28 March 2025

On 18 March 2025, the Accounting and Corporate Regulatory Authority (“ACRA”) published the Financial Reporting Surveillance Programme Report 2024 (“FRSP Report”) and the accompanying Directors’ Guide to the Financial Reporting Surveillance Programme (“Directors’ Guide”).

The Companies Act 1967 (“Act”) imposes specific obligations on all directors of Singapore incorporated companies, regardless of their role or financial expertise, regarding financial reporting. The Directors’ Guide elucidates these responsibilities, focusing on sections 201(2) and 201(5) of the Act, which require directors to present financial statements that comply with the prescribed accounting standards and give a true and fair view of the company’s financial position and performance.

The Financial Reporting Surveillance Programme (“FRSP”), administered by ACRA since 2014, is a crucial component of Singapore’s financial reporting regulatory framework. Under the FRSP, ACRA reviews selected financial statements for compliance with the prescribed accounting standards and publishes FRSP reports summarising the activities and findings of the programme. These reports aim to help companies avoid common pitfalls and improve their financial reporting by enhancing their understanding of the interpretation and application of the prescribed accounting standards.

The FRSP Report reflects on the FRSP’s impact over the past 10 years, highlighting key observations and common findings from ACRA’s reviews. During the past decade, non-compliances (“NCs”) have been identified across different accounting areas. However, certain areas appear to be more susceptible to misstatements, namely presentation in financial statements, consolidation/equity accounting, presentation in cash flow statement, impairment of assets, and financial instruments.

From ACRA’s review of selected financial statements between 2022 and 2024, ACRA observes that while recognition and measurement NCs remain the most common, their proportion has decreased. Conversely, disclosure-related NCs have significantly increased, indicating an emerging area of concern. Notably, disclosure and presentation issues are generally less complex and can be more readily addressed with due diligence. ACRA notes that the substantial increase in NCs in these areas warrants closer scrutiny by management and directors.

The FRSP Report further analyses the distribution of material NCs across companies based on revenue, categorising them into two groups: those with revenues below S$100 million and those with revenues above this threshold.

The FRSP Report also provides an overview of the audit opinions received by listed companies from FY2021 to FY2023 and specifically examines the modified audit reports issued for FY2023.

The Directors’ Guide accompanies the FRSP Report and aims to provide directors with essential information regarding their financial reporting responsibilities and the FRSP regime. It is presented in the form of Frequently Asked Questions to address the following three key areas:

  • Directors’ statutory responsibilities under the Act regarding true and fair financial statements;
  • ACRA’s FRSP; and
  • Directors’ role and responsibilities in the FRSP process.

ACRA strongly recommends reading the Directors’ Guide in conjunction with the FRSP Report and other resources mentioned herein. Together, these documents provide a comprehensive overview of directors’ responsibilities, the FRSP process, and practical guidance for navigating financial reporting requirements.

For matters not addressed in the Directors’ Guide or the FRSP Report, particularly in relation to directors’ duties on financial reporting or the FRSP process, directors are advised to seek professional advice or contact ACRA for further clarification.

Reference materials

The Financial Reporting Surveillance Report 2024 and the Directors’ Guide to the Financial Reporting Surveillance Programme are available on the ACRA website www.acra.gov.sg.