Every Singapore company is required by law to keep a set of statutory registers. They are not optional, and they are not just paperwork — they are the legal record of who owns the company, who controls it, who runs it, and whose interests touch the share capital. ACRA, IRAS, banks and any potential investor will look at these registers before they look at anything else.
This guide walks through each statutory register a Singapore company must maintain in 2026 — what it contains, where it lives, who can inspect it, and the penalties for getting it wrong.
Why Statutory Registers Matter
Sections 386A to 386AG of the Companies Act 1967 set out the registers every company must keep, and what each must contain. Some are kept by the company; others are maintained centrally by ACRA on BizFile+; one — the Register of Registrable Controllers — is private but must be produced to authorised officers on demand.
Getting these wrong creates real exposure: ACRA fines, banking onboarding delays, audit qualifications, and (in the worst case) personal liability for directors and the company secretary under section 386AC.
The Full List of Statutory Registers
| Register | Statute | Maintained By | Public? |
|---|---|---|---|
| Register of Members (Shareholders) | s.190 | ACRA (electronic) | Yes |
| Register of Directors | s.173 | ACRA + company | Yes |
| Register of Director’s Shareholdings | s.164 | Company | Yes (to members) |
| Register of Secretaries | s.173A | ACRA | Yes |
| Register of Auditors | — | ACRA | Yes |
| Register of Charges | s.131 / s.137 | ACRA | Yes |
| Register of Registrable Controllers (RORC) | s.386AB–AF | Company (private) | No — restricted access |
| Register of Nominee Directors | s.386AG | Company (private) | No |
| Register of Nominee Shareholders | s.386AH | Company (private) | No |
| Minutes Book(s) | s.188 | Company | Members |
Register-by-Register Walkthrough
1. Register of Members (Section 190)
The official record of every shareholder of the company. Must contain:
- Member’s name, address and NRIC / passport (for individuals) or UEN (for corporates).
- Date the person became a member, and date they ceased.
- Number, class and identifying numbers of shares held.
- Amount paid up on the shares.
For Singapore private companies, this register is held electronically by ACRA — every share transfer, allotment and cancellation flows through BizFile+. The company’s own records must reconcile to ACRA’s.
Filings tie back to our guides on transferring shares and issuing new shares.
2. Register of Directors (Section 173)
Records every director: name, NRIC / passport, residential address, nationality, date of appointment and date of cessation. ACRA mirrors this. Any change must be filed within 14 days under section 173(1A).
Remember the resident director requirement under section 145 — at least one director must ordinarily reside in Singapore.
3. Register of Director’s Shareholdings (Section 164)
Records every director’s interest in the company’s shares, debentures and related corporate interests, plus any change in those interests. The register must be kept at the registered office (or wherever the company secretary keeps the books) and updated within 2 business days of notification.
Members are entitled to inspect it free of charge during business hours.
4. Register of Secretaries (Section 173A)
Records the appointment and cessation of every company secretary. The Section 171 secretary requirement — every Singapore company must appoint a secretary within 6 months of incorporation — feeds into this register.
5. Register of Charges (Section 131, Section 137)
Records every charge created over company property — debentures, mortgages, fixed and floating charges. Each charge must be lodged with ACRA within 30 days of creation. Failure to lodge means the charge is void against a liquidator and other creditors. Lenders take this seriously.
6. Register of Registrable Controllers (Sections 386AB to 386AF)
The RORC identifies the beneficial owners and individuals exercising significant control over the company. Every company (with limited exceptions) must maintain it. We’ve done a full deep dive in our RORC compliance guide.
Key points:
- The RORC is private — not publicly searchable. ACRA holds a copy on BizFile but it is restricted.
- Every individual or corporate controller with 25% or more voting / share / management control must be entered.
- The register must be updated within 2 business days of the company knowing of any change.
- Failure to maintain or update attracts fines up to S$5,000 per offence under section 386AF.
7. Register of Nominee Directors (Section 386AG)
Every nominee director must be recorded in this register, along with the identity of the person on whose behalf they act. It is private — only ACRA and authorised law enforcement can inspect.
8. Register of Nominee Shareholders (Section 386AH)
Where a shareholder holds shares as nominee for another person, that nominee relationship must be recorded. The register is private.
