These registers catch companies out because the obligation is continuing rather than one-off: identify controllers, send notices, keep the register current, and file changes to the central registers. The rules tightened through 2025 and 2026, including a requirement that nominee director appointments made by way of business be arranged through a registered corporate service provider.
Registrable Controllers and Nominee Registers
RORC, ROND and RONS — registers, notices and central filing
These registers catch companies out because the obligation is continuing rather than one-off: identify controllers, send notices, keep the register current, and file changes to the central registers. The rules tightened through 2025 and 2026, including a requirement that nominee director appointments made by way of business be arranged through a registered corporate service provider.
| Item | Detail |
|---|---|
| Entity | [COMPANY NAME], UEN [UEN] |
| Type | [Local company / Foreign company / Limited liability partnership] |
| Exempt from RORC? | [No / Yes — state the exemption relied on] |
| RORC kept at | [ADDRESS — registered office or the office of a registered filing agent] |
| Person responsible | [NAME], [DESIGNATION] |
| Corporate service provider | [NAME], registered filing agent |
| Last annual verification notices sent | [DATE] |
| Last central register filing | [DATE] |
1. The Three Registers
| Register | What it records | Who must keep it | Central filing |
|---|---|---|---|
| RORC — Register of Registrable Controllers | Individuals and legal entities with significant interest in, or significant control over, the entity | Companies, foreign companies and limited liability partnerships, unless exempt | File and keep updated at the Central RORC |
| ROND — Register of Nominee Directors | Directors who are nominees, and their nominators | Companies | File and keep updated at the Central ROND |
| RONS — Register of Nominee Shareholders | Shareholders who are nominees, and their nominators | Companies | File and keep updated at the Central RONS |
1.1The registers are not public. They must be accurate, current, and available to the authorities and law enforcement on request.
1.2The registers are separate and distinct. A person may appear on more than one, and the definitions differ. Recording a nominee director in the RORC does not discharge the ROND obligation.
2. Who Is a Registrable Controller
2.1A registrable controller is an individual or legal entity that has significant interest in, or significant control over, the entity.
6 more pages in the Word file
This is page 1 of the Word document, exactly as it appears when you open it. Fields shown like THIS are placeholders for you to complete.
These notes accompany the template and explain the drafting choices, the compliance points and the mistakes most often made with this document. They appear as a final page in the Word file, intended to be deleted before the document is executed.
Most breaches arise not because a company never set up the register, but because it set one up and never touched it again. Controllers change, addresses change, and the annual verification notice is due every calendar year. Item 5 of the compliance calendar is the single most commonly missed obligation in this area.
Amendments in force from 2025 require information in these registers to be filed with the authority’s central registers, and kept updated there. Maintaining a beautiful register at the registered office while filing nothing centrally no longer satisfies the requirement. Confirm what has actually been filed, not what has been recorded.
From 9 June 2025, nominee director appointments made by way of business must be arranged through a corporate service provider registered with the authority, and arranging them outside one is an offence carrying a substantial fine. This affects the common arrangement where a foreign-owned company obtains a resident director informally through a contact. Check how any existing nominee arrangement was set up.
Significant interest is tested on direct **and indirect** holdings, including through nominees, trusts and chains of entities. Listing the registered shareholders is not identification of controllers. Where a corporate shareholder is itself owned by individuals, the analysis continues upward until individuals or exempt entities are reached.
A person may be a registrable controller with no shares at all — through a right to appoint or remove a majority of directors, a veto over key decisions, or the ability to direct decisions in practice. Founders who have diluted but retained control rights, and lenders with far-reaching covenants, are the categories most often overlooked.
The obligation is to take reasonable steps. Sending the prescribed notices, and keeping the responses, is what demonstrates that. An entity that "knew" who its controllers were but never issued notices has no evidence of having taken steps, whatever the register says.
Failure to respond without reasonable excuse, or supplying false or misleading information, is an offence by the recipient. Annexure D states this expressly, and stating it materially improves response rates from reluctant recipients.
A nominee director appears in the ROND. A nominee shareholder appears in the RONS. A controller appears in the RORC. The definitions differ and one entry does not satisfy another obligation. Companies with a nominee arrangement frequently maintain one register and assume it covers the position.
Certain entities are exempt from the RORC — listed companies, Singapore financial institutions, entities wholly owned by certain statutory bodies, and their wholly owned subsidiaries, among others. The exemptions are specific. Where one is relied on, identify it by reference to the relevant schedule and record the basis; do not assume an exemption because the group is large or regulated.
The registers are not open to public inspection, which leads some companies to treat them casually. They must be produced to the authorities and to law enforcement on request, and are a standard item in due diligence, in bank onboarding and in anti-money-laundering checks. An incomplete register surfaces at the worst moment in a transaction.
The register may be kept at the registered office or at the office of a registered filing agent, and the location must be declared in the annual return or annual declaration. Where a corporate service provider maintains it, confirm they are actually doing the annual notices rather than assuming it is included in the fee.
A new investment round, a share transfer, a shareholders’ agreement conferring veto rights, a change of board composition, or a restructuring upstream can all create or remove a controller. Item 11 of the calendar makes the review event-driven as well as annual.
The registers contain residential addresses, identification numbers and dates of birth. Handle them in accordance with the Personal Data Protection Act — restrict access, secure the storage, and do not circulate the register more widely than the obligation requires.
Reflects Singapore law current as of {{DATE OF USE}}. Requirements on these registers have been amended repeatedly, including through the Companies and Limited Liability Partnerships (Miscellaneous Amendments) Act 2024 and measures in force during 2025 and 2026 — confirm the current position with the authority or a corporate secretarial adviser, particularly on central filing and nominee arrangements.
This is a ready-to-use template provided for convenience. Laws and requirements change, and every situation is different — please have it reviewed by a qualified professional (a lawyer, corporate secretary, or accountant as relevant) before you rely on it.