If your company has a nominee director, a nominee shareholder, or any shareholder who is not the “real” owner of the shares, ACRA now expects you to know exactly who that person is answering to, and to keep that information current at all times. Get it wrong, and the fine has quintupled. Singapore’s registers of nominee directors, nominee shareholders and registrable controllers are no longer a quiet paperwork exercise tucked away in a corporate secretary’s filing cabinet. They are now central to ACRA’s anti-money-laundering strategy, backed by a central government database and penalties that make casual non-compliance a genuinely expensive mistake.
This article sets out, plainly and with verified figures, what the Register of Nominee Directors (ROND), the Register of Nominee Shareholders (RONS) and the Register of Registrable Controllers (RORC) actually require, how the penalty and disclosure regime has tightened across 2025 and into 2026, and what your company should be doing right now to avoid falling foul of it.
What are the ROND, RONS and RORC, and why do they matter?
Every Singapore-incorporated company (and most foreign companies registered here) must keep three internal registers under the Companies Act 1967, unless a specific exemption applies:
- Register of Registrable Controllers (RORC): records individuals or entities who have significant control over the company, typically more than 25% of shares or voting rights, or the right to appoint or remove a majority of directors.
- Register of Nominee Directors (ROND): records any director who acts on the instructions of another person (the nominator) in relation to how they vote or act as a director.
- Register of Nominee Shareholders (RONS): records any shareholder who holds shares on behalf of, or under the instructions of, another person.
These registers exist for one core reason: to stop companies being used as a screen for the true owners and controllers of a business, which is a well-known money-laundering and sanctions-evasion technique. That is why ACRA, together with the Ministry of Finance, has steadily tightened both the disclosure requirements and the consequences of getting the registers wrong.
From private register to central filing
Historically, ROND, RONS and RORC were private registers kept at the company’s registered office and shown only to authorised persons on request. That changed with the Companies and Limited Liability Partnerships (Miscellaneous Amendments) Act 2024, which took effect on 16 June 2025. From that date, companies and foreign companies must file the contents of their ROND and RONS with ACRA, which now maintains the information in central registers, alongside the existing central RORC. Any change to the private registers must be filed with ACRA within two business days. Existing companies had until 31 December 2025 to complete their initial filing, while companies incorporated from 16 June 2025 onwards must file on the date of incorporation itself. Full technical guidance is available directly from ACRA’s RORC, ROND and RONS guidance page.
What actually changed: the penalty and enforcement picture
The headline change that companies should not miss is the fine. The maximum penalty for failing to maintain, update, or file the ROND, RONS or RORC has been raised from $5,000 to $25,000, a five-fold increase, under the 2024 amendments that commenced on 16 June 2025. This applies to failures both in keeping the private register accurate and in filing changes with ACRA’s central register within the required window. Separately, individuals who arrange nominee director appointments through channels other than a licensed corporate service provider face a distinct fine, reported at up to $10,000, for facilitating unregulated nominee arrangements.
Companies also now need to think in terms of the nominator, not just the nominee. A nominee director or nominee shareholder is required to disclose the identity of the person instructing them (the nominator) to the company, and that nominator information flows through to ACRA’s central register. The nominee status itself becomes visible on a company’s business profile extract, but the underlying nominator details are restricted to public agencies for law enforcement and regulatory purposes, not disclosed to the general public.
This register-specific tightening sits alongside a second, broader wave of reform: the Corporate and Accounting Laws (Amendment) Act 2025 (CALA 2025), passed by Parliament on 5 November 2025, with its first tranche of provisions commencing on 6 May 2026. CALA 2025 does not itself rewrite the ROND/RONS/RORC fine schedule, but it raises the general cost of corporate non-compliance and misuse of companies across the board, which matters directly to any company relying on nominee arrangements. Under CALA 2025, the maximum fine for a breach of directors’ duties under section 157 of the Companies Act rises from $5,000 to $20,000, with imprisonment of up to 12 months available for serious cases. CALA 2025 also expands the list of offences, including money-laundering convictions under the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992, that trigger automatic director disqualification, and it tightens the grounds on which a struck-off entity can be restored to the register where restoration would be prejudicial to public order or national security. Official details are on ACRA’s CALA 2025 legislation page and the commencement announcement. We cover the director-duty and disqualification side of CALA 2025 in more depth in our Corporate Governance Overhaul article and our piece on director disqualification through court proceedings.
The practical effect for directors and shareholders using nominee structures is that the two reforms compound each other. Getting the register wrong now risks a $25,000 fine in its own right, and the surrounding conduct, concealing a controller, misrepresenting a nominee’s status, or otherwise facilitating a structure that misuses the company, can independently trigger the heavier CALA 2025 penalties, director disqualification, or both. Precise figures should always be confirmed directly with ACRA or in the statute itself, as enforcement guidance continues to be refined ahead of and after the 6 May 2026 commencement date.
Why this is not the Form 45 story
It is worth being clear about what this article is not. The revised Form 45 declaration, which proposed directors sign to confirm they are not disqualified under money-laundering-related grounds, is a separate compliance point that we have covered in detail in our article on the amended Form 45. The ROND, RONS and RORC penalty regime discussed here is about the ongoing, day-to-day obligation to keep three specific registers accurate and filed, not a one-off declaration at the point of appointment. Both matter, and both feed into the same broader anti-money-laundering push, but they are distinct obligations with distinct triggers.
