Filing the Winding Up Order is the second of three Bizfile submissions in a court-ordered winding up. You upload a copy of the Court’s order, state the date it was filed in court, and submit. It takes minutes, the fee is $20 for a local company and nil for an LLP, and processing is immediate.
Raffles Corporate Services works with a panel of experienced Singapore law firms who offer cost-effective and efficient legal service and advice. This article is general information only and is not legal advice.
The difficulty is almost never the form. It is that this filing sits in the middle of a linked sequence, and the sequence is unforgiving of people who leave it half-done and come back a fortnight later.
By the time you reach this step, the Notice of winding up order and the liquidator appointment should already be in. If they are not, start with the Notice of order and liquidator appointments, because the eService will not let you jump ahead.
Why there is a separate filing for the order
It looks redundant. You have already told ACRA there is a winding up order, entered the grounds, named the plaintiff and appointed a liquidator. Why file the order again?
Because the first filing records the notice of the order and the appointment that flows from it, and this one puts the order itself on the record. They are different documents with different dates, and in a compulsory winding up both dates matter.
Section 132 of the Insolvency, Restructuring and Dissolution Act 2018 deals with lodging a copy of the order. The register is meant to carry the document that actually displaced the directors, not merely a summary of it. Anyone later searching the entity, a bank freezing accounts, a counterparty assessing whether to keep performing a contract, a purchaser of assets from the liquidator, is entitled to see the order.
And the date of filing in court is not cosmetic. Commencement of a court-ordered winding up under section 126 usually relates back to the date of the application rather than the date of the order, and section 130 makes dispositions of property after commencement vulnerable to being avoided. The chronology on the register is the starting point when someone later asks which side of the line a payment fell on. Our note on validation orders under section 130 covers that problem in detail.
What you need before you open the form
Very little, which is why this step gets postponed and then forgotten.
| What you need | Detail |
|---|---|
| Copy of the court order | The sealed order, as a file you can upload |
| Date of filing the Winding Up Order in court | Must be the current date or a past date. Future dates are rejected |
| Corppass access, or CSP standing | Either as an authorised position holder of the entity, or as a registered corporate service provider acting for a third party such as the plaintiff or the Court |
Everything else, including the liquidator’s details and the notice details, is carried forward automatically from the first filing and displayed for you.
Which date goes in the date field
Read the field carefully. It asks for the date the Winding Up Order was filed in court. That is not:
- the date the winding up application was made;
- the date of the hearing;
- the date the order was pronounced, if that differs from when it was filed; or
- today, unless today happens to be the answer.
If you are working from a sealed copy, the filing date is on the face of it. If you are not certain, ask the solicitors who conducted the application rather than guessing. A wrong date here is a wrong date on a public register that insolvency practitioners, creditors and auditors will rely on.
The steps, in order
- Log in to Bizfile and select Business User, which routes you through Corppass. If you have not done this before, our walkthrough of the Corppass business user login covers the setup.
- Check the entity name and UEN on the top menu bar and dashboard. Confirm it is the entity being wound up. If you hold positions in more than one entity, switch profile first.
- If you are filing as a corporate service provider, select the Corporate Service Provider tab on the profile selection page, and pick the right firm if you belong to more than one.
- Open the File winding up of business entity eService and click Start.
- A pop-up will tell you that the Notice of winding up order and the liquidator appointment have already been submitted. Choose Resume current process.
- The webform loads with the notice details and the liquidator details already populated from the first filing. Read them. This is your last convenient chance to notice that something was keyed incorrectly a fortnight ago.
- Upload the copy of the court order.
- Enter the date the Winding Up Order was filed in court.
- Review and confirm, then submit.
An acknowledgement issues immediately and a notification goes to your Bizfile Inbox.
The mistake that costs you the whole submission
When you return to the eService, you are offered two choices: resume the current process, or start a new process.
Starting a new process initiates a fresh winding up application and deletes everything previously submitted within that process. It is not a warning about neatness. It means the notice details, the plaintiff’s particulars, the grounds, the liquidator’s licence number, firm UEN and contact details all have to be re-entered, and the notice document re-uploaded, by someone who may not have been the person who did it the first time.
In a compulsory winding up that person is often gone. The company’s finance manager has left, the CSP staff member has rolled off the file, and the liquidator’s office is working from whatever the solicitors sent across. Reconstructing a deleted submission is genuinely painful.
