What You Need to Know About the Register of Registrable Controllers (RORC)?

Hassle-Free S Pass & Employment Pass Applications

Filing the RORC with ACRA

All companies, foreign companies, and LLPs are required to submit their RORC information to ACRA via the “Update Register of Registrable Controller” eService on BizFile.
Failure to lodge or update the RORC with ACRA may result in a penalty of up to $25,000 per breach.
Please note that this requirement is separate from the submission of your Annual Return or Declaration filing.

What is the RORC?

Since 31 March 2017, companies, foreign companies, and LLPs (unless exempted) must maintain a Register of Registrable Controllers (RORC).

The RORC is a register containing information on the registrable controllers (commonly referred to as beneficial owners) of companies, foreign companies, or LLPs.

Who is a Registrable Controller (RC)?

You are considered a Registrable Controller if you:
(a) Own more than 25% of the shares in a company; or
(b) Hold more than 25% of the voting rights in a company; or
(c) Have significant influence or control over the company or LLP.

If an entity cannot identify a Registrable Controller, it must instead identify individuals who exercise executive control as the RC(s).

Setting Up and Maintaining the RORC

The RORC must be established on the same day the company, foreign company, or LLP is incorporated or registered.
Entities are required to issue notices to persons who may potentially be controllers to confirm and verify their particulars.
The RORC can be kept either at the entity’s registered office or at the office of its appointed Corporate Service Provider (CSP).
The same RORC information must also be filed with ACRA through BizFile, ACRA’s online filing system.

What Are the Responsibilities of a Registrable Controller (RC)?

Respond to notices issued by the entity and verify your particulars.
Provide details of any other potential Registrable Controllers to the entity.
Inform the entity promptly if there are any changes to your particulars.

RORC Requirements

With effect from 31 March 2017, all companies, foreign companies, and Limited Liability Partnerships (LLPs) (collectively referred to as “entities”) are required to maintain a Register of Registrable Controllers (RORC). This register must be maintained either at the entity’s registered office address or at the registered office of its appointed Corporate Service Provider (CSP). The RORC records the particulars of the entity’s registrable controllers, who are commonly referred to as the beneficial owners. Further details on the required information can be found under the section, “What information must be lodged with ACRA.”

Effective from 30 July 2020, in addition to maintaining the private RORC, entities are required to lodge the same information with ACRA’s Central Register of Registrable Controllers (central RORC) via BizFile within two business days of establishing or updating the private register.

The establishment of ACRA’s central RORC forms part of Singapore’s continued efforts to enhance the transparency of ownership and control of corporate entities and to safeguard Singapore’s standing as a reputable and trusted financial jurisdiction. Information maintained in the central RORC is strictly confidential and will only be accessible to law enforcement agencies for the purpose of carrying out their regulatory or enforcement duties, such as investigations into money laundering offences. Such information will not be disclosed to the public.

Employment Pass (EP) Application – Frequently Asked Questions (FAQ)

Why was my EP renewal rejected?

Common reasons include:

The company has been operating at a financial loss for the past two years.
The company is in an insolvent position (capital is less than retained losses).
The company’s revenue or existing contracts are insufficient to cover employee salaries.

Can I declare a salary higher than the MOM Self-Assessment Tool (SAT) recommends?

It is not advisable to declare a salary significantly higher than the SAT recommendation. The Ministry of Manpower (MOM) may request additional supporting documents, such as reasons for the higher salary or evidence (e.g., sales contracts) to justify the company’s ability to pay the stated salary.

Can I start working before my EP card is issued?

No, you cannot commence work before your EP card is issued. Doing so is considered illegal employment under Singapore law.

What is education verification for an EP application and how long does it take?

MOM requires companies to engage MOM-approved screening agencies to verify education qualifications and, if necessary, translate certificates into English.
The verification process typically takes about one month. It is recommended to complete this process prior to submitting your EP application to avoid delays.

Can an EP holder take up a secondary directorship (e.g., serve as a local director for two companies)?