9. Minutes Books (Section 188)
Every company must keep minutes of:
- All general meetings of members.
- All directors’ meetings.
- All resolutions passed in writing (members’ written resolutions and directors’ written resolutions).
Minutes must be entered within one month of the meeting or resolution. They must be signed by the chair of the meeting (or, for written resolutions, by the directors or members as appropriate).
Members can inspect minutes of general meetings. They cannot inspect board minutes unless allowed by the constitution. Our board resolutions guide covers the mechanics in detail.
Where Must the Registers Be Kept?
The default location is the company’s registered office. The company can elect to keep the registers at another place in Singapore (typically the corporate secretary’s office) but must lodge a Notice of Place of Records under section 158 with ACRA within 7 days of the change.
Electronic records are acceptable, provided they can be reproduced in legible form and are reasonably accessible. Most outsourced corporate secretaries maintain registers electronically on platforms like BoardRoom, Tricor or in-house systems, with PDF outputs available on demand.
Inspection Rights — Who Can See What?
| Register | Members | Public | Authorities |
|---|---|---|---|
| Register of Members | Free | Via BizFile (paid) | Yes |
| Register of Directors | Free | Via BizFile (paid) | Yes |
| Register of Director’s Shareholdings | Free during business hours | No | Yes |
| Register of Charges | Free | Via BizFile (paid) | Yes |
| Minutes of general meetings | Yes | No | Yes |
| Minutes of board meetings | Only if constitution allows | No | Yes (with order) |
| RORC, Nominee Director / Shareholder registers | No | No | Yes (ACRA, MAS, IRAS, CAD, etc.) |
Penalties for Non-Compliance
The Companies Act takes register maintenance seriously. Common offences and penalties:
- Failure to keep the register of members or directors — fine up to S$5,000.
- Failure to maintain the RORC — fine up to S$5,000 per offence under section 386AF, with further fines for continuing offences.
- Failure to lodge a Notice of Place of Records — fine up to S$2,500.
- Late filing of register changes (directors, secretary, share transactions) — composition fees plus late filing penalties via ACRA’s standard schedule.
Beyond fines, ACRA’s enforcement page notes that persistent non-compliance can lead to director disqualification proceedings, particularly where multiple companies under the same directors share the pattern.
Practical Compliance Checklist
- ✅ Registered office address is current at ACRA, and notices can be received there.
- ✅ Register of Members reconciled to BizFile every quarter.
- ✅ Every director and secretary change filed within 14 days.
- ✅ Every share allotment, transfer, sub-division or consolidation lodged with ACRA promptly.
- ✅ RORC updated within 2 business days of any change in beneficial ownership.
- ✅ Nominee director / nominee shareholder registers maintained if applicable.
- ✅ Board and shareholder minutes signed and filed within one month of each meeting.
- ✅ Register of Charges accurately reflects all bank facilities and security.
- ✅ Annual review by the company secretary before the AGM and annual return.
FAQ
Are my old paper registers still valid? Yes, provided they are accurate and ACRA mirrors them. Most companies migrate to electronic registers when they switch corporate secretarial providers.
What happens if I lose my registers? The company secretary must reconstruct them from ACRA records, prior filings, and meeting minutes. Document the reconstruction process. Repeated loss can attract regulatory scrutiny.
Can I keep the registers overseas? No. Statutory registers must be kept in Singapore. Cloud-hosted on a Singapore-based platform is fine; physical records overseas are not.
Do I need to maintain registers if my company is dormant? Yes. Dormancy doesn’t suspend statutory register obligations. The data may be static, but the registers must exist and be available.
Who is liable if the registers are not maintained? The company, every director, and the secretary. Section 386AC is explicit that the company secretary shares the obligation.
How Raffles Corporate Services Can Help
Maintaining all of the above is exactly what a competent company secretary is for. We hold and maintain the full statutory register set for every client company, reconcile to ACRA quarterly, run the RORC update protocol on every change of ownership, and produce certified extracts when banks, investors or auditors ask. Our compliance calendar flags every filing deadline and our pre-AGM checklist catches any register drift before the auditor does.
If your company secretary cannot produce a clean register set within an hour of being asked, that is itself a red flag worth addressing.
— The Editorial Team, Raffles Corporate Services