Version, authority and responsibility
The source cites section 38(1)(a) of the then Accountants Act and Practice Direction 4of 2010. It describes mentoring by a suitably qualified practising or former public accountant to improve audit quality, while leaving the signing accountant solely responsible for engagements, judgement and opinion. Review should occur throughout the process and finish before completion and sign-off, rather than be arranged only at the end. The PDF has no explicit issue date, so none is invented. Its historical statutory reference differs from later versions and should not be presented as a verified current provision.
Selection under the individual order
Orders vary with findings’ severity and may cover all engagements signed during a specified period; most specify a number. Unless the order gives other criteria, the FAQ says selected engagements should be among top clients by audit fees, also considering turnover, profit and operational complexity. A question asks what happens if no client exceeds S$5 million turnover or if the required number cannot be completed. The answer is to notify ACRA one month before expiry with evidence for variation, which only the committee can grant. The question’s S$5 million figure is not expressed as a standalone universal selection rule; it must not be replaced by a later version’s different threshold or fallback formula.
Qualifications, approval and appointment delays
Prior ACRA approval is required, with no conflict or independence problem. A registered accountant who passed practice review qualifies; a former accountant who passed and remained current may also qualify. A reviewer should decline if unable to mentor effectively. The historical ICPAS list was a starting resource; if no reviewer is found or willing, contact ACRA, which can liaise with the pool. The extension question states that appointment submission is due within two weeks of the order and that a request for more time should be made within those two weeks. These timing details should be retained even though the earlier approval answer does not itself repeat them.
Changes in suitability and private engagement terms
Suitability is assessed upfront and after new information. If an approved reviewer later fails PMP during the reviewed accountant’s period, this version says ACRA allows continuation for that accountant but disallows subsequent appointments. It does not use the later version’s more specific ongoing-engagement wording. Compensation is private and need not be reported; no standard hours or fees are given because complexity varies. The appointment letter should cover scope, remuneration, confidentiality, responsibilities and conduct. Agree adequate time against sign-off, expiry and workload; there is no fixed minimum interval within the review period. Valid-delay extensions require one-month advance notice and remain discretionary.
Scope covers the whole engagement and permanent file
The reviewer uses professional judgement rather than a prescribed checklist or manual, while obtaining the complete ACRA findings report and remediation plan and helping implement actions. The entire engagement and permanent files should be reviewed, not selected papers only, with discussion of key issues and high-risk work. Audits must comply with SSAs and statements with the then Companies Act and Singapore FRSs. Practice Direction 4of 2010 supplies further scope details. Discretion over review method does not permit ignoring standards or limiting the review to paperwork unrelated to the deficiencies.
Reports and compliance lists are separate obligations
A written report is needed to demonstrate review and compliance, with AnnexA minimum contents although format is discretionary. Routine report submission is not required: PMP reviewers examine it at revisit, and ACRA may request it. Separately, question 26 expressly requires the accountant to inform ACRA of compliance and supply a list of reviewed audit files and reviewer names. A no-routine-report-submission answer does not remove that separate notification obligation. Failure to appoint a reviewer or complete the process can result in disciplinary or enforcement action, or both.
Annex A: the accountant’s complete engagement record
Minimum report information includes both accountants’ identities and reviewer registration, entities and financial year-ends, engagement letters, partner and manager tenure, report type and sign-off, subsequent-event date, activities, materiality, performance materiality and uncorrected detected misstatements, approach, risks, issues, discussions and judgement bases, hours, findings, commencement and completion, reviewer signature and report date. Suggested SectionA has sixteen numbered fields, additionally identifying the firm and group materiality where applicable, and ends with the reviewed accountant’s signature, name and registration number. The template uses hot-review partner wording, but that label does not override the FAQ’s express allowance for a qualified former accountant.
Annex A: the reviewer’s involvement record
Suggested SectionB contains eight fields: commencement date, completion date, hours, planning discussions, key-issue discussions, significant-judgement basis, the proposed opinion discussion and report date. The reviewer signs with name and registration number. Together with the engagement-specific findings required by the minimum list, these records show what was actually reviewed and discussed. Empty form lines are placeholders rather than evidence; the actual facts and conclusions of each review are needed. This article preserves the older form and procedure rather than retroactively importing a later template.
Official source
This article independently explains the substantive contents of the official PDF, including the relevant conditions, procedures and annexes. The linked document remains the authoritative source for its original wording, and later changes should be checked separately.
Read the official PDF ↗