Is the Register of Company Controllers publicly accessible?

No. Both the internal Register of Registrable Controllers and the central register are not publicly accessible. They may be inspected only by the Accounting and Corporate Regulatory Authority and other authorised public agencies.

What is the difference between the internal register and the central register?

The internal register is maintained by the company at its registered office or at the office of its registered filing agent. The central register is maintained by ACRA, and companies must submit controller information electronically via BizFile+. Both registers must be maintained in parallel.

When must controller information be updated?

Controller particulars must be entered in the internal register within seven days after confirmation. The updated information must then be submitted to ACRA within two business days after the internal register is updated.

What happens if a controller does not respond to a notice?

If a controller fails to respond, the company must still enter the controller in the internal register and note that the particulars have not been confirmed. The company must then submit the information to ACRA after the statutory waiting period.

What is the penalty for non-compliance?

Failure to maintain the register, identify controllers, or submit required information may result in a fine of up to S$5,000. Controllers who fail to respond to notices or provide false information may also be liable.

Register of Company Controllers in Singapore

Q: Who qualifies as a controller of a Singapore company?

A controller is an individual or entity that has significant interest or significant control over a company. Significant interest generally means holding more than 25% of shares, voting power, or profit or capital entitlement. Significant control may exist even without shareholding, for example through the right to appoint directors or influence key company decisions.

Last Updated: Feb 2026

Under the Companies Act, Singapore companies must identify controllers, maintain an internal Register of Company Controllers, and submit prescribed information to the central register administered by the Accounting and Corporate Regulatory Authority. These obligations apply from incorporation and continue throughout the company’s lifecycle. This register ensures that Singapore authorities have access to accurate information about the individuals and entities that ultimately own or control companies.

This guide explains who qualifies as a controller, what information must be recorded, and how companies can comply with both internal and central register requirements.

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Key Takeaways

Companies must create an internal Register of Company Controllers and submit controller information to ACRA at the time of incorporation. After incorporation, companies must maintain and keep the register up to date.

Controller particulars must be entered in the internal register within seven days of confirmation and submitted to ACRA within two business days after the internal update.

A controller is an individual or entity with significant interest or significant control, including indirect or contractual control.

Significant interest means more than 25% of shares, voting power, or profit or capital entitlement.

Significant control includes the right or ability to influence or determine key company decisions.

Companies must take reasonable steps to identify controllers and issue statutory notices at least once per calendar year.

What Is a Register of Company Controllers?

A Register of Company Controllers is a statutory register that records individuals and entities that have significant interest or significant control over a Singapore company. Its purpose is to enhance transparency of company ownership and control and to support anti-money laundering and counter-terrorism financing measures.

Singapore companies are subject to a dual obligation:

To maintain an internal Register of Company Controllers, also referred to as the Register of Registrable Controllers (RORC); and
To submit controller information to the central register maintained by the Accounting and Corporate Regulatory Authority, known as the Central Register of Registrable Controllers (central RORC).

Both obligations apply concurrently and are ongoing.

What Is an Internal Register of Company Controllers?

The Internal Register of Company Controllers is a private statutory register that must be maintained by the company itself. Key points:

It is not publicly accessible.
It must be kept either at the company’s registered office or at the office of its registered filing agent.
It must be available for inspection by ACRA and other authorised Singapore government authorities upon request.
The register must be created at the time of company registration and kept up to date throughout the company’s existence, including during dormancy, winding up, or striking off processes.

The internal register records detailed particulars of all registrable controllers, including individuals and corporate entities, as prescribed under the Companies Act.

What Is a Central Register of Company Controllers?

In addition to maintaining an internal register, companies are required to submit controller information to the central Register of Company Controllers administered by ACRA. Key points:

The central register is not public and is accessible only to ACRA and authorised public agencies.
Controller information is submitted electronically via BizFile+.
Companies must lodge controller information when a controller is added and submit updates whenever there is a relevant change.
Filing with the central register does not replace the obligation to maintain an internal register. Both must be maintained in parallel.

This requirement ensures that Singapore authorities have timely access to accurate information on company ownership and control, even though such information is not available to the general public.

Who Is Considered a Controller?

Under the Companies Act, a controller is an individual or entity that has significant interest or significant control over a company. A person may qualify as a controller even if they are not a shareholder or do not hold a majority ownership stake. The assessment is substance based and looks at actual ownership, voting rights, and control arrangements, rather than formal titles alone.

Controllers by Significant Interest

An individual or entity is considered to have significant interest in a company where prescribed ownership or economic thresholds are met. For companies with share capital, significant interest exists where an individual or entity:

Directly or indirectly holds more than 25% of the issued shares in the company; or
Directly or indirectly holds shares carrying more than 25% of the total voting power in the company.

