Applying to ACRA for Financial Reporting Relief

ACRA can exempt a company from complying with the accounting standards, and can relieve it from some of the form and content requirements for its financial statements and directors’ statement. Both are discretionary, both cost $200, both take around 30 working days, and both are granted rarely.

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.

That last point is the one to absorb before you spend anything. These are not administrative concessions. They are exceptions to a regime designed to keep every Singapore company’s accounts comparable, and the Registrar guards that comparability closely.

So the useful question is usually not “how do I apply” but “is there a route that does not need an application at all”. Very often there is. Here is what each relief covers, what it does not, and what to test first.

What the law actually requires before any relief

Two obligations sit behind everything on this page.

Accounting standards and the true and fair view. Section 201(2) of the Companies Act 1967 requires a company’s financial statements to comply with the accounting standards and to give a true and fair view of its financial position and performance. The accounting standards are those issued by the Accounting Standards Committee, which in practice means the SFRS family, including SFRS(I) and SFRS for Small Entities.

The directors’ statement. Section 201(16) requires the financial statements to include a directors’ statement, and the Twelfth Schedule to the Act sets out what has to go in it. Among other things, that includes disclosure of directors’ interests in shares in, or debentures of, the company and related bodies corporate.

Relief, where it exists, is relief from one of those two things. Nothing on this page touches the audit requirement, and nothing on this page changes the filing deadlines. If your question is really about audit, the separate test is the small company concept set out in the Act’s schedules, not a relief application.

Relief from the accounting standards, under section 201(12)

This is the exemption you need if you want to prepare financial statements under a framework other than the standards issued by the Accounting Standards Committee.

ACRA grants it in limited circumstances only, and the stated reason is fairness: if one company can report on its own chosen basis, the register stops being comparable and every user of it, from banks to acquirers to the Registrar itself, loses something.

If what you actually want is IFRS, do not apply

This is the most common reason companies start down this road, usually because an overseas parent or an investor has asked for IFRS accounts.

ACRA generally does not approve exemptions to allow financial statements to be prepared under IFRS alone. You do not need one. Apply SFRS(I), which is convergent with IFRS, and state in the financial statements that they simultaneously comply with IFRS. That gives the overseas reader exactly what they asked for, it costs nothing, and it needs no application.

Nine times out of ten the conversation ends there. Our note on preparing your company for financing covers what lenders actually look for in the accounts.

Timing matters more than you think

An application to be exempted from compliance with the accounting standards takes about 30 working days to process, and ACRA asks that you submit it at least six months before your filing deadline.

Six months is not padding. If the application is refused and you have already prepared the accounts on the framework you hoped to be allowed, you have to redo them, get them re-audited where applicable, put them to the members and still file on time. Work backwards from your annual return deadline, set out in our Annual Return Filing in Singapore guide, and the stated lead time makes sense.

Relief from disclosure requirements, under section 202

The second route is relief from requirements as to the form and content of the financial statements and the directors’ statement.

Again, ACRA grants these in very limited cases. The application is judged on whether the disclosure genuinely produces an outcome the Act did not intend, not on whether the company would prefer not to disclose.

What section 202 relief does not cover

Two things get asked for constantly and neither is available here.

Audit exemption. That is a separate statutory test, not a discretionary relief. A company qualifies as a small company on the statutory criteria or it does not, and no application is involved. Check the small company test before you pay for anything.

A single director signature on the directors’ statement. Where two or more directors hold office, the directors’ statement must be signed by at least two of them. This holds even when one director is abroad for an extended period, uncontactable, or in open dispute with the others. It is precisely in those situations that companies apply, and it is precisely in those situations that the answer is no. The solution is a governance one: appoint a director who will sign, or resolve the dispute. Our Companies Act 1967 deep-dive FAQ covers the surrounding director duties.

The automatic relief most companies should be using instead

There is one meaningful disclosure relief that requires no application, no fee and no waiting.

Since 9 December 2024, non-listed public companies and private companies do not have to disclose directors’ interests in shares in, or debentures of, the company and related bodies corporate, provided two conditions are met:

1. The directors declare in the directors’ statement that all members have consented to the exclusion of that information.
2. The company confirms that consent when it files its annual return.

Note what this is and is not. It is not a relaxation you can assume. It depends on all members consenting, and on the directors saying so on the face of the statement. If one member has not consented, the disclosure goes back in.

