RORC and beneficial-owner register under CSP Act 2024 — Costs and fees breakdown

The RORC and beneficial-owner register under CSP Act 2024 are the transparency obligations requiring Singapore companies to maintain registers of registrable controllers and to lodge that information with ACRA. This guide explains who must keep them, the deadlines, the penalties, and the costs in Singapore dollars as at June 2026.

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

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

The Register of Registrable Controllers (RORC) records the individuals or entities with significant control or ownership of a company, typically those holding more than 25% of shares or voting rights, or who exercise significant influence. Companies must maintain the RORC and lodge its contents with ACRA’s central register. The Corporate Service Providers Act 2024 reinforced this regime, raising standards for corporate service providers and strengthening beneficial-ownership transparency in line with international anti-money-laundering expectations.

The substantive controller obligations sit in the Companies Act 1967, while the Corporate Service Providers Act 2024 introduced a dedicated licensing and conduct framework for service providers who assist with these filings.

Who must keep these registers

Most Singapore companies and limited liability partnerships must maintain a RORC, with limited exemptions (for example, certain listed and regulated entities). Beneficial-ownership information must be kept accurate and lodged with ACRA. Companies that engage a corporate service provider should confirm the provider is licensed under the Corporate Service Providers Act 2024. The company secretary’s role in maintaining these registers is covered in our company secretary statutory duties guide.

Requirements, deadlines and penalties

A company must set up its RORC within 30 days of incorporation, take reasonable steps to identify controllers, and update the register within prescribed periods when changes occur. Information must be lodged with ACRA’s central register and kept current. Failure to maintain a RORC or to lodge accurate information can attract financial penalties and, for the new service-provider regime, regulatory action against the provider. The CSP Act 2024 also introduced obligations around nominee director arrangements.

Costs and timeline

Indicative figures: maintaining the RORC is usually bundled into a company-secretarial retainer; standalone setup or remediation typically costs S$150 to S$500. Lodgement with ACRA’s central register carries no separate government fee in the ordinary course. Where controller analysis is complex (layered ownership, trusts or foreign entities), advisory work can run S$800 to S$2,500. Initial setup is required within 30 days of incorporation, and updates within 2 to 30 days depending on the change.

Step-by-step compliance process

Identify all registrable controllers, including indirect holders through intermediate entities. Send notices to suspected controllers requiring confirmation. Record the required particulars in the RORC. Lodge the information with ACRA’s central register. Keep the register at the registered office or with the licensed corporate service provider, and update it whenever ownership or control changes. Foreign-owned structures should be cross-checked against the Singapore Pte Ltd registration for foreigners requirements, and group tax positions against Section 37C group relief.

Common mistakes and gotchas

The most common failings are not setting up the RORC within 30 days, missing indirect controllers in layered structures, failing to issue controller notices, and not updating the register after share transfers. Under the Corporate Service Providers Act 2024, engaging an unlicensed provider is itself a risk. Nominee arrangements now carry additional disclosure expectations that companies often overlook.

Related guides

See company secretary statutory duties under the Companies Act, Singapore Pte Ltd registration for foreigners, and Singapore group relief under Section 37C for related compliance and tax matters.

Authoritative references: ACRA publishes the controller-register and CSP Act requirements, and the Inland Revenue Authority of Singapore addresses related reporting where beneficial ownership affects tax.

FAQs

When must the RORC be set up?
Within 30 days of incorporation, after taking reasonable steps to identify registrable controllers.

Who is a registrable controller?
Generally an individual or entity holding more than 25% of shares or voting rights, or who exercises significant influence or control over the company.

Does the CSP Act 2024 change anything for companies?
It strengthens beneficial-ownership transparency and requires corporate service providers to be licensed, so companies should confirm their provider holds the appropriate licence.

What does RORC maintenance cost?
Usually bundled into a company-secretarial retainer; standalone setup or remediation is typically S$150 to S$500, more where ownership is complex.

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.