The establishment timelines in the source
Foreign companies registered on or after 31 March 2017 must keep a public member register in Singapore within 30 days after registration. Those registered earlier had 60 days after 31 March 2017, stated as by 30 May 2017. The latter was a transitional deadline, not a current recurring deadline.
Member registers and controller registers are different
The FAQ says the Fifteenth Schedule exemptions for registrable-controller registers do not apply to public member-register duties. Its requirements are in sections 379 and 380 and are compared with section 190 for locally incorporated public companies. Exemption from one type of register should not be treated as exemption from all registers.
Identify members under the home-jurisdiction law
Each foreign company assesses who its members are by its home-jurisdiction law. The source does not assume shareholders, depositors or all beneficial owners are automatically interchangeable categories. The register can be electronic or hardcopy.
Keep it in Singapore and notify the address
Keep the register at the Singapore registered office or another place in Singapore. Even an electronic Excel register is illustrated as stored on a computer at a Singapore location. Lodge notice of that address with the Registrar and lodge a change notice within 30 days after the storage address changes.
Inspection and permitted copy contents
Members inspect free; another person pays S$1 per inspection or a lower amount required by the company. A member or other person can request copies so far as they concern names, addresses, share numbers and paid amounts, paying in advance S$1 per page or a lower amount. This is not a right to every document held by the company.
Time to supply copies
The FAQ gives 21 days, or a longer period the Registrar considers reasonable, beginning on the day after the request is received. It points to regulation 11 of the 2017 controller-and-nominee-director regulations for details. Both the next-day start and possible allowed extension form part of the source rule.
SGX and overseas depositary arrangements
For SGX-listed shares held in the described CDP structure, certificates are registered and immobilised in CDP’s name, while CDP tracks depositors through book entries. The member register therefore lists CDP for those shares even though depositor records change. Overseas exchanges may have similar arrangements depending on their rules and home law; an existing home register may be adapted where comparable.
The FAQ’s no-exemption statement is historical
The original FAQ states that no foreign company is exempt. A later 2023 regulation specifically exempts Commonwealth War Graves Commission (Singapore Branch), UEN T15FC0152C, from section 379 from 28 June 2023. This article preserves the FAQ’s explanation while identifying that later named exception, rather than repeating the old universal statement as an unqualified current rule.
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 ↗