For companies without share capital, significant interest exists where an individual or entity holds the right to receive more than 25% of the company’s profits or capital. Ownership may be held directly or indirectly, including through nominees, trusts, or intermediate entities.

Controllers by Significant Control

An individual or entity is considered to have significant control over a company if they have the ability to influence or determine key decisions of the company, even without meeting the ownership thresholds for significant interest. Significant control exists where an individual or entity satisfies one or more of the following conditions.

1. Right to appoint or remove directors

An individual or entity has the right to appoint or remove directors who hold a majority of voting rights at directors’ meetings.

Example: An individual holds only 5% of the shares in a company but is granted the right under the company’s constitution to appoint or remove directors. That individual exercises significant control and is a controller.

2. Voting rights on members’ reserved matters

An individual or entity holds more than 25% of the rights to vote on matters that must be decided by the members of the company, such as changes to the constitution or appointment of directors.

Example: A shareholder holds 10% of the issued shares but has 25% of the voting rights on matters reserved for members under the constitution. Despite the minority shareholding, the shareholder is considered a controller.

3. Significant influence or control without shareholding

An individual or entity has the right to exercise, or actually exercises, significant influence or control over the company’s management or policies.

Example: A former founder no longer holds shares in the company but retains contractual rights to approve the company’s business plan and appointment of the chief executive officer. The former founder exercises significant influence and is a controller.

clarifying about singapore Register of Company Controllers

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Who Are the Exempt Controllers?

In general, any individual or entity that qualifies as a controller must be entered in the Register of Company Controllers. However, the Companies Act recognises certain situations where a controller is treated as exempt and does not need to be separately recorded in the register. A controller is considered exempt if any one of the following conditions applies.

1. Controller through another registrable controller

An individual is exempt if they have significant interest or significant control in the company only through another registrable controller that is already recorded in the register.

Example: An individual controls a company indirectly through a holding company that is already recorded as a corporate controller. The individual does not need to be separately entered as a controller.

2. Controller through an exempt company

A company is exempt if it is a controller through a local or foreign company that is itself exempt from maintaining a Register of Company Controllers. This typically applies where the controlling company is subject to equivalent transparency and disclosure requirements under Singapore law or foreign law.

3. Controller through a company required to maintain its own register

A company is exempt if it is a controller through a local or foreign company that is required to maintain its own Register of Company Controllers or an equivalent register. In such cases, transparency is achieved through the upstream entity’s compliance obligations, and duplicative registration is not required.

What Information Is Required in the Register?

Companies are required to record specific prescribed particulars of each registrable controller in both the internal Register of Company Controllers and the central register. The information must be accurate, complete, and kept up to date. The required particulars differ depending on whether the controller is an individual or a corporate entity.

For each registrable corporate controller, the following particulars must be entered in the register:

Name;
Unique entity number, if any;
Address of registered office;
Email address;
Contact number;
Legal form of the corporate controller;
Jurisdiction where the corporate controller is formed or incorporated and under which law;
Name of the authority with which the corporate controller is formed or incorporated, if applicable;
Identification number or registration number issued to the corporate controller upon formation or incorporation, if applicable;
Date of becoming a controller; and
Date of cessation as a controller, if applicable.

Identifying Controllers

Companies must take reasonable steps to identify and obtain information on all registrable controllers. This obligation applies on incorporation and on an ongoing basis.

Duty to Take Reasonable Steps

A company is regarded as having taken reasonable steps if it issues statutory notices to obtain and confirm controller information.

Reasonable steps include:

Sending notices to persons known, or reasonably believed, to be controllers;
Sending notices to persons likely to know the identity of a controller; and
Reviewing ownership, voting rights, and control arrangements.

Notices may be sent electronically or in hard copy in the prescribed format.

Persons to Whom Notices Must Be Sent

At a minimum, notices must be sent to:

All directors;
All shareholders; and
Any nominee directors, if appointed.

Notices must also be sent to any other person reasonably believed to be a controller or to have knowledge of a controller.

Annual Notice Requirement

Companies must send notices at least once per calendar year to verify controller information.

Recipients are required to:

Confirm whether they are a controller; and
Confirm whether there are any changes to controller particulars or identities.

This annual verification supports the accuracy of both the internal register and the central register.

Responding to Notices

Persons who receive a statutory notice are required to respond accurately and within the prescribed timeframe. The response obligations differ depending on whether the notice is sent to a controller or to a person who may know the identity of a controller.

Obligations of Controllers

A controller who receives a notice is required to:

State whether they are a controller of the company;
Confirm or provide the prescribed particulars required for the register; and
State whether they know of any other individual or entity who is a controller of the company.

