RORC and beneficial-owner register under CSP Act 2024 — Timeline and processing benchmarks

Raffles Corporate Services works with a panel of corporate and employment law firms; this article is general information, not legal advice.

This guide to rorc and beneficial-owner register under csp act 2024 sets out the practical detail Singapore businesses need. The Register of Registrable Controllers (RORC) and the beneficial-owner framework require most Singapore companies to identify and record the individuals who ultimately own or control them. Since the Corporate Service Providers Act 2024 reforms, this information is lodged with ACRA’s central register, and a company must keep its own RORC up to date within statutory deadlines.

Understanding Rorc and beneficial-owner register under csp act 2024

The sections below break down rorc and beneficial-owner register under csp act 2024 step by step, covering what it is, who it applies to, the numbers that matter, the process, and the mistakes practitioners see most often.

What the RORC and beneficial-owner register are

A registrable controller is an individual or legal entity with a significant interest in, or significant control over, a company, typically a holding of more than 25 per cent of shares or voting rights, or the ability to control the composition of the board. The Companies Act 1967 requires companies to keep a Register of Registrable Controllers identifying these persons. The Corporate Service Providers Act 2024 strengthened the framework and reinforced lodgement of controller information with ACRA’s central register.

For a related perspective, see Singapore Corporate Tax 2026: A Complete Guide to Rates, Exemptions and Filing.

Who must keep a RORC

Most companies and limited liability partnerships incorporated or registered in Singapore must maintain a RORC unless they fall within a specific exemption, such as certain listed entities and government bodies. The obligation applies from incorporation, and the company must take reasonable steps to identify its controllers and give notice to any person it believes to be a controller.

See also our guide on RORC and beneficial-owner register under CSP Act 2024 — Costs and fees breakdown.

Timelines and deadlines

See the numerical block below. A newly incorporated company must set up its RORC within 30 days of incorporation, and update it within specified periods after becoming aware of a change. Information is also lodged with ACRA’s central register, and changes must be reflected promptly to keep the two consistent.

Related reading: EntrePass Singapore 2026: A Founder’s Complete Walkthrough.

How to identify and record a controller

The process runs: (1) analyse the ownership and control structure, looking through nominee and intermediate holdings; (2) issue notices to suspected controllers requiring confirmation; (3) record the required particulars in the RORC; (4) lodge the information with ACRA’s central register; and (5) review at least annually and whenever the structure changes.

Common mistakes and gotchas

Frequent errors include treating a corporate shareholder as the controller rather than looking through to the ultimate individual, missing the update deadlines when shares change hands, and failing to reconcile the company’s own RORC with the ACRA central register. Companies with layered or foreign holding structures should document the look-through analysis to evidence that reasonable steps were taken.

What particulars must be recorded

For each individual controller, the register records the full name, aliases, residential address, nationality, identity document number, date of becoming a controller and the nature of control. For a corporate controller, the register records the corporate name, registration number, registered office, legal form and governing law. Keeping these particulars accurate is as important as identifying the controllers in the first place, because ACRA’s central register must mirror the company’s own records.

How the CSP Act 2024 changed the framework

The Corporate Service Providers Act 2024 formed part of a broader tightening of Singapore’s beneficial-ownership transparency regime. It reinforced the obligation to lodge and maintain controller information centrally with ACRA and raised expectations of the corporate service providers who administer these registers for their clients. Companies that previously kept only an internal register should confirm their central-register lodgements are complete and current, as the two must remain consistent.

Enforcement and penalties

Failing to keep a RORC, to take reasonable steps to identify controllers, or to lodge and update central-register information is an offence that can attract financial penalties for the company and its officers. Beyond the legal exposure, gaps in beneficial-ownership records can delay bank account opening, audits and transactions, because counterparties increasingly require clean controller documentation as part of their own due diligence.

How Raffles Corporate Services can help

As experienced corporate secretarial practitioners, we set up and maintain the Register of Registrable Controllers, run the look-through analysis for layered structures, issue the required controller notices, and keep the ACRA central register aligned with the company’s own records.

Deadlines and thresholds at a glance

  • Significant interest threshold: generally more than 25% of shares or voting rights.
  • Set-up deadline: within 30 days of incorporation.
  • Update deadline: within the statutory period after the company becomes aware of a change.
  • Central register: controller information lodged with and kept current at ACRA.
  • Penalties: non-compliance is an offence attracting fines.

Official sources

FAQs

Is the RORC public?
The company’s own RORC is not public, but controller information lodged with ACRA’s central register is accessible to public agencies for administration and enforcement.

What if no individual meets the threshold?
The company must still keep a RORC and record the position, including where control is exercised through other means or where no registrable controller can be identified after reasonable steps.

Who can keep the register for us?
A registered corporate service provider or company secretary can maintain the RORC and handle lodgements on the company’s behalf.

Does a dormant company need a RORC?
Yes. The obligation applies regardless of activity unless a specific exemption applies.

Related guides

Need help with this? Call, SMS or WhatsApp +65 8501 7133, or email [email protected]. Raffles Corporate Services works with a panel of corporate and employment law firms; this article is general information, not legal advice.