Circuit Breaker Measures for Singapore Company Audit Practices

The ongoing COVID-19 pandemic and corresponding Circuit Breaker regulations have had a major impact on many companies and businesses, not just financially but also in administrative matters. Statutory requirements and financial audit practice are no exemption to these operational measures and changes in Singapore.

In recognition of these administrative complications key financial institutions in the country, the Accounting and Corporate Regulatory Authority (ACRA), Monetary Authority of Singapore (MAS) and the Singapore Exchange Regulation (SGX RegCo), have instated deadline extensions for various annual statutory requirements mandated under the Companies Act.

These include the extension of the deadline for issuing annual reports to company shareholders, as well as the extension of deadlines for holding annual general meetings (AGMs) and filing annual returns to the ACRA. These changes are intended to provide ample time for Singapore companies to adjust to the new Circuit Breaker measures and plan their schedules for compliance with local statutory requirements.

ACRA filing deadlines

Listed and non-listed Singapore companies with AGM due dates falling between 16 April 2020 to 31 July 2020 are automatically granted a 60-day extension. For example, if a company is required to hold a mandatory AGM by 30 June 2020, the latest the companies head members may convene to conduct its AGM is by 29 August 2020.

The deadline for filing Annual Returns for listed and non-listed Singapore companies whose due date falls within 1 May 2020 to 31 August 2020 has also been extended for a maximum of 60 days. This gives companies more time to prepare their financial statements and finalise any audited financial statements within the extension period.

Both the AGM and annual return filing extensions are outlined in the Companies (Amendment No. 2) Regulations 2020 published by the ACRA on 15 April 2020. The Authority has also issued an Audit Practice Bulletin to guide public accountants in the conduct of audits during the COVID-19 situation.

SGX and MAS rulings

SGX RegCo, with the concurrence of ACRA and MAS, has extended the AGM deadline for all listed companies with Financial Year-Ends (FY-end) on or before 31 March 2020 by 60 days. Annual reports must be issued 14 days before the AGM. For companies with 31 December Financial year end, AGM must be held before 29 June 2020, and would have issued their annual reports by 15 April 2020. The following table summarizes key deadlines for respective year ends:

Financial Year End	New AGM Due Date	New Annual Report Due Date
31 December 2019	29 June 2020	15 April 2020
31 January 2020	30 July 2020	15 July 2020
29 February 2020	29 August 2020	14 August 2020

Following the issuance of the COVID-19 (Temporary Measures) (Alternative Arrangements for Meetings for Companies, Variable Capital Companies, Business Trusts, Unit Trusts and Debenture Holders) (Amendment No. 2) Order 2020 by the Ministry of Law on 24 April 2020, companies holding AGM must adhere to safe distancing guidelines should physical presence be required for “virtual meeting”.

SGX RegCo will also grant an automatic 2-month extension to listed companies with financial year-ends (FY-end) of 29 Feb 2020 or 31 March 2020 as well as a 1-month extension to issuers with a 30 April 2020 FY-end, to release their full year unaudited results.

Singapore companies and businesses can better adapt to the recent changes in the conduct of financial matters with the help of sound advice from experts. As the country starts to adjust to the Circuit Breaker guidelines designed to curb the spread of COVID-19, seeking professional accounting assistance can significantly ease these concerns and ensure compliance in times of uncertainty.