Who must nominee shareholders or beneficial owners (UBOs) be reported to?

Beneficial owners must be recorded in the company's Register of Registrable Controllers (RORC) and lodged with ACRA's central register. To improve ownership transparency, Singapore requires companies to identify and report their ultimate beneficial owners (UBOs) / registrable controllers. Even where a nominee shareholder holds shares on behalf of another, the true beneficial owner's identity cannot be hidden: the company must trace through to the ultimate natural person via due diligence, record them in the Register of Registrable Controllers (RORC), and lodge the information with the central register maintained by ACRA. The nominee arrangement between the nominee shareholder and the beneficiary must also be accurately recorded in the register of nominee shareholders. This information is not public but can be accessed by regulators and enforcement agencies. Hiding beneficial owners to evade reporting is a breach and can be penalised. The corporate secretary usually issues controller notices, verifies identities and maintains the registers to keep transparency compliance in order.