Scope of the September 2026 renewal guide
The seventh edition published on 1 September 2026 applies to existing ACAP businesses and their independent reviewers. Renewal is lighter than first-time review: a three-month test period within a 12-month review year, tax-classification walk-throughs, targeted controls testing for changes, lower substantive samples and a simplified report. Existing controls must still be effective at entity, transaction and reporting levels. The four appendices cover methodology, post-renewal PAR, certified final PAR and transaction/reporting risks.
Invitation, application and final deadline
IRAS invites renewal 15 months before expiry. Submit GST F 29 through FormSG within three months of invitation, after self-assessment. Begin review following acceptance and deliver the declaration and package within three months after original expiry. Start planning at the beginning of the final status year. A renewal application after expiry is treated as a new application with first-time review scope; delaying can also require Final PAR and scheme certification.
Eligibility and score changes
Maintain all key SRC controls, with each key control having at least 60% of listed/equivalent features and every level at least 60%. Premium retention or Merit upgrade requires at least 80% control-framework scores; otherwise renewal may be Merit for four years. Latest audited accounts must be unqualified, no current IRAS GST audit, good GST/income/property/withholding-tax and Customs compliance, no outstanding tax and a qualified reviewer. Instalment amounts/next GIRO are excluded from outstanding tax; surveys/ruling clarifications are not audit contacts.
Benefits and renewed duration
Renewed Premium lasts six years and Merit four from original expiry. Accepted renewal applicants are excused the Final PAR otherwise due six months before expiry. Benefits include reduced GST interventions, faster anomaly-free refunds/rulings and applicable scheme auto-renewal, subject to major anomalies or policy-change risks. Timely non-wilful disclosures can receive VDP relief, but the renewal grace rules must be assessed separately from report deadlines.
Penalty grace and review-year selection
Choose the latest filed 12 months at commencement, with reviewer concurrence, falling within the final two status years. The Review Year grace ends one year after the statutory filing deadline for its last return: disclose by then to waive the 5% late-payment penalty for non-wilful Review Year errors meeting VDP conditions. Earlier errors use their own return filing dates. An earlier grace deadline can require submission before the normal three-month deadline. The guide example has 15 February 2026 expiry and 16 May 2026 submission; January–December 2024 review requires disclosure by 31 January 2026, April 2024–March 2025 by 30 April, whereas later windows have July/October grace dates. The last sentence of that example prints 2024 instead of 2026; follow the stated period/date relationship rather than this inconsistent historical-example typo.
SRC by registration structure
A single registrant can submit one entity SRC, highlighting different unit features or electing separate transaction/reporting sections. Groups can consolidate entity/reporting sections only if controls do not differ significantly, while each member completes transaction controls. Divisional registrants may consolidate entity controls but complete transaction/reporting per division. F 29 includes individual and aggregate score summaries; full SRC goes to reviewer and final submission. Explain Premium-to-Merit score drops, missing prior controls and mitigating actions.
Preparation and trend evidence
Identify business/process changes since the last PAR or review, including staff, outsourcing, systems, tax logic, models and legislation. Update flows and identify high-risk income/expenditure and non-revenue GST items such as claimed-input gifts above S$200, payroll/benefits, CA, RC and OVR marketplace/redeliverer/overseas-establishment supplies. Compare year-on-year and period-on-period returns, reconcile supplies to accounts and every figure to listings. Explain anomalies and provide per-member/unit contributions, trial balances, audited accounts, tax tables and changed organisation/GST-responsibility charts.
Reviewer qualifications and independence
External PAEs/tax affiliates require an SCTP GST Advisor lead, partner/director oversight and recognised audit methodology; first-time firms need screening. Internal teams need a professional accounting/audit lead, accredited GST member and independent non-executive audit-committee reporting, including overseas equivalents. Joint teams follow lead eligibility. Prior return preparation/review requires a different year or entirely separate staff-to-partner team; process-design staff cannot conduct the review.
Risk assessment and three-month test
Verify control existence/scores, industry risks, missing features and change impact; investigate substantial score reductions. Interview overall GST leaders and inspect evidence of oversight, updated risk policy, communication and monitoring including Missing Trader Fraud. Select representative higher-risk/value three months, potentially non-consecutive for monthly filers, covering improvements operated at least three months and major changes. Exceptional transactions outside the test window still need procedures. Compare listings with accounts both ways. Group analytical coverage should include at least 50% of supplies/purchases and members; two-member groups select both. Divisions provide each listing.
Tax-classification walk-through sample counts
Cover every applicable supply/input/CA/RC/OVR category, including system and manual classification. Centrally reported single registrants use at least one system-coded and one manually coded transaction per category. Decentralised singles, groups and divisions with up to three units/members/divisions use one of each; four to five use two of each; six or more use three of each. Group counts follow members, not business units inside each member. Errors require expansion to other streams. Verify actual source documents, posting, written decisions and system logic.