The annual return question that trips people up

When you file the annual return and financial statements, you are asked whether the directors’ statement includes directors’ interests in shares or debentures.

If your company has no such interests to report, the instinct is to answer no. That is wrong. You should still select Yes, because the directors’ statement does still address the point: it indicates that the company has no such directors’ interests, which is itself the disclosure. Answering no in that situation creates an inconsistency between your filed statement and your filed annual return, and inconsistencies are what surveillance programmes look for.

For related disclosure questions in the same part of the accounts, see our note on key management personnel compensation disclosure under FRS 24.

Cost, timing and how to lodge

The application goes through the General lodgement eService on Bizfile.

1. Open the General lodgement eService and log in with Corppass. If Corppass access is not yet set up for the company, do that first: see Logging In to Bizfile as a Business User.
2. Select the correct lodgement type. There is one for an application under section 201(12) for exemption from compliance with the accounting standards, and a separate one for an application under section 202 for relief from requirements as to form and content.
3. Complete the application form and attach it, together with your supporting documents.
4. Pay the $200 and submit. Keep the transaction reference.

The fee is non-refundable whether or not the application succeeds, so the quality of the written case matters. State the specific requirement, the specific consequence of applying it to your facts, and why that consequence was not what the Act was aiming at. A general assertion that compliance is burdensome will not carry it.

What goes wrong in practice

Applying when a free alternative exists. The IFRS case is the classic: $200 and 30 working days spent on an application nobody needed, when stating simultaneous compliance with IFRS in SFRS(I) accounts would have done the job.

Applying too late. An application filed two months before the deadline leaves no room to recover if it is refused. You still have to file on time, and late filing carries its own penalties regardless of what was pending.

Assuming the automatic directors’ interest relief applies. It requires every member’s consent and a declaration in the directors’ statement. Drop the disclosure without both limbs and you have an inaccurate directors’ statement on the public record.

Confusing relief with audit exemption. Different mechanisms, different tests. Paying $200 to ask for something the Registrar does not grant under that provision is a wasted fee and a wasted month.

Filing accounts that do not match the relief. If relief is granted, any XBRL filing must reflect the same figures and the same basis. Our XBRL filing guide covers how the filed data is expected to tie back to the signed accounts.

Frequently asked questions

Can I get permission to prepare my accounts under IFRS instead of SFRS?
Generally no, and you almost certainly do not need to. Prepare the financial statements under SFRS(I) and state that they simultaneously comply with IFRS. This gives an overseas parent or investor what they want, costs nothing and requires no application to ACRA.

How much does a financial reporting relief application cost?
$200, and the fee is non-refundable whether the application is approved or refused. It is paid when you submit the application through the General lodgement eService on Bizfile.

How long does ACRA take to decide?
Around 30 working days. For an exemption from compliance with the accounting standards, ACRA asks that you apply at least six months before your filing deadline, so that there is time to prepare compliant accounts if the application is refused.

Only one of my two directors will sign the directors’ statement. Can I apply for relief?
No. Where two or more directors hold office, at least two must sign. Absence, being uncontactable or being in dispute with the other directors does not change that. The fix is to resolve the governance problem or appoint an additional director.

Do we still have to disclose directors’ interests in shares?
Not necessarily. Non-listed public companies and private companies can exclude that disclosure if the directors declare in the directors’ statement that all members have consented, and the company confirms that consent when filing its annual return. Both limbs are required.

Does financial reporting relief give me audit exemption?
No. Audit exemption is a separate statutory test based on the small company criteria, and it is not something you apply to ACRA for. Check that test first, because it is the question most companies asking about relief are really asking about.

Before you spend the $200

Most of the relief applications we see described do not need to be made. The requirement causing the problem usually has an answer inside the standards, inside the automatic relief, or inside the audit exemption test, and the answer is free.

Raffles Corporate Services prepares and files financial statements and annual returns for Singapore companies across the size range, and we will tell you plainly when an application is worth making and when it is not. If a parent company, auditor or investor has asked for something your current reporting basis does not seem to allow, that is usually a half-hour conversation rather than a lodgement.

The underlying provisions are in the Companies Act 1967 on SSO, and ACRA’s financial statement preparation pages set out the related obligations. You can also read more on Singapore corporate secretarial practice at Singapore Secretary Services.

— The Editorial Team, Raffles Corporate Services