If a Singapore company’s accounting records are incomplete or years behind, the directors must still submit a statement of affairs. The usual approach is to reconstruct the figures as at the relevant date from third-party records (bank statements, IRAS and GST filings, CPF records, ACRA BizFile, invoices, supplier statements and emails), label every estimate and its basis, and list the gaps in a short note. Tell the liquidator or Official Receiver early, ask in writing for any extension you need, and never leave a section blank or guess without saying so.
This guide is for directors, company secretaries and finance staff facing a statement of affairs deadline with poor records. It reflects the law and Insolvency Office guidance as at 6 November 2026.
Do you still have to submit if the books are incomplete?
Yes. In a court winding up, section 141 of the Insolvency, Restructuring and Dissolution Act 2018 (IRDA) requires one or more directors and the company secretary to submit a statement of affairs within 14 days after the winding up order. Similar duties apply in judicial management, in a creditors’ voluntary winding up and in the simplified winding up programme. Our guide on what a statement of affairs is compares them.
Poor records are not, by themselves, a reason not to file. What the law asks is that the statement is true to the best of your knowledge and belief: that is the wording of the affidavit on Form CWU-7. That standard is achievable even with gaps, provided you show what you know, how you know it, and what you could not establish.
The record-keeping duty itself is a separate issue, covered in our article on failing to keep proper accounting records. This guide is about the practical job in front of you: producing an honest statement on time from what is left.
What should you do in the first few days?
- Fix the date. In a court winding up the statement is as at the date of the winding up order. In judicial management it is the date the company entered judicial management. Every figure must be measured at that date, not today.
- Write to the Official Receiver or liquidator. Say plainly that the books are incomplete, roughly for which period, and what you are doing about it. Early candour is far better than an incomplete statement arriving without warning.
- Ask for access to the records. After a winding up order, the liquidator takes control of the company’s property, and officers must hand over the company’s books. You may need the liquidator’s help, or the liquidator’s consent, to get copies of bank statements and files.
- List what exists and what is missing. Make an inventory: which bank accounts, which months of ledgers, which invoices, which logins still work.
- Ask for an extension early if you need one. Section 141(3) allows the Official Receiver, liquidator or court to extend the 14 days for special reasons. Ask in writing, before the deadline, with a short plan showing what you will deliver and when. Our article on the statement of affairs deadline explains the timings in each procedure.
Where can you rebuild the figures from?
Most of a company’s financial life is recorded somewhere outside its own ledger. The trick is to match each source to the schedule it supports. The schedule letters below refer to Form CWU-7, explained in our guide to statement of affairs contents.
| Source | What it tells you | Schedules it supports |
|---|---|---|
| Bank statements for every account | Cash balance at the date; receipts from customers; regular payments that identify suppliers, landlords, lenders and staff | B3 cash, A receivables, G creditors, F1 employees |
| IRAS records (Notices of Assessment, filed GST returns, statements of account) | Tax owed and periods unfiled; GST returns also show sales and purchases totals for each period | F4 tax; cross-check of sales and purchases |
| CPF employer contribution records | Contributions paid and missing months for each employee | F3 CPF, F1 employees |
| ACRA BizFile business profile | Registered charges, shareholders, share capital and officers | C security, E unpaid share capital |
| Sales invoices, e-invoices, email and messaging apps | Amounts billed to each customer; disputes and promises to pay | A receivables, D contingent assets |
| Supplier statements, letters of demand, court papers | Amounts creditors say they are owed; lawsuits | G unsecured claims, H contingent claims |
| Leases, hire purchase and loan agreements | Deposits, monthly instalments, balances, security | B7 deposits, C security, G |
| Last filed financial statements and auditor or accountant files | Opening balances for fixed assets, loans and share capital | B4 assets, E, G |
| Payment platforms and cloud accounting logins | Card and online sales; partial ledgers | A, B2, G |
If the previous bookkeeper left with the logins or files, our guide on recovering records after a bookkeeper leaves sets out where to look. If GST returns were not filed, IRAS may have raised estimated assessments, which show as tax owed even though they may not reflect the real figures. Our article on missed GST returns and estimated assessments explains how they arise. List the amount IRAS says is owed and note that it is an estimated assessment.
How do you reconstruct each part of the statement?
Cash and bank
Take the balance on each bank statement at the relevant date. This is usually the most reliable figure in the statement. Include accounts held in foreign currency, converted into Singapore dollars, and any payment platform balances.
Receivables
List every invoice issued in the period you can reconstruct, then tick off customer payments from the bank statements. What remains unpaid is the starting list of receivables. Check old balances against emails for disputes and credit notes before stating them, and write down to a realistic recoverable amount with the reason.
Assets
Start with the fixed assets in the last financial statements, add purchases visible in bank payments since then, and remove anything sold or scrapped. Then walk the premises, if you still can, or ask the liquidator to compare your list with what is physically there.
Creditors, employees and tax
Ask every supplier you can identify for a statement of account as at the relevant date. Recurring payees in the bank statements point to suppliers you may have forgotten. For employees, rebuild unpaid salaries and leave from employment contracts, payslips and the last payroll run, and check CPF records for missing contribution months. For tax, rely on what IRAS shows as owing.
How do you show estimates and gaps honestly?
