NEW - Lodge Registrable Controllers' Information with ACRA

The requirement to maintain register of registrable controllers should not be news to you since this was implemented since 31 March 2017. In fact, your Company, unless exempted, should have set up and maintained a Register of Registrable Controllers (“RORC”) at its registered office address or the registered office address of its appointed corporate secretarial agent.

Just to recap, the RORC is maintained privately by corporate entities (i.e. companies, foreign companies and limited liability partnerships) with information of their controllers i.e. similar to the concept of ultimate beneficial owners. The information maintained in the RORC includes the details of their controllers as well as information on their citizenship for individuals or places of registration in the case of legal corporate entities.

New Requirements with effect from 30 July 2020

The Accounting and Corporate Regulatory Authority (“ACRA”) has implemented a central register of controllers (“Central Register”), as part of its on-going efforts to uphold Singapore’s reputation as a trusted financial hub, and to further enhance the transparency of ownership and control of corporate entities.

The RORC information in ACRA’s Central Register is non-public i.e. it will only be made available to law enforcement agencies for the purpose of administering or enforcing the laws under their purview, for instance, investigation of money laundering offences. Members of the public will not have access to the RORC information in ACRA’s Central Register.

Timeline to lodge with ACRA

With effect from 30 July 2020, the same information that is currently maintained in your Company’s RORC will be required to be lodged with ACRA’s Central Register. This must be done within 30 days from 30 July 2020.

However, as Singapore has just exited the circuit breaker period and to assist corporate entities to ease into the resumption of normal business activities, ACRA will allow corporate entities to file their RORC information with ACRA by 29 September 2020.

Information to lodge with ACRA

As mentioned earlier, the same information that is currently maintained in your Company’s RORC will be required to be lodged with ACRA’s Central Register.

Subsequent updates to your RORC information

A corporate entity, unless exempted, is required to set up its RORC within 30 days after date of incorporation. Thereafter, RORC information should be lodged with ACRA’s Central Register within two business days after RORC has been set up.

If you wish to make subsequent changes to RORC information, you must lodge the change with ACRA within two business days after updating the information on your Company’s RORC. The update can be lodged via BizFile transaction “Update Register of Registrable Controllers”.

Here's a simple diagram to show the timeline of updating RORC with ACRA when there are subsequent changes:

Note: If you wish to check if your Company is exempted from maintaining RORC, check out the list below.

Companies
A company is exempted if it is:

1. a public company which shares are listed for quotation on an approved exchange in Singapore;
2. a company that is a Singapore financial institution;
3. a company that is wholly owned by the Government;
4. a company that is wholly owned by a statutory body established by or under a public Act for a public purpose;
5. a company that is a wholly-owned subsidiary of a company mentioned in sub-paragraph (a), (b), (c) or (d);
6. a company which shares are listed on a securities exchange in a country or territory outside Singapore and which is subject to —

• regulatory disclosure requirements; and
• requirements relating to adequate transparency in respect of its beneficial owners (imposed through stock exchange rules, law or other enforceable means).

1. a foreign company that is a Singapore financial institution;
2. a foreign company that is a wholly-owned subsidiary of a foreign company that is a Singapore financial institution;
3. a foreign company which shares are listed on a securities exchange in a country or territory outside Singapore and which is subject to —
4. regulatory disclosure requirements; and
5. requirements relating to adequate transparency in respect of its beneficial owners (imposed through stock exchange rules, law or other enforceable means)

1. a LLP that is a Singapore financial institution;
2. a LLP which all partners are companies or foreign companies exempted from the requirement to maintain the register of registrable controllers.