Identifying & sending annual notices to registrable controllers (RCs)
Check how to identify RCs based on significant interest or significant control. You must send RCs annual notices to verify their details and update any changes to your RORC.
Last updated 29 January 2026
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Identifying RCs
RCs are individuals or legal entities that have significant interest or significant control over your business. For most businesses, the controllers are likely to be the shareholders or partners.
Select your business structure to identify potential RCs.
Companies and foreign companies
First, check whether any person or legal entity meets the significant interest criteria. Then, check the significant control criteria for companies.
Significant interest: Companies
Company type | Significant interest criteria |
|---|---|
Has share capital | Any person or legal entity who has:
|
Has no share capital | Any person or legal entity who has the right to share in more than 25% of the capital or profits of the company |
Significant control
A controller has significant control if they:
Hold the right to appoint or remove directors who hold a majority of the voting rights at directors' meetings
Hold more than 25% of the rights to vote on matters that are to be decided upon by a vote of the members
Exercise or have the right to exercise significant influence or control
Limited liability partnership (LLP)
A controller of an LLP is a person or legal entity who meets any of these criteria.
LLP controller criteria
Area | Criteria |
|---|---|
Financial interest | Holds a right to share in any of these :
|
Management control | Holds the right to appoint or remove any of these:
|
Voting rights | Holds more than 25% of the rights to vote on matters decided by the partners |
Significant influence or control | Has the right to exercise, or actually exercises, significant influence or control over the LLP |
Note: Rights can be held directly or indirectly.
Note: All companies, foreign companies, and LLPs must identify their own controllers. ACRA cannot identify controllers on your behalf.
Sending notices to RCs
At incorporation, you do not need to send notices to confirm your controllers' particulars. You should already have this information when you register your business.
After incorporation, you only need to send notices when circumstances change or for annual verification.
Identifying new RCs (when circumstances change)
If you identify new RCs after incorporation, you need to send them a notice to confirm their status.
Who to send notices to
Unless you wholly own and control a business, you need to send a notice to confirm if they:
Are an RC
Know of any other possible controllers
Who to send notices to
For | You should send notices to |
|---|---|
Companies and foreign companies |
|
Limited liability partnerships (LLPs) |
|
What controllers need to do
Controllers need to:
Respond to the notice within 30 days. The person named in the notice must respond, even if they are not a controller.
Confirm their particulars if they are a controller. They can either sign and date the confirmation themselves or have their registered corporate service provider (CSP) confirm on their behalf.
Inform you if they know of other possible controllers, or if their particulars change.
If a controller does not respond within 30 days
You must still update your RORC. Complete this within seven calendar days after the end of the 30-day period.
Steps to take:
Enter their most recent particulars in your private RORC.
Add a note stating the particulars have not been confirmed by the controller.
File the RORC information with ACRA through the update RORC eService
Mark the controller's particulars as "unconfirmed" when you file.
Sending annual notices to existing RCs
After you identify and record your RCs, you need to send annual notices to confirm their status and particulars. You need to verify controllers even if their details appear in your Business Profile (for example, as shareholders).
Follow these steps to verify controller information for your RORC.
When to send annual notices
You must send a notice to each RC at least once a year. There is no set date for sending notices, as long as each RC receives a notice annually.
Give RCs 30 days from the date of the notice to respond.
What RCs need to confirm
Each RC needs to confirm whether their particulars in the register are still correct.
If there has been a relevant change since the last notice, they must provide:
The date of the change
The correct details
What counts as a relevant change:
The RC is no longer a registrable controller of your company
Any other change (for example, a change in particulars) that makes the RC's particulars in your register incorrect or incomplete
If your company fails to send annual verification notices: You may be fined up to $25,000. This applies to the company and officers in default.
If an RC fails to respond to the notice: They may be fined up to $25,000.
Updating your RORC
You need to update your RORC if there are any changes or if you did not manage to identify any controllers.
How to update
If you | What you need to do |
|---|---|
Managed to identify and verify your RCs | If there are any changes to your RORC:
|
Did not manage to identify any controllers after taking all efforts to identify controllers with:
| You need to identify individuals with executive control as your controllers:
How to update your RORC with ACRA:
Note: Keep all documentation showing you took reasonable steps to identify the controllers. ACRA may ask you to demonstrate this. |
Frequently asked questions (FAQs)
Can a society or a licensed trust company be a controller?
Yes, all local and foreign entities can be corporate controllers. This includes societies and licensed trust companies.
How do I identify controllers involving a trust?
If your company or foreign company involves a trust, you must send a notice to:
The trustee; and
Other parties to the trust
Related pages
Setting up & maintaining a Register of Registrable Controllers (RORC)
Check if you need to comply with RORC requirements, and how to set up and maintain your private RORC.
Filing with the Central Register of Registrable Controllers (RORC)
All companies and foreign companies must file their RORC information with ACRA's Central RORC. This filing is separate from maintaining your private RORC.
RORC, ROND & RONS guidance
Instructions and regulatory requirements for companies to establish and maintain statutory business registers.