If they haven’t already, companies in Singapore should look to register alternate addresses for their directors, chief executive officers and company secretaries.
Three years ago, the Accounting and Corporate Regulatory Authority of Singapore (ACRA) introduced new regulations allowing directors, CEOs and company secretaries of Singaporean entities to register an alternate address. While some have taken advantage of this opportunity, many may still not be aware of the change, and so continue to make their residential address available to the public.
The change was introduced to protect the privacy of these individuals by allowing their residential address to remain confidential.
When a company is registered in Singapore, the company officers are required to provide their residential address – be it in Singapore or another country – so they can be contacted by ACRA. This information forms part of the company profile which can be purchased by any person for just SGD5.50.
Some businesses purchase company profiles to compile mailing lists, resulting in the officers of a company potentially inundated with unwanted mail at their home address. But of greater concern was the possibility of a disgruntled customer easily accessing the addresses of senior officers. The regulatory change was made to eliminate these risks.
Registration of an alternate address
Officers of a company can register an alternative address with ACRA for a SGD40 fee. In doing so, they must meet certain criteria:
- only one alternate address can be registered for each officer
- it must not be their residential address
- it must be an address at which they can be contacted
- it must not be a post office box number
- it must be located in the same jurisdiction as the officer’s residential address, not necessarily Singapore.
The alternate address will be the address made available to the public and the residential address (which must still be registered with ACRA) will be listed on internal records only.
It’s very important for the officers to be contactable at the alternate address. If they’re not, they may be liable for a fine of up to SGD10,000 or imprisonment for a period not exceeding two years, or both. They also face their alternate address being deleted from the registry and their residential address made public instead.
An officer found to be in default will not be able to register another alternate address for three years, and must pay another registration fee when they do.
With such serious potential penalties, it’s important that directors, CEOs and company secretaries seek sound professional advice.