Incorporating in Singapore: the beneficial owner information you must give from day one

The short answer: when you set up a Singapore company today, beneficial ownership information is no longer something to tidy up after incorporation. It is due on the day the company is born. Two sets of rules that took effect in 2025 explain why:

• Under the Companies and Limited Liability Partnerships (Miscellaneous Amendments) Act 2024, in force from 16 June 2025, a new company must keep a register of registrable controllers (RORC) from its date of incorporation and file its controller information with ACRA when it incorporates.
• Under the Corporate Service Providers Act 2024 and the Corporate Service Providers Regulations 2025, in force from 9 June 2025, the registered corporate service provider (CSP) forming the company must carry out customer due diligence (CDD) before providing the service, identifying and verifying the customer and each beneficial owner.

So incorporation involves two sets of questions: what the company must record with ACRA about who controls it, and what the CSP must verify, for anti-money-laundering purposes, about who you are and where the money comes from.

This article draws on ACRA’s commencement notice, its guidance on registers of controllers (16 June 2025 edition) and its FAQs on the CSP Act. It is current as at 3 November 2026.

Who counts as a registrable controller?

Under ACRA’s guidance, for a company with share capital, an individual or legal entity has a significant interest if it:

• has an interest in more than 25% of the shares; or
• holds voting shares carrying more than 25% of the total voting power.

It has significant control if it:

• can, directly or indirectly, appoint or remove directors holding a majority of the board’s votes;
• holds, directly or indirectly, more than 25% of the votes on matters decided by members; or
• has the right to exercise, or actually exercises, significant influence or control over the company.

The 25% test adds all classes of shares together, whatever their type or currency. A controller can be an individual or a legal entity, and control held indirectly through one company or a chain of companies is registrable by default.

A nominee does not change the answer. ACRA’s own example: if individual X holds 30% of company Z’s shares as nominee for individual Y, the shares are treated as Y’s, so Y, not X, is Z’s controller.

If a company has no controller, or cannot identify one after taking reasonable steps, it must note this in the register and record the particulars of its directors with executive control or its CEO instead.

What controller information is needed at incorporation?

ACRA’s how-to guide lists, for an individual controller:

• full name and any aliases
• residential address, email and contact number
• nationality, ID card or passport number, and date of birth
• the date they became a controller (and ceased to be one, where relevant)

For a corporate controller, the register records its name, registration number, registered office, legal form, place of incorporation and governing law, and its registrar.

For companies incorporated from 16 June 2025, the register must exist on the day of incorporation, and the controller details are filed through Bizfile as part of registering the company. The old 30-day grace period is gone.

What does the corporate service provider check before incorporating?

According to ACRA’s CSP Act FAQs, a registered CSP must complete CDD before forming a business entity, arranging directors or nominee shareholders, or providing a registered office. That includes:

• identifying and verifying the customer, any agent and the beneficial owners;
• screening the customer, agents, connected parties and beneficial owners against UN sanctions and terrorism-financing lists;
• where enhanced CDD applies, establishing the source of wealth (for example, where the paid-up capital came from and how the wealth was built) and the source of funds.

Remote incorporation adds a step. If the customer cannot be physically present, the CSP must hold a live video call with at least one proposed director (other than a nominee director), or a proposed member holding not less than 50% of the voting rights (or, if that member is a legal entity, its authorised representative). ACRA states that this cannot be replaced by a third-party verification platform or notarised documents.

What continues after incorporation?

• When a controller’s particulars change, the company must update its register within 7 calendar days of the particulars being confirmed (previously 2 business days), and file the update with ACRA’s central register within 2 business days after that.
• Each year, the company must send a notice to every controller in the register to confirm whether anything has changed.
• The register must be produced to the Registrar, ACRA or a public agency on request.
• Nominee director and nominee shareholder information must be filed with ACRA. According to ACRA’s page on the amendment Act, nominee status is shown publicly on the company’s profile, while nominator details are available only to public agencies.
• The maximum fine for a company’s offences relating to these registers has risen from S$5,000 to S$25,000.

Frequently asked questions

I hold 100% of a Singapore company through a BVI company. Who is registered? The BVI company is a corporate controller and must be recorded. The individuals who control the Singapore company through it are, by default, registrable controllers too.

A relative holds the shares for me. Can I register just the relative? No. Shares held by a nominee are treated as held by the nominator, who is the controller. The nominee shareholding itself must also be filed with ACRA and is shown publicly.

Is controller information open to the public? The register must be produced to ACRA and public agencies on request, for enforcement purposes. What appears publicly is a director’s or shareholder’s nominee status, not the nominator’s details.

Can I incorporate remotely from China? Yes, but the CSP must hold a live video call with a proposed director or a proposed member with at least 50% of the votes. Notarised documents are not accepted in its place.

Transparency as the starting point of the structure

For families settling in Singapore, the company often carries the residency and wealth plan. Because controller information has to be accurate and verifiable from day one, the shareholding, the source of funds and each family member’s role are best settled before incorporation, not repaired afterwards. When PASSION INTERACTIVE plans a family’s move as a whole, the company’s ownership and control are considered together with residency and wealth planning.

This article is general information and does not constitute financial, legal or tax advice. Rely on written advice from a licensed professional for any specific arrangement.