONS. ACRA's rule for both is a 7-day update of the private register and a 2 business day central filing for companies registered after . A nominee shareholder who votes or takes dividends for someone else must tell the company on incorporation day or within 30 days of becoming a nominee. The shareholder requirements page has the detail.
What happens if you get it wrong?
ACRA's RORC page, as we read it, does not state penalty amounts, so we do not quote any. The Companies Act deals with the controllers regime and its offences, and the subsidiary regulations include rules on the register of controllers. Read the relevant sections on Singapore Statutes Online, or ask your secretary. See our Companies Act guide.
Who should do this?
Most companies give the job to their company secretary, who tracks the 7-day and 2-business-day clocks. A simple habit helps: whenever shares move, ask whether a controller changed. For the secretary's wider role, see what a corporate secretary does.
Want a provider to maintain the RORC?
If you would like quotes from Singapore providers, 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, Register of Registrable Controllers: https://www.acra.gov.sg/manage/companies/legal-requirements-common-offences/maintaining-local-companys-information-registers/rorc/ (who must keep a RORC).
- ACRA, setting up and maintaining a RORC: https://www.acra.gov.sg/manage/companies/legal-requirements-common-offences/maintaining-local-companys-information-registers/rorc/setting-up-maintaining/ (timelines, particulars, exemptions).
- ACRA, filing with the Central RORC: https://www.acra.gov.sg/manage/companies/legal-requirements-common-offences/maintaining-local-companys-information-registers/rorc/central-rorc/ (central filing within 2 business days).
- ACRA, company registers: https://www.acra.gov.sg/manage/companies/legal-requirements-common-offences/maintaining-local-companys-information-registers/company-registers/ (which registers are public, where private registers are kept).
- ACRA, ROND and RONS: https://www.acra.gov.sg/manage/companies/legal-requirements-common-offences/maintaining-local-companys-information-registers/rond-rons/setting-up-maintaining/ (nominee registers and the 30-day disclosure).
