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Preparing for an ACRA inspection, before the letter arrives.

How do you prepare for an ACRA inspection?

ACRA inspects in two ways: a practice review of a public accountant's audits under the Practice Monitoring Programme, and a quality control review of the firm's system of quality management against SSQM 1 and SSQM 2. The preparation is the same work as a good audit: files that show, on their own, what was done and why, a quality management system that is documented and tested, and a clear view of the areas where inspectors most often find problems.

The two kinds of inspection

  • Practice review (engagement inspection). Practice reviewers appointed by the Public Accountants Oversight Committee (PAOC) inspect a selection of a public accountant's audits against the Singapore Standards on Auditing and other requirements. For public accountants who do not audit listed companies, the reviewers are generally ISCA employees appointed by the PAOC.
  • Quality control review (firm level). Entity reviewers appointed by the PAOC (Firm Level), the committee without its public accountant members, assess the firm's quality controls against SSQM 1 and SSQM 2. ACRA has had statutory powers for these reviews since 1 July 2023.

Selection is risk-based: ACRA's profiling looks at factors such as the public accountant's capacity and capabilities, the complexity of the engagements and the public interest involved. The result of a firm's quality control review feeds into how intensively its engagements are inspected.

How it runs

Practice review: the reviewers inspect the selected audits; the Practice Monitoring Sub-Committee, made up of experienced public accountants and lay members, considers the findings and recommends an outcome; the PAOC decides.

Quality control review: the entity reviewers assess the firm's system; the Registrar of Public Accountants considers the findings and reports to the PAOC (Firm Level) with recommendations; the PAOC (Firm Level) decides. ACRA describes interviews on the firm's quality objectives, risks and responses, followed by walkthroughs, re-performance and independent testing of whether the policies work.

The four outcomes

Both programmes use the same four outcomes.

  • Satisfactory: the standards were met in all significant respects, with no non-compliance.
  • Satisfactory but with findings: met in all significant respects, with limited or minor non-compliance.
  • Partially satisfactory: many minor, or more than minor, instances of non-compliance, none of them significant or severe.
  • Not satisfactory: extensive, significant or severe, or repeated non-compliance.

In a practice review, each finding is weighed for how far the work departs from the standard and the materiality of any misstatement, and the PAOC also takes the public accountant's inspection history into account. In a quality control review, findings are weighed by their nature, severity and pervasiveness.

What can follow

After a partially satisfactory or not satisfactory practice review, the PAOC may order:

  • structured training;
  • a root cause analysis and a remediation plan that addresses the causes;
  • a hot review, in which another public accountant reviews a set number of audits before the reports are signed.

After a not satisfactory outcome, it may also:

  • restrict which audits the public accountant may sign, for example public interest entities or companies above a size;
  • for a public interest entity audit, order the findings sent to its audit committee or board;
  • suspend or cancel the public accountant's registration.

The root cause analysis and remediation plan are due within one month of being told the outcome, and ACRA checks that the actions link back to the findings. ACRA publishes not satisfactory outcomes, and failures to comply with orders, under its Practice Direction No. 1 of 2024.

Our checklist for a Singapore audit firm

These are Nebis's suggestions, drawn from ACRA's process and its published findings.

  1. Read a file as a stranger would. Pick recent files and ask whether an experienced auditor with no contact with the team could see what was done, by whom, and why the conclusion holds.
  2. Start with the common themes. Accounting estimates, the auditor's report and group audits lead ACRA's engagement findings; fraud risk assessment and business combinations were new to the top five in 2024. See what ACRA's inspections find.
  3. Check the auditor's reports. Every required element, the right opinion for the facts, and, since 6 May 2026, the name of the public accountant primarily responsible.
  4. Check archiving. Files assembled within the firm's deadline, which should ordinarily be no more than 60 days after the report date. See SSA 230 file assembly.
  5. Back independence with evidence. Test personal declarations against records, and monitor non-assurance service approvals, fee levels, overdue fees and rotation.
  6. Bring the SoQM up to date. Quality objectives complete, risk ratings applied consistently, a monitoring plan that covers the key responses, the annual evaluation done, and safeguards where one person holds several roles.
  7. Make the EQR visible. The engagement quality reviewer's scope, timing, what was challenged and how it was resolved, recorded through the audit.
  8. Close earlier findings properly. Show the root cause of each, not the symptom, and evidence that the remediation worked. ACRA's Audit Practice Guidance No. 1 of 2024 covers this.

During and after the inspection

Inspectors judge the work on what was known and done up to the date of the auditor's report. SSA 230 lets a firm clarify existing documentation after the file is assembled, including in response to inspection comments, but each change must record why it was made, when and by whom, and who reviewed it. Nothing added later can show work that was not done before the report date. In our view, any change made after the inspection notice should be pointed out to the reviewers. Explain judgements from what the file shows, and put any disagreement and its reasons in writing, since the findings go to a committee for a decision.

If the outcome needs a remediation plan, the one-month deadline is short. Starting the root cause analysis when the findings arrive, rather than when the outcome is formally notified, leaves more time to get it right.

How the Nebis audit workspace approaches these points

In the Nebis workspace, AI prepares and the firm's people review and sign. Each answer carries its reasoning and evidence, and every change, sign-off and upload is kept in the engagement's audit trail. The report cannot be signed until the engagement quality review is complete. At archive, the file becomes a pack of the final papers, the evidence and the audit trail, readable without Nebis. Where the firm uses the SSQM module, automated tests read the engagement records for its monitoring.

How it works · SSQM module · EQR module

Sources: ACRA: PMP process and outcomes · ACRA: PMP orders · ACRA: QC review process · ACRA Audit Regulatory Report 2024 (PDF) · ACRA Audit Practice Guidance No. 1 of 2024 (PDF). This guide summarises the source in our own words; read the source for its full text. It is general information, not advice for a particular engagement.

Questions

Asked and answered.

Who carries out ACRA inspections of smaller audit firms? +
For public accountants who do not audit listed companies, practice reviews are generally carried out by ISCA practice reviewers appointed by the Public Accountants Oversight Committee, under ACRA's oversight. ACRA decides which public accountants and engagements are reviewed and calibrates the findings.
What is a quality control review? +
A review of an accounting entity's system of quality management against SSQM 1 and SSQM 2, by entity reviewers appointed by the PAOC (Firm Level). ACRA has had statutory powers to carry it out since 1 July 2023.
What happens after a partially satisfactory outcome? +
The PAOC may order remedial action: structured training, a root cause analysis and remediation plan, or a hot review of a set number of audits before their reports are signed. The root cause analysis and plan are due within one month of notification.
Are ACRA inspection outcomes published? +
Not satisfactory outcomes, and failures to comply with orders, are published under ACRA's Practice Direction No. 1 of 2024.
Can we update the file after we hear about the inspection? +
SSA 230 allows existing documentation to be clarified after assembly, including in response to inspection comments, with a record of why, when and by whom each change was made and reviewed. A later addition cannot show work that was not done before the report date, because the work is judged on what was known and done up to then.

See a file that explains itself.

A walkthrough of the Nebis audit workspace on a sample file: reasoning and evidence behind each answer, the audit trail, EQR and the archive pack.

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