The rule is simple: if you did not personally start the winding up process in that eService within the current session, choose Resume, not Start new.
What else goes wrong here
The order never gets filed at all. The first filing changed the entity status, so it looks done. Everyone moves on. The register then carries a winding up status without the underlying order, which is precisely the gap a diligence exercise flags a year later when the assets are being sold.
The wrong document is uploaded. The notice of winding up order and the winding up order are different documents. Uploading the notice a second time produces a filing that appears complete and is not. Check the document you are attaching says what the field asks for.
The order has been amended or corrected since it was made. File the operative version. If the Court subsequently varied the order, that is worth raising with the liquidator before you upload anything, because a superseded order on the register is worse than a late one.
Somebody keeps running the business. This is not a filing error, but it surfaces at this stage often enough to mention. After the winding up order, the directors’ authority is displaced and the property of the company falls under section 140. Continuing to trade, pay selected creditors or move assets invites the liquidator’s investigative powers, and those are broad. Our articles on the powers and duties of a liquidator and on public examination of company officers set out what that looks like in practice.
The entity is an LLP and nobody realises the fee differs. For an LLP this filing is free. For a local company it is $20. The fee is trivial either way, but the difference is a useful reminder that LLP and company winding up run on different statutory tracks even though they share one eService.
After you file
One filing remains. The third and final step is confirming the liquidator or provisional liquidator appointment, which closes out the initiation process. Our guide to appointing liquidators in a court-ordered winding up covers it, and you can do it immediately or return to the eService later.
Once all three are in, the liquidation proper begins: creditors lodge claims, the liquidator investigates and realises assets, and distributions follow the statutory order of priority. If you are on the receiving end of that, our articles on proof of debt and the distribution of assets in a Singapore liquidation explain where you are likely to rank.
Frequently asked questions
Can I file the Winding Up Order before the Notice of winding up order?
No. The eService enforces the sequence. The Notice of order and liquidator appointment is the first filing, this is the second, and confirming the appointment is the third. Attempting to start at step two will simply drop you back into the beginning of the process.
What if the Court appointed the Official Receiver and there is no private liquidator?
The sequence is the same. The liquidator details carried forward into this form will show the Official Receiver’s particulars, which the system populated automatically at the first filing. You still upload the order and give the court filing date.
Do I need the original sealed order, or will a scan do?
You upload a copy, so a clear scan of the sealed order is what is required. Keep the sealed original in the liquidation file. The liquidator will need it for banks, registries and counterparties who will not accept a Bizfile printout.
Is there a deadline for this filing?
Treat it as immediate rather than looking for a grace period. The register is misleading while the order is not on it, and the practical consequences of a stale register fall on creditors and counterparties who had no way of knowing. File it in the same sitting as the first submission if you can.
Who pays the $20?
Whoever files. In practice it is absorbed by the liquidator’s costs or by the creditor’s corporate service provider. It is not worth arguing about, and it is not a reason to delay the filing.
The company disputes that it was ever insolvent. Does that change anything here?
Not at this stage. Once the order is made, the filing obligations follow. A company that believes the order should not have been made pursues that through the Court, not by declining to update the register. Our note on disputed debts and the AnAn standard covers the argument that should have been run earlier.
The small filing that nobody owns
Compulsory winding ups generate a lot of urgent work and this is not the urgent part. The order has been made, the liquidator is appointed, the status has flipped, and a $20 upload sits in a half-finished eService waiting for someone to decide it is theirs.
It usually is not anybody’s. The solicitors acted on the application, not the filings. The liquidator is dealing with assets. The directors have stopped answering. Six months on, a purchaser’s lawyers ask why the register carries a winding up status with no order behind it.
Raffles Corporate Services picks up exactly this kind of work: the ACRA filings that follow a court order, made properly and in sequence, whether we are acting for the entity, the liquidator or the creditor who obtained the order. If you are holding a sealed order and are not sure what still has to reach ACRA, get in touch. ACRA’s own overview of winding up a limited liability partnership is a useful companion if your entity is an LLP rather than a company, and there is further reading on Singapore corporate secretarial practice at Singapore Secretary Services.
The Editorial Team, Raffles Corporate Services
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