Every Singapore company is required by law to keep a set of statutory registers — internal records that track the company’s ownership, leadership and control. These registers are not optional, and ACRA has steadily tightened the disclosure regime over the last decade, most recently through the Companies Act 1967 amendments and the Register of Registrable Controllers regime.
This 2026 guide walks Singapore company directors and secretaries through the three core statutory registers — the Register of Members, the Register of Directors, and the Register of Registrable Controllers — what they must contain, where they must be kept, and how to keep them audit-ready.
Why Statutory Registers Matter
Statutory registers serve two purposes. First, they are evidence: the register of members is, under Section 195A of the Companies Act, prima facie evidence of who holds shares in the company. Second, they are a compliance trigger: failure to maintain a register accurately exposes the company and its officers to fines and, in serious cases, prosecution under the Companies Act.
In practice, statutory registers also matter for routine business — banks open corporate accounts only after reviewing the registers, prospective investors rely on them for due diligence, and ACRA requests them during enforcement reviews.
Register of Members
What it must contain
Section 190 of the Companies Act requires the register of members of a Singapore private company to be kept at ACRA’s Electronic Register of Members (eROM). For public companies, the company itself must maintain its own register.
For a private company, ACRA’s eROM is updated automatically whenever a transaction is filed via BizFile+ — for instance, when shares are allotted or transferred. The required particulars include:
- Full name and address of each member.
- Number, class and identifying numbers of shares held.
- Amount paid or agreed to be paid on each share.
- Date the person became, and ceased to be, a member.
Practical points
Even though ACRA maintains the eROM for private companies, the company should keep its own up-to-date record at the registered office. This is essential when (a) the company is issuing share certificates, (b) declaring dividends and verifying who is entitled, and (c) responding to share-related enquiries from members or banks. A clean internal register also makes stamp duty filings simpler.
Register of Directors, Secretaries, Auditors, CEOs and Managers
Section 173 of the Companies Act requires every Singapore company to maintain a register of its directors, secretaries, auditors, CEOs and managers. Unlike the register of members, this is kept by the company itself at its registered office (or such other place notified to ACRA).
For each officer, the register must record:
- Full name and any former names.
- Identification number (NRIC or passport).
- Nationality.
- Usual residential address (a service address may be substituted under Section 173B).
- Date of appointment and date of cessation.
- Business occupation and any other directorships held (Section 173(2)(c) requires disclosure of other Singapore directorships).
Each entry must be updated within 14 days of any change. Officers must give the company the necessary particulars; failure to do so is itself an offence under Section 173(5).
Register of Registrable Controllers (RORC)
The RORC is the most recent addition to the statutory registers regime. Introduced in 2017 and significantly strengthened in 2020 and 2024, the RORC implements Singapore’s anti-money-laundering and counter-terrorism financing obligations under FATF guidance.
Under Sections 386AB and following of the Companies Act, every Singapore company (and every Singapore LLP) must maintain a register of its registrable controllers. A registrable controller is generally:
- An individual who directly or indirectly holds more than 25% of the shares or voting power, or who has the right to appoint or remove directors holding a majority of voting rights, or who otherwise exercises significant control.
- A corporate entity meeting the same thresholds.
What the RORC must contain
For each registrable controller, the company must record:
- Full name, aliases and former names.
- Residential address.
- Nationality.
- NRIC or passport number.
- Date of birth.
- Date the person became / ceased to be a registrable controller.
- The nature of the control held.
Since the Corporate Service Providers Act 2024 came into force, the obligation to verify and update controller information has been reinforced — corporate service providers must take reasonable steps to confirm the data provided by their clients before lodging it with ACRA.
Lodging RORC information with ACRA
From 30 July 2020, companies have also been required to lodge their RORC information centrally with ACRA, in addition to keeping the register at the registered office. Updates must be made within 2 business days of any change taking effect.
Register of Nominee Directors
Section 386AJ of the Companies Act requires companies that have nominee directors to maintain a separate register identifying each nominee, the person on whose behalf they act, and the nature of the nomination. Many practitioners overlook this register entirely.
If your company uses any form of nominee director arrangement, this register is mandatory and must be lodged with ACRA in addition to being kept at the registered office.
Penalties for Non-Compliance
Failure to maintain accurate statutory registers attracts financial penalties and, in serious cases, criminal liability for the company and its officers:
- Register of directors (Section 173): Fine up to S$5,000 per officer in default.
- RORC (Section 386AC): Fine up to S$5,000.
- Register of nominee directors (Section 386AJ): Fine up to S$5,000.
- Persistent or willful failure can result in director disqualification under Section 155 (three or more compliance defaults in 5 years).
Beyond fines, an incomplete register can derail a deal: banks have refused to open accounts, auditors have qualified opinions, and acquirers have insisted on indemnities for the cost of reconstructing missing records.
Practical Tips for Keeping Registers Audit-Ready
- Maintain the registers in a structured digital format with version control. A spreadsheet or company secretarial software is far more reliable than ad hoc Word files.
- Reconcile registers after every transaction: every allotment, transfer, change of director or change in controller should trigger an immediate update.
- Synchronise with ACRA’s records: print the BizFile+ business profile periodically and reconcile against your internal registers.
- Engage a qualified corporate secretary to take responsibility for register maintenance. The Companies Act imposes strict liability — outsourcing the function does not transfer the legal duty, but a competent corporate secretary will keep you on the right side of it.
How Raffles Corporate Services Helps
Maintaining accurate statutory registers is core corporate secretarial work — and it is what we do every day. We set up new companies with the registers in good order from day one, reconstruct registers for companies that have fallen behind, and we lodge all required updates with ACRA within the statutory deadlines. If your company has recently changed hands, restructured, or is approaching a transaction, send us your registers for a free health check.
— The Editorial Team, Raffles Corporate Services