Ask any Singapore corporate secretary what separates a well-run company from one that stumbles at its next audit, ACRA filing, or due diligence exercise, and you will hear the same answer: statutory registers. These are the six-plus registers that every Singapore company must maintain under the Companies Act 1967 — from the Register of Members to the Register of Registrable Controllers. Keep them current and your annual filings, share transfers and M&A due diligences are frictionless. Neglect them and even the simplest secretarial task becomes a research project.
Statutory registers are not optional, and they are not just formalities. ACRA can and does inspect them, and directors are personally liable for breaches. Here is the 2026 guide to what every Singapore private company must maintain, where the law lives, and how to keep the registers audit-ready.
The full set of statutory registers
Under the Companies Act 1967, every Singapore company is required to keep the following registers:
- Register of Members (section 190) — every shareholder, their shares held, class of shares, dates of allotment and transfer.
- Register of Directors, Managers, Secretaries and Auditors (section 173) — appointment and cessation details for every officer.
- Register of Directors’ Shareholdings and Interests (section 164) — every director’s beneficial interest in shares of the company or its related corporations.
- Register of Charges (section 138) — every mortgage, charge or debenture created by the company.
- Register of Debenture Holders (section 93) — where the company has issued debentures.
- Register of Registrable Controllers (section 386AF) — the beneficial owners of the company under the anti-money-laundering regime.
- Register of Nominee Directors (section 386AL) — where any director acts as nominee for another party.
Public companies and listed companies have additional registers, but for the typical private limited (Pte Ltd), these seven are the core set.
Register of Members: the most important one
The Register of Members records who owns the company. Section 190(1) requires the register to show, for each member: full name, address, date of entry on the register, date of cessation (if any), number and class of shares held, and dates of any share allotments or transfers. Section 196A further requires the beneficial owner to be identified where the registered holder is a nominee.
Since 2015, the electronic Register of Members maintained by ACRA is the authoritative record for private companies. When you file share transfers or allotments via BizFile+, ACRA’s electronic register updates automatically. Your company’s internal register must be kept consistent with the ACRA record.
Register of Directors, Managers, Secretaries and Auditors
Under section 173, every appointment, cessation, and change of particulars for any director, manager, company secretary or auditor must be entered in the register and lodged with ACRA within 14 days. See our detailed guide on section 173 director changes.
Details required include: full name, NRIC or passport, nationality, residential address, date of appointment, date of cessation (if applicable), and any other directorships (for public companies).
Register of Registrable Controllers (RORC)
Introduced in 2017 under section 386AF, the Register of Registrable Controllers identifies the ultimate beneficial owners of a Singapore company. A “controller” is a person with significant control — generally, an individual who directly or indirectly holds 25% or more of the shares, voting rights, or right to appoint directors, or otherwise exercises significant influence over the company.
The RORC must be maintained at the company’s registered office or with the corporate services provider, and details must also be filed with ACRA’s central RORC (though not publicly viewable). Failure to maintain a RORC is a strict-liability offence — fines of up to S$5,000 per director. This is one of the most audited registers by ACRA.
Register of Charges
Every fixed or floating charge created by a Singapore company must be recorded in the Register of Charges (section 138) and registered with ACRA within 30 days of creation (section 131). Failure to register within 30 days makes the charge void against the liquidator and creditors — a catastrophic outcome for the lender.
The register records: date of creation, amount secured, description of the property charged, and the chargee’s name. See our companion guide on registering charges with ACRA.
Where to keep the registers
Under section 191, registers must be kept at the registered office or at another place notified to ACRA. Increasingly, companies keep electronic registers maintained by their corporate services provider on cloud-based platforms. The Companies Act permits this, provided a printable copy can be produced on demand and access controls are in place.
Members have a statutory right to inspect the Register of Members free of charge (section 192), and any person can inspect on payment of a small fee. The Register of Registrable Controllers is NOT publicly inspectable — only law enforcement and specified authorities can access it.
Common statutory register mistakes
The five errors we see repeatedly: (1) internal register out of sync with ACRA’s electronic register after a share transfer or director change; (2) RORC never updated after a change in beneficial ownership (e.g. a shareholder trust restructures); (3) Register of Charges missing floating charges over inventory or receivables; (4) nominee director status not disclosed in the Register of Nominee Directors; and (5) auditor changes not entered on the register within the statutory 14-day window.
Every one of these is a fine risk under sections 173, 190, or 386AF and is picked up on the first day of an M&A due diligence exercise.
Penalties for non-compliance
ACRA can impose penalties from S$300 for late updating to S$5,000 for RORC failures, plus daily accumulating fines for continuing offences. Directors personally bear the liability under sections 190(5), 173(11) and 386AG. In more serious cases (fraudulent register entries), section 401 makes it a criminal offence punishable by imprisonment.
Best-practice checklist
Run this checklist at least once a quarter: reconcile the internal Register of Members against ACRA’s BizFile+ record; refresh the RORC after any change in beneficial ownership or 25%+ shareholding; update the Register of Charges after any new bank facility or debenture; capture director appointments and cessations within 14 days; verify nominee director disclosures; run an audit trail on register access; and back up the electronic register offsite.
Statutory registers are boring — until they are not. When ACRA inspects, when your AGM approaches, when a buyer runs due diligence, or when a bank asks for KYC on your ultimate beneficial owner, these registers are the first documents opened. Keep them right, and everything else flows. Let them drift and every corporate action becomes an archaeology exercise.
— The Editorial Team, Raffles Corporate Services