Reporting walk-through and partial exemption
Trace extraction, compilation and submission, automated checks and preparer/approver review evidence. Decentralised arrangements cover 50% of members/units/divisions plus consolidator and approver. September 2026 expressly requires examination of partial-exemption input recovery and longer-period adjustments where applicable. Reconcile all figures in test-period returns to listings/schedules, recompute and investigate differences; verify residual apportionment, deemed output tax and unpaid RC adjustments.
When changes require extra controls testing
Untested major new models/processes require walk-through, control tests and substantive review, with at least five samples per new model/process and substantive tests on the same items. Examples include outsourcing accounting/return/inventory functions, moving manual tax decisions into automated logic, new retail/property operations and CA/RC/OVR legislation. Correctly mapped new products under existing controls, unchanged controls after a system change with user acceptance tests, and new/renamed codes with updated extraction can omit controls testing but still require walk-through/substantive checks. Other waivers need prior approval. Previously tested unchanged processes need not be retested absent control/legal changes.
Material items and the 30%-of-count rule
Select material/high-risk transactions across all categories and verify value, tax treatment, timing, scheme requirements and evidence. The baseline is 30% of each category’s transaction count, rounded up, capped at the applicable table number; if a category appears only outside the test period, sample another period in the review year. New-process samples are additional to these. If gaps suggest errors or material transactions exceed minimums, increase each relevant category by at least five and record findings. For nine standard-rated and 200 zero-rated transactions in category A, the example selects three and 25, not nine and 60.
Categories A, B, C and D
Category A covers a centralised single registrant, decentralised singles with up to three units, groups with up to three members and up to three divisions. Category B covers decentralised singles/groups/divisions with four or more. Category C is offshore, wholesale or merchant banks; D is full banks including foreign full banks. These classifications determine the substantive table, and must not be confused with the one/two/three walk-through counts.
Insurance/finance and residential-developer table
For regulation-34 businesses excluding banks, and residential sale/lease developers, category A/B table numbers are standard-rated 10/20, zero-rated 10/10, exempt 20/25, out-of-scope 5/5, input claims 25/35 and import schemes 10/15. Other schemes are marked inapplicable. CA made/received each uses 2–12, RC 5–15, OVR remote services five and OVR low-value goods five. The 30%-count baseline and risk-related expansion still apply.
Bank table
For C/D banks the table specifies standard-rated 10/20, combined zero-rated plus exempt 25/40, out-of-scope 5/5 and inputs 25/35. Import/other schemes are marked inapplicable. CA made/received each uses 2–12, RC 5–15 and each OVR category five. Check the bank type before choosing C or D rather than counting branches as ordinary category B units.
Other-business table and predominantly standard-rated exception
A/B other businesses use standard-rated 10/20, zero-rated 25/35, non-regulation-33 exempt five each or regulation-33-only exempt one each, out-of-scope five each, inputs 25/35, import schemes 10/15 and other schemes ten each. CA made/received each uses 2–12, RC 5–15, each OVR category five. If standard-rated supplies exceed 90% of all supplies, replace the standard-rated figures with 25/35 and zero-rated with 10/20. CA/RC use the higher range minimum if no other standard-rated supplies exist; received-supply testing includes both input and output tax.
Evidence, imports and scheme footnotes
Include section 33(2)/33A principal-agent supplies, exempt nature and third-country/disbursement/payroll items. Input tests include own/principal imports, bad-debt and unpaid-purchase repayments; import schemes reconcile TradeExchange permit records. Verify valid tax/CA/RC invoices addressed to applicant, import permit/consignee, SGD amounts, correct periods and taxable business use. Do not claim wrongly charged OVR GST. Check exports, CA customer eligibility, connected-person RC market-value/cost-allocation rules, intra-group/branch imports, marketplace/redeliverer supplies and transport/insurance in low-value-goods value.
Report contents and September 2026 additions
The seven report sections cover business information, GST risks, walk-through/interview, new processes, entity controls, schemes and substantive tests. Identify software changes, per-member/division income classification, regulation 33/non 33 exemptions and compliance with input attribution/apportionment and longer-period adjustments. Report score shifts, industry-specific risks, unit selection, outside-window procedures, control/scheme deviations and sample table, population and actual count where below table numbers. Common Appendix 4 errors need not be recopied as industry-specific risks.
Errors, five-year review and clarification requests
Quantify test-period errors; recurring input/output errors require reviewing the past five years and current period as applicable. Consolidate annual errors before/during/after review year and justify estimated proxies for IRAS approval if actual quantification is difficult. Record cause, recurrence, corrective actions/effective date and amounts per period. Surface contentious rulings at least three months before deadline. September 2026 requires a request-summary table in follow-up section 3 and separate detailed cover letter under IRAS guidance; retain support rather than submitting upfront for ACAP/renewal only. Quantify affected annual values pending ruling.
