Country-specific guidance Current

ACRA's register of registrable controllers requirement explained

A private register with its own filing clock, not a one-off form.

Since 31 March 2017, most Singapore companies, foreign companies registered here, and limited liability partnerships have had to keep a register of registrable controllers. This guide sets out what that requirement covers and what it means for a firm verifying a corporate client. It is general information, not legal or compliance advice.

Action plan

1 Know which entities must maintain a register of registrable controllers The requirement is broad, and dormancy or winding up doesn't remove it.

Companies (private and public), foreign companies registered in Singapore, and limited liability partnerships must establish and maintain a register of registrable controllers (RORC), even if the entity is dormant or being wound up. A small set of entities, such as listed public companies and Singapore financial institutions, are exempt but must still notify ACRA of that exemption.

  • Treat companies, registered foreign companies, and LLPs as generally in scope
  • Don't assume dormancy or winding up removes the requirement
  • Check exemption status specifically rather than assuming an entity type is automatically exempt

Done when: The entity's obligation to maintain an RORC, or its specific exemption, has been confirmed rather than assumed

ACRA: setting up and maintaining a register of registrable controllers
2 Know what makes someone a registrable controller Ownership and control are tested separately, and either one is enough on its own.

A registrable controller is an individual or legal entity with a significant interest in, or significant control over, the entity. Significant interest generally means an interest in more than 25 per cent of shares. Significant control generally means the right to appoint or remove a majority of directors, or the right to exercise, or the actual exercise of, significant influence or control.

  • Apply the more-than-25-per-cent share interest test
  • Apply the right to appoint or remove a majority of directors test
  • Apply the significant influence or control test even where the first two tests aren't met

Done when: Controllers were identified against all three limbs of the registrable controller test

ACRA: maintaining registers
3 Know the filing clock, and treat a stale register as a red flag The private register and the central filing with ACRA run on different, short clocks.

A company's private RORC must be updated within seven days of a controller notifying a change, with the corresponding lodgment to ACRA's central register made within two business days of that update. Entities incorporated or registered from 16 June 2025 must set up their RORC on the same day as incorporation or registration. A client company that can't describe this process is worth asking further questions about.

  • Expect a seven-day private-register update clock from notification of a change
  • Expect a two-business-day central lodgment clock from the private-register update
  • Treat an entity that can't explain its own RORC process as needing closer follow-up

Done when: The client company's own RORC filing practice was checked against these timeframes, not assumed to be compliant

See requesting beneficial ownership information from a corporate client