If the controller is aware of any changes to their particulars, these must be disclosed in the response.

Obligations of Persons Who Know of Controllers

A person who receives a notice because they are believed to know the identity of a controller is required to:

State whether they know, or have reasonable grounds to believe they know, the identity of a controller; and
Provide the prescribed particulars of that controller, to the extent known.

When Notices Are Not Required

A company is not required to send a notice where:

The controller or relevant person has already provided accurate and complete particulars; or
The company has reasonable grounds to believe that the person is neither a controller nor has knowledge of any controller.

In such cases, the company should retain records supporting its assessment.

Adding Controllers to the Register

Once a controller has been identified, the company must enter the controller’s particulars in the internal register and submit the information to the central register within the prescribed timelines.

When Controller Particulars Are Considered Confirmed?

Controller particulars are considered confirmed when:

The controller responds to a statutory notice confirming their status and providing the required particulars; or
The controller or their authorised filing agent provides the required particulars directly to the company.

Timeline for Internal Register Updates

A company must enter a controller’s particulars in its internal Register of Registrable Controllers within seven days after the particulars are confirmed.

Timeline for Central Register Filings

After updating the internal register, the company must submit the corresponding controller information to the central register within two business days. The same timelines apply to any subsequent changes to controller particulars.

Non-Responsive Controllers

If a controller does not respond to a statutory notice:

The company must still enter the controller in the internal register, noting that the particulars have not been confirmed; and
The company must submit the information to the central register within two business days after 30 days from the date the notice was sent.

Incorrect Particulars Provided by Controllers

A company will not be held liable where a controller provides incorrect particulars in response to a notice, provided the company has acted in good faith and taken reasonable steps to obtain accurate information.

Foreign Entity Controllers

Where a controller is a foreign entity, the company must take reasonable steps to identify and record the prescribed particulars of that entity based on available information in the relevant foreign jurisdiction.

Statement Where There Are No Registrable Controllers

If a company knows or has reasonable grounds to believe that it has no registrable controllers, it may enter the following statement in its register:

“As at [date], the company knows or has reasonable grounds to believe that there are no registrable controllers in relation to the company.”

Keeping the Register of Company Controllers Up to Date

Companies are required to keep the Register of Registrable Controllers accurate and current at all times. This obligation applies to both the internal register and the central register.

Annual Verification of Controller Information

At least once every calendar year, companies must send notices to all registrable controllers to verify whether their particulars remain accurate.

If a controller confirms that there are no changes, no update to the registers is required. If a change is identified, the company must update the internal register and submit the change to the central register within the prescribed timelines.

What Constitutes a Relevant Change?

A relevant change includes any change that affects the accuracy of information recorded in the register, including:

Changes to a controller’s particulars;
A controller ceasing to be a controller; or
A new individual or entity becoming a controller.

Additional Situations Requiring Notices

Apart from annual verification, a company must send a notice to a controller where:

The company knows, or has reasonable grounds to believe, that a relevant change has occurred; or
The company receives credible information indicating that a relevant change has occurred.

Situations Where Notices Are Not Required

A company is not required to send a notice where:

The controller has already provided updated and accurate particulars; or
The company has verified and documented that no relevant change has occurred.

In such cases, the company should retain records supporting its conclusion.

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Penalties and Enforcement

Failure to comply with the Register of Registrable Controllers requirements may result in a fine of up to S$5,000.

Penalties may apply where a company fails to:

Maintain an internal register;
Take reasonable steps to identify controllers;
Keep the register up to date; or
Submit required information to the central register within the prescribed timelines.

Controllers or other persons who fail to respond to notices or provide false information may also be liable.

Practical Compliance Tips

Here are some practical compliance tips from CorporateServices.com to ensure ongoing compliance with the Register of Registrable Controllers requirements:

Review shareholding and control structures carefully, including indirect and nominee arrangements;
Document the basis on which a person is determined to be, or not to be, a controller;
Maintain clear records of all notices sent and responses received;
Monitor changes in shareholding, voting rights, and control agreements promptly;
Align internal register updates with central register filings to avoid missed deadlines; and
Conduct the annual verification process even where no changes are expected.

Companies with nominee shareholders or layered ownership structures should pay particular attention to identifying ultimate controllers and keeping records up to date.

Where there is uncertainty, seeking professional advice may help reduce compliance risk.

Business consultants advising on nuances of the Register of Company Controllers in Singapore

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Author

Eddy Putra

Eddy has been in the corporate services industry for over 20 years. An experienced Chartered Accountant and alumnus of Deloitte Singapore, he has extensive expertise in corporate finance, tax, structuring, and regulatory compliance. Eddy specializes in advising global clients on business expansion and corporate migration to Singapore.