Final renewal package
Submit the renewal declaration, SRC, trend analysis, renewal report, follow-up on gaps/errors and changed functional/business/GST charts within three months after expiry. GST-process documentation submission is optional in the simplified report, but evidence and working papers remain necessary and IRAS may ask to inspect them. Request extensions at least one month before deadline; an extension does not itself alter the penalty grace date.
Post-renewal PAR: approval-date distinction
For renewed status approved before 1 January 2025, Renewal PAR is compulsory. For approval on/after that date, it is generally unnecessary unless IRAS requires extra review or PAR replaces ASK for a scheme application. When required, complete within 18 months of IRAS notification, using the latest 12-month returns at the end of its first notification-year and a higher-risk three-month test. Original Renewal-PAR due dates before 1 July 2026 extended beyond that date still must be met. Final PAR remains compulsory unless renewing again; use latest 12 months at Premium year five/Merit year three and finish six months before renewed expiry.
PAR sample exceptions
If transactions are fewer than minimum, inspect all. Increase towards maximum if minimum covers below 30% of value, unless all transactions have second-level checks or ASK pre-filing checklist was used. Overseas-principal import agents use 30 samples(single) or 45(group/divisions) and reconcile ME permits unless already controlled. Full-input-recovery-ineligible RC businesses test five extra RC transactions even if already in standard samples; if all standard supplies are only RC, use 20 or all if fewer and no extra sample. CA/RC checks both input/output. IRAS may approve reduction for analytical tools case by case.
Apportionment and new-process checks
Above de-minimis exempt supplies, verify residual input identification/apportionment. Exclude received CA, imported RC services/low-value goods and OVR marketplace/redeliverer underlying-supplier supplies from both standard recovery-formula numerator and denominator. Check duplicated inputs, gifts, reimbursements/disbursements, missing sales, extraction and purchases unpaid 12 months after due date. New systems, outsourcing/contracts/models need updated source treatment and controls, not just samples.
Completion declarations from February 2026
From 1 February 2026 every PAR requires FormSG completion declaration by deadline. Keep F 28 and appendices even if not submitted. Submit reports when IRAS requires extra review, business/operating/financial processes changed, PAR supports scheme application, or final review replaces renewal. First three include applicable errors/quantification/concession declarations and trends; Final PAR adds supply/exempt/input/refund/own-and-principal import working papers. Correct through F 7, or next F 5 only if administrative concession applies.
Certified Final PAR for schemes
A scheme user not renewing ACAP uses ASK methodology/sample sizes, not ordinary reduced PAR. An accredited in-house/external GST Advisor/Practitioner performs it, or in-house staff obtain external accredited certification under ASK procedures. Check earlier gaps, IRAS risks, new activities and controls. Submit F 28A, trends, error/concession details and transaction/import papers with completion declaration six months before expiry; externally certified in-house work adds certification summary. IRAS-discovered extra errors outside reviewed samples do not qualify for VDP relief through that review.
Revocation and continued oversight
Notify IRAS of going-concern-qualified/adverse financial opinions, qualified internal-control assurance, receivership/liquidation/creditor arrangements, cessation/inactivity, unmet requirements, false or misleading information, or negligent/wilful incorrect returns. Status may be revoked; serious PAR system errors can impose extra retention conditions. Regular checks remain advisable since delayed disclosure beyond VDP one-year grace can attract penalties.
Risk checklist and continued review
Appendix 4 covers incorrect coding, missing non-trade/related-party/advance supplies, credit notes/netting, invoice particulars/foreign currency, export/international-service evidence, input eligibility/duplicate claims, wrong OVR charging, apportionment, unpaid purchases and Customs-scheme use. Reporting risks include extraction parameters/omissions, overwritten data, missing adjustments and unexplained fluctuations. Review regularly even when no annual PAR is required to keep disclosures within VDP grace. Revocation/qualifying transfer or retention follows the main ACAP guide, rather than automatic status portability.
Risk checklist and continued review
Appendix 4 covers incorrect coding, missing non-trade/related-party/advance supplies, credit notes/netting, invoice particulars/foreign currency, export/international-service evidence, input eligibility/duplicate claims, wrong OVR charging, apportionment, unpaid purchases and Customs-scheme use. Reporting risks include extraction parameters/omissions, overwritten data, missing adjustments and unexplained fluctuations. Review regularly even when no annual PAR is required to keep disclosures within VDP grace. Revocation/qualifying transfer or retention follows the main ACAP guide, rather than automatic status portability.
Risk checklist and continued review
Appendix 4 covers incorrect coding, missing non-trade/related-party/advance supplies, credit notes/netting, invoice particulars/foreign currency, export/international-service evidence, input eligibility/duplicate claims, wrong OVR charging, apportionment, unpaid purchases and Customs-scheme use. Reporting risks include extraction parameters/omissions, overwritten data, missing adjustments and unexplained fluctuations. Review regularly even when no annual PAR is required to keep disclosures within VDP grace. Revocation/qualifying transfer or retention follows the main ACAP guide, rather than automatic status portability.
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 ↗