RORC and beneficial-owner register under CSP Act 2024 — Documents required and templates

The RORC and beneficial-owner register under CSP Act 2024 refers to the Register of Registrable Controllers every Singapore company must maintain, and the strengthened beneficial-ownership obligations that accompany the Corporate Service Providers Act 2024. This guide explains who is a registrable controller, what must be recorded, the documents required and the templates directors and company secretaries need in 2026.

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

What the RORC and beneficial-owner register under CSP Act 2024 is

Every Singapore company and LLP must keep a Register of Registrable Controllers (RORC) identifying the individuals or entities with significant control or ownership. The RORC regime sits within the Companies Act 1967 (introduced by amendment) and must also be lodged centrally with ACRA. The Corporate Service Providers Act 2024 reinforced this framework by tightening the obligations of corporate service providers who assist companies with beneficial-ownership information and anti-money-laundering checks.

The policy aim is transparency: authorities and gatekeepers should be able to see who ultimately owns and controls a company, so the register is now a front-line compliance document rather than a formality.

Who is a registrable controller

A registrable controller is broadly an individual or legal entity that holds more than 25% of the shares or voting rights, has the right to appoint or remove a majority of directors, or otherwise exercises significant influence or control over the company. Where control is held through a chain of entities, the analysis follows the chain to the ultimate controller.

The company must take reasonable steps to identify its controllers, send notices to obtain the required particulars, and record and update the information. The register must be kept at the registered office or the office of the corporate service provider.

Documents and particulars required

For each registrable controller who is an individual, the register records full name, aliases, residential address, nationality, identification details and the date they became a controller. For a corporate controller, it records the entity name, registration number, registered office and legal form. Supporting documents include the notices sent to and replies from controllers, and the underlying identification evidence gathered during due diligence.

Templates to keep ready are the controller identification notice, the reply form, the RORC itself and a change-of-controller update log. The company secretary’s wider statutory duties, including maintaining statutory registers, are set out in our note on the company secretary’s statutory duties under the Companies Act.

Timelines, updates and ACRA lodgement

A company must set up its RORC within 30 days of incorporation and lodge the information with ACRA’s central register, updating both within two business days of becoming aware of any change. Failure to maintain or lodge the register is an offence carrying financial penalties for the company and its officers.

Because the CSP Act 2024 raised expectations on service providers, expect your corporate secretary to request refreshed identification and source-of-wealth information periodically, not only at onboarding.

Common mistakes and gotchas

Frequent failures are treating the RORC as a one-off setup task, missing the two-day update window when shareholdings change, failing to look through nominee or trust arrangements to the true controller, and not lodging with ACRA’s central register. High-net-worth and family-office structures often involve layered ownership that demands careful look-through analysis; our note on multi-jurisdiction family office structures illustrates the point.

Families relocating with dependants should also keep immigration records consistent with declared control; see our guide to the Dependant Pass and Long-Term Visit Pass.

Step-by-step process

  1. Within 30 days of incorporation, take reasonable steps to identify all registrable controllers.
  2. Send controller identification notices and record the particulars received.
  3. Set up the Register of Registrable Controllers at the registered office or the corporate service provider’s office.
  4. Lodge the controller information with ACRA’s central register.
  5. Refresh identification and source-of-wealth information as expected under the Corporate Service Providers Act 2024.
  6. On any change of control, update both the company register and the ACRA central register within two business days.
  7. Retain notices, replies and identification evidence to support the register.

FAQs

Who must keep a Register of Registrable Controllers?
Every Singapore company and LLP, unless specifically exempted, must maintain a RORC and lodge the information with ACRA’s central register. The register must be set up within 30 days of incorporation.

How quickly must the RORC be updated after a change?
The company must update its own register and the ACRA central register within two business days of becoming aware of a relevant change to its controllers.

What did the Corporate Service Providers Act 2024 change?
It strengthened the anti-money-laundering and beneficial-ownership obligations of corporate service providers and reinforced the framework for accurate, current controller information, increasing the diligence expected at onboarding and on an ongoing basis.

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.