Understanding the differences in audit requirements is essential for any multinational business seeking compliance, transparency, and investor confidence.
In this blog we compare the auditing requirements in Singapore and France.
Regulatory Bodies and Audit Frameworks
Both France and Singapore have well-established regulatory systems that ensure the integrity and transparency of financial reporting.
Auditing in France
In France, the audit profession is regulated by the Haut Conseil du Commissariat aux Comptes (H3C), which ensures the quality and independence of auditors. Audits are performed in accordance with the Normes d’Exercice Professionnel (NEP), developed under the authority of the H3C.
As France operates under a civil law system, audit obligations and professional standards are clearly defined and codified in legislation.
Auditing in Singapore
In Singapore, the Accounting and Corporate Regulatory Authority (ACRA) oversees the audit profession and enforces compliance with national auditing requirements. Auditors follow the Singapore Standards on Auditing (SSAs).
Unlike France, Singapore operates under a common law system, placing greater emphasis on principles, professional judgment, and sound corporate governance practices.
Despite these differences in auditing requirements, both frameworks aim to promote transparency, reliability, and trust in financial information.
Auditing Process
In both France and Singapore, the purpose of auditing is the same: to verify the accuracy of financial statements, ensure transparency, and strengthen confidence in a company’s financial reporting.
This means that auditors in both countries focus on confirming that the financial statements present a true and fair view of the company’s financial position in accordance with the respective national auditing standards. Throughout the audit process, they are also required to remain fully independent and objective to maintain the integrity of their opinion.
Both jurisdictions also require auditors to report any irregularities they identify during their work, although the approach differs.
In France, auditors have a formal procédure d’alerte (alert procedure), which obliges them to inform the company’s management and, if necessary, the commercial court when they detect irregularities that could threaten the company’s going concern.
Similarly, under the Companies Act, auditors in Singapore are required to report to the Accounting and Corporate Regulatory Authority (ACRA) if they suspect that a company has committed an offence under the Act. This includes instances of fraud or misrepresentation in financial statements.
Additionally, French auditors play a broader role beyond the annual audit of financial statements. They may be appointed to perform specific assignments such as verifying the value of contributions during mergers, transformations, or capital increases.
Statutory Auditing Requirement Thresholds
Criteria |
France |
Singapore |
|---|---|---|
Audit Requirement Trigger
|
All companies which meet 2 of the 3 conditions below need to do a statutory audit: • Total annual revenue > S$10 million • Total assets > S$10 million • Number of employees > 50 |
Proprietary company considered “large” if it meets 2 of 3 thresholds: • Revenue: ≥ AUD 50 million • Gross assets: ≥ AUD 25 million • Employees: ≥100 |
Audit Obligation
|
All companies are required to appoint an auditor unless they are considered a small company, in which case they are exempt.
|
Large proprietary and all public companies must prepare audited financial reports. Small proprietary companies only if directed by ASIC or shareholders. A company is considered a small company if – a. it is a private company in the financial year in question; and b. it meets at least 2 of 3 following criteria for immediate past two consecutive financial years: i. total annual revenue ≤$10m; ii. total assets ≤ $10m; iii. no. of employees ≤ 50 |
Lower Thresholds for Subsidiaries
|
Applies when controlled by an entity already audited: • Balance sheet: €2.5 million • Turnover: €5 million • Employees: >25 |
Charities: • Gross income or expenditure > S$500,000 → audited by a public accountant • S$250,000–S$500,000 → examined by a qualified independent person or audited • ≤ S$250,000 → examined by a competent independent person or audited Institutions of a Public Character (IPCs): Audited by a public accountant, regardless of income. Charities as Companies Limited by Guarantee (CLGs): Accounts must be audited, regardless of income. |
Other Entities that need to conduct an Audit
|
Non Profits are required if annual donations + subsidies exceed €153,000 or if recognized as public utility, issue bonds, or provide microloans.
|
Companies limited by guarantee: • Revenue < AUD 1 million → audit or review • Revenue ≥ AUD 1 million → audit mandatory |
Public Companies
|
All public limited companies (Société Anonyme – SA) require audits regardless of size.
|
All public companies must prepare audited financial reports and lodge them with the Accounting and Corporate Regulatory Authority (ACRA).
|
Filing / Submission Timeline
|
Financial statements filed annually with the Greffe du Tribunal de Commerce.
|
Annual Return must be filled within 7 months after the end of the company's financial year.
|
You can read more about audit requirements in France on our dedicated blog post.