Old versus new: a quick comparison
| Area | Before 16 June 2025 | From 16 June 2025 onwards |
|---|---|---|
| Where registers are kept | Private register only, at the registered office | Private register, plus mandatory filing with ACRA’s central ROND, RONS and RORC registers |
| Filing deadline for changes | No central filing requirement | Within 2 business days of any change to the private register |
| Maximum fine for failing to maintain or file | $5,000 | $25,000 |
| Nominator identity | Not systematically disclosed to ACRA | Disclosed to the company and flows through to ACRA’s central register; restricted to public agencies, not published |
| Unregulated nominee arrangements | Not separately penalised | Arranging a nominee director outside a licensed corporate service provider risks a fine of up to $10,000 |
| Wider deterrent effect (CALA 2025, from 6 May 2026) | Director duty breaches fined up to $5,000 | Director duty breaches fined up to $20,000, plus up to 12 months’ imprisonment for serious cases; wider automatic disqualification grounds |
Figures above reflect the Companies and Limited Liability Partnerships (Miscellaneous Amendments) Act 2024 (registers) and CALA 2025 (director duties and disqualification) as published by ACRA. Companies should confirm current figures with ACRA before relying on them for a specific decision.
Practical compliance steps for your company
1. Confirm whether you actually have nominee arrangements or controllers to declare
Many small and medium-sized companies assume the ROND, RONS and RORC requirements do not apply to them because ownership looks straightforward on paper. Review your shareholding and directorship structure carefully, particularly if any shareholder holds shares as trustee, custodian, or on behalf of an undisclosed principal, or if any director has been appointed at the instruction of someone else.
2. Get the private register accurate first
The central filing obligation only works if the underlying private register is correct. Update the ROND, RONS and RORC whenever there is a change in directors, shareholders, or controllers, and record the nominator’s identity where a nominee arrangement exists.
3. File with ACRA within the two-business-day window
Do not treat central filing as an annual housekeeping task. Any change must reach ACRA’s central register within two business days of the change occurring in the private register, so build this into your corporate secretary’s standard change-of-particulars workflow rather than treating it as a separate reminder.
4. Use a licensed corporate service provider for nominee arrangements
If your company genuinely needs a nominee director, for example to satisfy the requirement for a locally resident director, arrange this only through a licensed corporate service provider. Informal arrangements outside a registered provider carry their own separate fine exposure.
5. Review governance documents as CALA 2025 approaches
With CALA 2025’s director-duty and disqualification provisions commencing 6 May 2026, boards should use the run-up to that date to review director conduct, tighten record-keeping around resolutions and duty of care, and ensure any past compliance gaps, including in the registers, are remediated before the heavier regime takes effect. If your company is also dealing with a strike-off or restoration matter, note that CALA 2025 tightens the grounds for restoration where an entity’s return to the register could be used for unlawful purposes; our guide to objecting to an ACRA strike-off covers the related process.
Frequently asked questions
Does every Singapore company need to keep a ROND, RONS and RORC?
Most companies do, unless a specific statutory exemption applies, for example certain listed companies or entities already subject to equivalent transparency requirements. If your company has no nominee directors, no nominee shareholders, and no controllers beyond the shareholders shown on Bizfile, your registers may simply record that position, but you should still confirm your exemption status rather than assume it.
Is the $25,000 fine per breach or a one-off cap?
It is the maximum fine that a court may impose for an offence relating to failure to maintain or file the relevant register. The actual penalty imposed in any case depends on the facts, and repeated or deliberate non-compliance is likely to attract a penalty closer to the maximum. Companies should verify current enforcement practice with ACRA rather than assume a fixed figure will apply.
Is nominator information available to the public?
No. A company’s nominee status is visible on its business profile extract, but the identity of the nominator is restricted to public agencies for regulatory and enforcement purposes and is not published to the general public.
How is this different from the amended Form 45?
Form 45 is a declaration signed by a proposed director confirming they are not disqualified from acting, with enhanced due diligence obligations on directors, corporate service providers and registered filing agents. The ROND, RONS and RORC obligations are ongoing register-keeping and filing duties that apply throughout the life of the company, not a one-time declaration at appointment. See our dedicated article on the amended Form 45 for that separate requirement.
Conclusion
The message from ACRA across 2025 and into 2026 is consistent: Singapore’s corporate registry is tightening the net around nominee arrangements and hidden control, and the days of treating the ROND, RONS and RORC as a low-priority filing are over. A $25,000 maximum fine, a two-business-day central filing window, and mandatory nominator disclosure mean these registers deserve the same attention as your annual return or your XBRL filing, not less. Layer on CALA 2025’s heavier director-duty penalties and wider disqualification grounds from 6 May 2026, and the cost of getting corporate governance wrong in Singapore has never been higher.
If you are not entirely sure your company’s registers are accurate, filed, and defensible, do not wait for an ACRA query to find out. Speak to the corporate secretarial team at Raffles Corporate Services for a register health check and practical help bringing your filings up to date.
. The Editorial Team, Raffles Corporate Services