Singapore has long been regarded as one of the world’s most trusted business hubs, and that reputation depends in no small part on robust corporate transparency measures. Among the most important of these is the Register of Registrable Controllers (RORC) — a statutory register designed to identify the ultimate beneficial owners, or “controllers”, behind every Singapore company, foreign company, and Limited Liability Partnership (LLP).

First introduced in March 2017, the RORC framework has been steadily strengthened. From June 2025 onwards, new companies are required to lodge their RORC information with ACRA simultaneously with incorporation. With ACRA intensifying enforcement in 2026, companies with outdated or missing RORC entries now face real penalties.

Whether your company was incorporated recently or years ago, understanding and maintaining your RORC is a non-negotiable compliance obligation. This guide explains everything you need to know.

What Is the Register of Registrable Controllers (RORC)?

The RORC is a statutory register that identifies the ultimate beneficial owners — or controllers — of a Singapore company, foreign company, or LLP. It was introduced under Part VIA of the Companies Act (Cap. 50) as part of Singapore’s commitment to international standards on anti-money laundering (AML) and counter-financing of terrorism (CFT), aligned with the Financial Action Task Force (FATF) recommendations.

The key distinction between the RORC and the Register of Members — which records the legal shareholders of a company — is that the RORC looks through corporate or nominee structures to identify the natural persons who ultimately own or exercise control over the entity. Complex ownership structures involving holding companies, trusts, or nominee arrangements can obscure who truly benefits from or controls a business. The RORC is designed to cut through this opacity.

Who Is a Registrable Controller?

Under the Companies Act, a registrable controller is broadly any individual — or, in certain cases, a legal entity — that has either a significant interest or significant control in the company.

Significant Interest

A person has a significant interest if they hold, directly or indirectly:

  • More than 25% of the total votes attached to all voting shares;
  • More than 25% of the total issued share capital; or
  • An entitlement to receive more than 25% of the company’s distributions (e.g. dividends).

Significant Control

A person has significant control if they have the ability to:

  • Appoint or remove a majority of the board of directors;
  • Exercise dominant influence or control over the management of the entity; or
  • Otherwise be the ultimate controller of the entity through a chain of ownership or control.

Where a company has a complex ownership structure with multiple layers — for example, a holding company that is itself majority-owned by an individual — it is necessary to look through the chain to identify the individual at the apex of control.

If, after conducting reasonable due diligence, no registrable controllers can be identified (for instance, in widely dispersed shareholding structures), the company should document this finding. The absence of identifiable controllers does not remove the RORC obligation — it must still be documented and records maintained.

The Two-Tier Structure: Private RORC and Central RORC

The RORC regime operates on two levels, and both must be actively maintained.

Private RORC

This is the internal register that every company must maintain at its registered office, or at the office of its registered filing agent (typically your corporate secretarial firm). It must be kept in English and must contain the full particulars of each registrable controller, including:

  • Full legal name and NRIC/FIN/passport number;
  • Nationality and residential address;
  • The nature and extent of the controller’s interest or control;
  • The date on which the person became a registrable controller; and
  • The date on which the person ceased to be a registrable controller, if applicable.

Central RORC (Lodged with ACRA)

Since 30 July 2020, all companies and LLPs have been required to lodge their RORC information with ACRA’s central register via the BizFile+ portal. ACRA, law enforcement agencies, and other authorised parties can access this centralised data. While the general public does not have unrestricted access, this central filing ensures that beneficial ownership information is available to the relevant regulatory authorities at all times.

Our article on the BizFile+ eServices portal provides further guidance on navigating ACRA’s digital filing platform.

Updated Requirements Since June 2025

The most significant update to the RORC regime came into effect from 16 June 2025, when ACRA significantly tightened the filing timeline for newly incorporated entities:

  • For companies incorporated on or after 24 November 2025: RORC information must be filed simultaneously with the incorporation application itself, using the “Register New Business Entity” eService on BizFile+. There is no separate step — the company is registered and the RORC is filed at the same time.
  • For companies incorporated between 16 June 2025 and 23 November 2025: RORC information should have been lodged on the same date as incorporation approval, using the “Update Register of Registrable Controller” eService on BizFile+.

For existing companies incorporated before June 2025, the obligation to maintain and update the RORC continues. Any changes to a controller’s particulars must be:

  1. Updated in the private RORC within 7 days of the company being informed of the change; and
  2. Lodged with ACRA via BizFile+ within 2 business days of updating the private RORC.

There is no fee payable to ACRA for lodging RORC information.