The Insolvency Office’s explanatory note for Form CWU-7 says no schedule or part of one should be left blank intentionally. That does not mean you must invent a number. It means every question needs an answer, and where the answer is uncertain, the uncertainty must be visible.
| Situation | Weak approach | Better approach |
|---|---|---|
| Ledger missing for the last 18 months | Copy figures from the last audited accounts | Rebuild from bank statements and say so in the details column |
| Customer balance uncertain | Leave the customer out | List the customer with your best estimate and the basis, for example “invoices issued less receipts per bank statement” |
| Supplier has not replied | Enter nil | Enter the last known balance and note “supplier statement requested on 3 November 2026, not received” |
| Fixed asset may no longer exist | Include at book value | Include with a note that its location and condition are unconfirmed, and a cautious realisable value |
| Possible claim against a former employee | Ignore it | Disclose it as a contingent asset with the facts known |
It also helps to give the Official Receiver or liquidator a short covering note on the basis of preparation. Set out which periods were reconstructed, the sources used, the records that are missing, what you did to find them, and who might hold them (a former bookkeeper, an overseas parent, a software provider). This note is not part of the prescribed form, but it puts your explanations in one place and shows the liquidator where to look next.
What are the risks if the gaps are not explained?
- Failure to submit. Defaulting on section 141 without reasonable excuse can lead to a fine of up to S$10,000, up to 12 months’ imprisonment, or both, plus a default penalty. Waiting for perfect records is not a reasonable excuse for missing the deadline without asking for more time.
- Material omissions. Under section 234(1)(d) of the IRDA, a past or present officer who makes a material omission in any statement relating to the affairs of a company being wound up commits an offence (fine up to S$10,000 or imprisonment up to 2 years). It is a defence to prove no intent to defraud, and a clearly explained gap is the best evidence of that.
- Duty to cooperate. Under section 243, officers must give the liquidator information and attend when reasonably required. Expect follow-up questions on every estimate. In serious cases the liquidator may seek a public examination of company officers.
- Disqualification. Under section 149 of the Companies Act 1967, a director of an insolvent company that went into liquidation can be disqualified for up to 5 years if found unfit. In deciding this, the court considers the director’s responsibility for the company’s failure to comply with record-keeping and other duties, including section 199 on accounting records.
The Insolvency Office states that, apart from prosecuting officers who fail to file the statement of affairs, it can pursue offences including failure to keep proper accounts.
What does a reconstruction look like in practice?
Example: This is a hypothetical example, not a client case. A small trading company stopped updating its books 20 months before a creditor obtained a winding up order. The finance executive had resigned, and the cloud accounting subscription had lapsed. The two directors have 14 days.
On day 1 they write to the Official Receiver explaining the gap and asking for copies of the bank statements, since the bank accounts are now under the liquidator’s control. They restore read-only access to the accounting software, which gives them reliable ledgers up to the last bookkeeping date. They download filed GST returns and tax statements from IRAS and CPF contribution records. From the bank statements they identify 23 regular payees and write to each for a statement of account.
By day 10 they have reliable cash, tax, CPF and employee figures, and receivables rebuilt from invoices and bank receipts. Six suppliers have not replied. On day 11 they ask for a two-week extension, explaining the outstanding confirmations, and propose to submit the statement with those six balances estimated from the last known invoices and clearly flagged. The covering note lists the missing records and where they may be. Whether to grant the extension is for the Official Receiver, but the directors have shown reasonable effort and an honest basis for every figure.
Frequently asked questions
Do we need to bring the full accounts up to date before submitting?
Not usually. The statement needs figures for assets and liabilities at one date, not full financial statements for every missed year. Focus on balances that matter to creditors: cash, receivables, assets, and every creditor. Ask the liquidator if they need more.
Can I write “unknown” for a figure?
Use it sparingly. A reasoned estimate with a note is more useful than “unknown”. Where you truly have no basis for a number, say why, what you tried, and who may know.
The liquidator now has the company’s records. How do I prepare the statement?
Ask the liquidator for access to, or copies of, what you need, and record your requests in writing. Liquidators generally want an accurate statement too, so a specific request for named documents is usually more productive than a general one.
Can the cost of reconstructing the records be paid by the company?
Section 141(4) allows reasonable costs of preparing the statement to be paid out of the company’s assets, as the Official Receiver or liquidator considers reasonable, subject to appeal to the court. Agree the scope first, because an insolvent company may have little to pay with.
What if I find a mistake after submitting?
Tell the Official Receiver or liquidator promptly in writing, with the corrected figure and the evidence. Correcting an error yourself is far better than having it discovered later.
Need help preparing a statement of affairs from incomplete records?
Raffles Corporate Services can help you rebuild the figures for a statement of affairs by gathering bank statements, IRAS and CPF records, reconciling debtor and creditor balances, and setting out the estimates and gaps clearly for the liquidator, Official Receiver or judicial manager.
If your company, or you as a director or shareholder, is dealing with a statement of affairs deadline and incomplete company records, contact the Raffles Corporate Services team at [email protected] or on WhatsApp at +65 8501 7133 or +65 9018 0072. We will help you understand the documents and deadlines. Where your matter needs a lawyer, we will refer you to a firm on our panel of Singapore law firms that regularly handles insolvency and winding up matters. Raffles Corporate Services is a corporate services provider, not a law firm, and this article is general information, not legal advice.
Kevin Yeo, Raffles Corporate Services