Version and companies with share capital
Version 2.0 was issued on 16 June 2025 under Part 11A of the Companies Act 1967 and the 2017 register regulations. It incorporates that day’s changes to nominee definition, central filing, contact details and location declarations. Only companies with share capital are covered by the nominee shareholder provisions. The private register requirement began on 4 October 2022. Nominee shareholder, nominee director and registrable controller registers are distinct; being a nominee alone does not establish registrable control.
Which companies are exempt
Exemptions cover SGX-listed public companies, Singapore financial institutions as defined in the Fourteenth Schedule, companies wholly owned by Singapore’s Government or a statutory body established under a Singapore public Act for a public purpose, wholly owned subsidiaries of those four categories, and overseas-listed companies subject to both regulatory disclosure and adequate beneficial-owner transparency requirements. Comparable substantial-shareholder disclosure can meet the overseas-listing condition. Section 5B governs wholly owned subsidiary status, including specified nominee and subsidiary holdings. Winding up, receivership, judicial management or striking off does not itself create an exemption.
Either voting instructions or dividends for another person
A registered shareholder is a nominee if either or both tests apply: the shareholder is accustomed or formally/informally obliged to vote the registered shares according to another person’s directions, instructions or wishes; or receives dividends on those shares on another person’s behalf. The two tests are alternatives, not cumulative conditions. Nominees must notify status and provide prescribed nominator particulars, then report cessation and changes. An exempt company’s role as a nominator does not exempt the nominee from identifying it to a non-exempt company.
Disclosure deadlines depend on incorporation date
For companies incorporated from 4 October 2022 to before 16 June 2025, a shareholder who is a nominee at incorporation must notify and supply particulars within 30 days after incorporation; becoming a nominee later starts a 30-day period from that event. For companies incorporated on or after 16 June 2025, an existing nominee must provide the information on incorporation day; a later nominee still has 30 days. For companies incorporated before 4 October 2022, the guidance specifies 30 days where the shareholder becomes a nominee after that date. Cessation of nominee status and changes to previously supplied particulars must each be notified within 30 days of the event.
Individual and legal-entity nominators
For an individual, record full name, aliases, residential address, email, contact number, nationality, identity-card or passport number, date of birth and the date the shareholder became that person’s nominee. For a legal entity, record name, ACRA UEN if any, registered-office address, email, contact number, legal form, formation jurisdiction and statute, applicable corporate register name and registration/identification number, and the nominee commencement date. Legal form means the entity type, such as private company; statute means the legislation under which it was formed. ACRA and UK Companies House illustrate register names. Commencement and cessation dates are actual event dates on or after 4 October 2022, not simply the date of entry.
Seven-day updating, location and custody
Enter information and updates received from nominee shareholders within seven days, and document when they were received. Keep the register at the company’s registered office or the registered office of an appointed registered corporate service provider. State where it is kept in the annual return; the guidance separately says companies need not lodge, notify or update ACRA with the address of that location. A resigning service provider should hand the register back to the company, which may appoint a replacement. Electronic or paper records are permitted, provided the prescribed Eighth Schedule form is met; formatting can differ from Annex A.
No information received and restricted inspection
A company that has received no nominee-shareholder information may record a dated statement to that effect. The private register and its particulars must not be disclosed to or inspected by the public, including company members; auditors have no entitlement to access. In contrast, the Registrar, ACRA officers and public agencies or their officers can require the register, related records and supporting documents, inspect them and make copies. Examples include the Police, Commercial Affairs Department, CPIB and IRAS. Companies must cooperate with those requests.
Documents supporting accurate particulars
The guidance gives NRIC copies for Singapore citizen or PR nominators; passport and residential-address evidence such as a utility bill for foreign individuals; and a foreign entity’s registration certificate plus address evidence if its registered office is not shown on the certificate. Retain emails or letters through which nominee shareholders supplied the information entered in the register. These examples support the accuracy and updating of the register and must be furnished when requested by the authorised agencies.
Central filing and public nominee status
The June 2025 guidance requires existing companies to file all private-register information with ACRA by 31 December 2025. Companies incorporated on or after 16 June 2025 must file nominee shareholder and nominator information at incorporation. Thereafter, updates must be filed within two business days after the company enters or updates the private register. The shareholder’s nominee status becomes publicly available, including in business profiles, but complete information in ACRA’s central register is accessible only to public agencies administering or enforcing written law. These are the transition dates stated in this version of the guidance.
Annex A: separate dates and corrected interpretation
The template uses entry date, nominee shareholder name, nominator particulars and remarks. It covers individual and foreign corporate nominators, cessation and updated corporate address, recording both the new address and change date. Commencement, cessation, change and entry dates are different facts. The first example prints a 2022 entry with a 2025 commencement, and later corporate tables mislabel the name column as nominee director. These apparent template errors do not change the operative shareholder definition or deadlines; use the real shareholder relationship and dates. Layout may vary if the prescribed Eighth Schedule form is satisfied.
Official source
This article independently explains the substantive contents of the official PDF, including the relevant conditions, procedures and annexes. The linked document remains the authoritative source for its original wording, and later changes should be checked separately.
Read the official PDF ↗