Implementation of Central Register of Controllers

To uphold Singapore’s reputation as a trusted financial hub that is align with international standards, the Companies Act (CA) has been amended to require all companies incorporated in Singapore (unless exempted) to maintain a Register of Registrable Controllers (RORC). Enforced by Accounting and Corporate Regulatory Authority (ACRA), the RORC is made mandatory for all companies from 31 March 2017.
 
The aim of this is to make both the ownership and control of corporate entities more transparent, and restrict the misuse of corporate entities for unlawful purposes such as money laundering. More information about the definitions of controllers and what information is collected in the RORC can be found in our blog post: What Your need to know about the Register of Registrable Controllers and Register of Nominee Directors.

Centralized Register of Controllers
Earlier this year, ACRA announced the implementation of a centralized non-public RORC. Under this new regulation, this requirement is further enhanced by stipulating that the RORC must also be submitted online to ACRA via ​BizFile. ACRA have also issued its Practice Direction No.3 of 2020 that states the requirement to lodge the RORC information in the Central Register of Controllers maintained by ACRA.
 
This is in addition to existing requirement of maintaining the RORC internally at the company’s registered office address or with their respective corporate service providers. We have shared more information about this new requirement in our SingaporeBytes eNewsletter 2020Q2.
 
Access and Inspection of the Centralized Register of Controllers
Information in the Central RORC will only be made available to law enforcement authorities for the purpose of administering and enforcing the law under their purview (e.g. investigating the company of suspected money laundering offences). These law enforcing authorities include:

• ACRA
• Singapore Police Force
• Commercial Affairs Department
• Corrupt Practices Investigation Bureau
• Inland Revenue Authority of Singapore

Officers from these authorities are allowed to inspect, examine and make copies of the RORC and its supporting documents (e.g. copy of NRIC or Passport).
 
Information in the Central RORC will not be made accessible and/or available to the public, therefore such information should not be disclosed to the public. Companies (including the company officers) may face a fine of up to S$5,000 if found to be breaching this rule.
 
Deadline to lodge RORC in the Central Register
Previously, ACRA’s instructions is to file the information within 30 days from 31 July 2020, but this has since been extended to 29 September 2020, in view of the resumption of more businesses in phases after Singapore’s Circuit Breaker. Companies (including the company officers) may face a fine of up to S$5,000 if they fail to lodge the RORC in ACRA’s Central Register.

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How can Inter Group help you with RORC?
We understand that the requirements for RORC may seem complicated and confusing. However, as the RORC is an updated requirement for all companies (unless exempted), it is important to not take this requirement lightly, especially when the penalty comes with a hefty fine for failure to file.
 
If you are reading this as our valued client, we have already emailed you the notice, and if you have responded, we thank you, thus the above is For Your Information (FYI) only. But you can still reach out to any of our consultants if you need further clarification.
 
If you are a business owner and unsure how to create or maintain your company’s RORC, Inter Group can help you take care of this, thus providing you peace of mind. Engagement of our Corporate Secretarial services will include the updating and safekeeping of your company’s RORC. Please contact us if you have questions.

You may email your questions to ibs@icononline.net or call any of our offices, the numbers are located at the bottom of this page.