Auditor Appointment
Appointment of an Auditor in France
In France, a statutory auditor (commissaire aux comptes) can be appointed either directly in the company’s founding documents (statuts) or later by a resolution passed at a general shareholders’ meeting.
If an auditor has not been appointed or a vacancy arises due to resignation or dispute, the commercial court may designate one to ensure compliance with audit obligations.
Compliance with the audit law in France requires companies to appoint both a principal (titular) auditor and an alternate auditor, who steps in if the primary auditor is unable to perform their duties.
Auditors must be selected from the official registry maintained by the Haut Conseil du Commissariat aux Comptes (H3C).
Rotation rules:
Public Interest Entities (PIEs) are required to change their audit firms every 10 years. This rotation period can be extended up to 24 years if the audit firm is appointed through a competitive tender process, ensuring that companies periodically reassess and select their auditors transparently.
For companies that are not classified as PIEs, auditors are typically appointed for a term of 6 years, but there is no strict requirement for mandatory rotation.
You can read more about mandatory rotation of auditors in France here.
Appointment of an Auditor in Singapore
In Singapore, an auditor must be a public accountant or an accounting firm approved by the Accounting and Corporate Regulatory Authority (ACRA). All companies, unless exempted, are required to appoint an auditor within three months of incorporation. The appointed auditor holds office until the conclusion of the company’s first Annual General Meeting (AGM), where the appointment must be confirmed or replaced.
For subsequent years, the company must appoint an auditor at each AGM, who will hold office until the conclusion of the next AGM. Auditors may resign by giving written notice to the company, which must then notify ACRA within 14 days. Removal of an auditor is also possible, but companies must follow proper procedures under the Companies Act.
Rotation Rule:
In Singapore, rotation requirements apply mainly to Public Interest Entities (PIEs). An audit firm may serve as the auditor of a PIE for a maximum of five consecutive years, after which a five-year cooling-off period is required before the same firm can be reappointed. Likewise, the key audit partner responsible for the audit must rotate off after five consecutive years and cannot resume the role for the next five years. These measures ensure auditor independence and maintain high audit quality.
Penalties
In the event of non compliance with audit laws, the following penalties may apply.
Penalties in France
In France, if the auditor finds errors, then tax reassessments and penalties may apply.
Penalties may include:
- 0.4% monthly interest on unpaid taxes
- 10% fines for errors made in good faith
- Up to 200% penalties in cases of fraud or willful misconduct
Appeals are possible but are rare, costly, and usually unsuccessful.
Penalties in Singapore
In Singapore, if an auditor identifies errors or discrepancies in a company’s financial statements, the Inland Revenue Authority of Singapore (IRAS) may reassess taxes and impose penalties. These penalties vary depending on the nature of the error and the intent behind it.
- Late Payment: 5% initial penalty if tax is unpaid by the due date, plus 1% per month for continued non-payment (up to 12%).
- Errors in Tax Returns: Up to 200% of undercharged tax for unintentional errors; up to 400% for intentional tax evasion. Fines and imprisonment may also apply.
- Appeals: Taxpayers can request a waiver of penalties through IRAS, though approvals are limited and conditions apply.
Taxpayers may appeal for a waiver of late payment penalties through the IRAS myTax Portal. However, appeals are only considered if the overdue tax has been paid in full by the due date and no waiver has been granted in the past two calendar years.
You can find more details on the official IRAS website.
Audit requirements in Singpore and France share the common goal of ensuring financial transparency and integrity, but they differ significantly in structure, legal framework, and regulatory enforcement.
Auditing in Singapore emphasizes principles, professional judgment, and adherence to international standards, while French audits are closely codified in law with broader statutory obligations for corporate transactions.
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