Annual Notice Obligation

Maintaining the RORC is not a one-time task — it requires active, ongoing management. At least once per year, every company must send a written notice to every person it believes to be a registrable controller, requesting them to confirm whether:

  • Their particulars as recorded in the RORC are still accurate; and
  • They are still a registrable controller of the company.

Controllers are legally required to respond within 30 days. If they report a change, the company must update its private RORC within 7 days and then lodge the updated information with ACRA within a further 2 business days.

This annual notice obligation is often overlooked, particularly in smaller companies where the same individuals serve as both shareholders and directors. However, non-compliance carries penalty risk regardless of company size or structure.

Who Is Exempt from the RORC Requirement?

Certain entities are exempt from the requirement to maintain a RORC and lodge information with ACRA. These generally include:

  • Companies listed on the Singapore Exchange (SGX) or a recognised foreign exchange;
  • Wholly-owned subsidiaries of such listed companies (where the listed company itself is the controller);
  • Entities regulated by the Monetary Authority of Singapore (MAS) under certain legislation; and
  • Certain government entities and statutory bodies.

Even if your company qualifies for an exemption, it is strongly advisable to document the basis for the exemption and retain that record in your company’s statutory files. Where there is doubt about whether an exemption applies, seek advice from a qualified company secretary.

Penalties for Non-Compliance

ACRA takes RORC non-compliance seriously, and its enforcement approach has become increasingly automated and progressive in 2026. The informal grace periods that companies may have relied on in earlier years are no longer available. The penalties under the Companies Act are as follows:

Breach Penalty
Failure to maintain a private RORC Up to S$5,000 per breach
Failure to send annual notices to controllers Up to S$5,000 per breach
Failure to update RORC within required timeframes Up to S$5,000 per breach
Failure to lodge with ACRA’s central RORC Up to S$25,000 upon conviction
Lodging false or misleading RORC information Up to S$25,000 upon conviction
Failure by a controller to respond to a notice Up to S$5,000

Companies with outdated or missing RORC entries are at real risk of enforcement action in 2026. ACRA’s enhanced framework means that compliance failures are identified systematically, not just through tip-offs or targeted audits.

The Role of Your Corporate Secretary

Keeping your company’s statutory registers — including the RORC — in good order is a core function of good corporate governance, and is one of the key duties that falls within the remit of a qualified company secretary. In practical terms, a corporate secretarial firm will:

  • Set up your RORC correctly at the time of incorporation;
  • Send annual notices to registrable controllers and follow up on responses;
  • Update the private RORC promptly when ownership or control changes;
  • Lodge changes with ACRA via BizFile+ within the required 2-business-day window;
  • Maintain records of all RORC notices and responses; and
  • Advise on complex ownership structures, including nominee arrangements and multi-tier holding companies.

For a full overview of what corporate secretarial services typically cover, see our article on routine secretarial services.

What to Do If Your RORC Is Not in Order

If you realise that your company’s RORC is out of date, has never been properly set up, or has not been lodged with ACRA’s central register, you should act promptly. ACRA generally takes a more favourable view of companies that proactively rectify their records than those discovered to be non-compliant during enforcement checks.

The steps to take are:

  1. Identify all current registrable controllers based on your company’s current shareholding and control structure.
  2. Gather the required particulars for each controller.
  3. Update the private RORC with accurate and complete information.
  4. Lodge the correct information with ACRA via BizFile+ without further delay.
  5. Engage your corporate secretary to establish a process for future annual notices and timely updates whenever ownership or control changes occur.

It is also worth reviewing your RORC after any corporate event that changes ownership or control — such as a share transfer, allotment of new shares, change of directors, or restructuring. These events may give rise to new registrable controllers or result in existing controllers losing their registrable status.

Conclusion

The Register of Registrable Controllers is one of Singapore’s most important mechanisms for ensuring corporate transparency and preventing the misuse of companies for financial crime. With requirements tightened from June 2025 and ACRA’s enforcement framework becoming more rigorous in 2026, compliance with the RORC regime is more critical than ever for every Singapore company, foreign company, and LLP.

If you are unsure whether your company’s RORC is accurate and up to date, or if you need assistance setting up your RORC correctly — whether at incorporation or as part of an ongoing compliance review — Raffles Corporate Services can help. Our team of qualified corporate secretaries will ensure your statutory registers are maintained in full compliance with the Companies Act and ACRA’s requirements. Contact us today at Raffles Corporate Services.

— The Editorial Team, Raffles Corporate Services