Audit Requirements in Singapore vs France: Key Differences

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

Single Family Office Structure Requirements in Singapore

This article explores the different entity types commonly used to establish a single family office structure in Singapore, such as private limited companies, Variable Capital Companies (VCCs), and trusts, and outlines the regulatory and tax requirements specific to each.

Family Office in Singapore: Structure, Strategy, and Jurisdictional Advantages

Demand for structured wealth management and legacy planning has surged globally. A family office is a private vehicle that manages the wealth, succession, and often lifestyle of ultra-high-net-worth individuals. In recent years, Singapore has emerged as the premier hub in Asia, offering a stable regulatory environment, tax incentives, and high standards of professional services, making it an ideal destination for setting up your family office. This blog will guide you on the requirements for setting up a family office in Singapore. What is a Family Office? A family office is a wealth and asset management entity established to manage the private affairs of ultra-high-net-worth individuals. It serves as a management system that preserves and grows wealth across generations and helps in estate planning. Family offices are involved in a range of activities from investment management, tax planning, and succession planning to concierge and philanthropic services. In Singapore, these take two main forms: Single Family Offices (SFOs): Dedicated to one family and fully customized for their needs. Multi-Family Offices (MFOs): Serve multiple families, offering economies of scale while maintaining tailored advice. The choice between these two depends on the aggregate net worth of the family, the complexities of financial needs and the desired level of personalized attention.    A well-structured family office will often include the following functional entities or roles: Function Description Investment Entity Holds and manages family assets, such as equities, private equity, or real estate. Management Company Employs investment professionals, oversees operations, and executes the family’s investment strategy. Trust or Holding Entity Provides asset protection and tax planning flexibility. Philanthropy Arm Manages donations, foundations, or social impact Investments. Family Governance Body Family council, investment committee, or board that aligns family and professional interests. Singapore Family Office Structures Establishing the right legal and operational structure is critical to the success of a family office. In Singapore, structures are tailored based on the family’s investment strategy, risk appetite, tax planning objectives, and governance preferences. Your family office can be structured as one of the following: Private Limited Company Singapore Variable Capital Company (VCC) Trust All of these can either be SFO or MFO subject to conditions and legal requirements. Additionally, each legal structure has implications for taxation, asset control, confidentiality, and regulatory compliance. For example, families establishing investment funds may prefer the VCC due to its flexibility in managing pooled assets and offering sub-fund segregation, while Pte Ltd companies are typically used for holding investment portfolios or employing staff locally. You can find more information about the requirements of each type of structure on the blog dedicated to Singapore family office structures. Key Considerations for Structuring When designing the structure, families typically focus on: Governance: Who has decision-making authority, and how are decisions escalated? Tax efficiency: How to benefit from exemptions under Sections 13O and 13U? Risk segregation: How to separate operating, investment, and philanthropic activities? Succession: How will assets and responsibilities pass to the next generation? Economic substance: Ensuring sufficient staff and operations are in Singapore to meet MAS and IRAS expectations. Succession Planning and Governance The central purpose of family offices is to ensure smooth succession planning across generations. This is achieved through: Governance frameworks: Family constitutions, charters, and clearly defined decision-making processes. Professional oversight: Investment committees and external advisors to temper family influence. Succession mechanisms: Role clarity, continuity playbooks, and structured training for heirs. Effective governance aligns family values with professional rigor, safeguarding long-term wealth. Choosing the Right Jurisdiction When setting up a family office, selecting the right jurisdiction is critical to ensuring long-term stability, tax efficiency, and operational ease. Below are key factors to consider: Function Description Regulatory clarity and stability Choose a jurisdiction with transparent and consistent regulations to avoid legal uncertainties that could disrupt operations or affect tax status. Favorable tax regime A low or structured tax environment can enhance after-tax returns, especially when tax exemptions or incentives apply to investment income. Access to financial markets and talent Jurisdictions with deep capital markets and a strong pool of legal, financial, and investment professionals support more effective wealth management. Ease of doing business Administrative efficiency, legal infrastructure, and speed of processes (e.g. bank account setup, fund registration) reduce friction in daily operations. Why Choose Singapore for Your Family Office? Setting up a family office in Singapore is one of the best ideas for the following reasons: Tax incentives under Sections 13O/13U of the Income Tax Act allow tax exemption on specified investment income for funds managed locally. As per DLA Piper, in 2024, over 2,000 single family offices have been set up in Singapore, growing ~43% from 2023. Singapore hosts 59% of all family offices in Asia – more than any other country in Southeast Asia. Exceptional political stability, economic stability, clean legal framework, and operational efficiency make it a highly trusted jurisdiction. Government support is coordinated through the Family Office Development Team (FODT) and partnerships like the Global-Asia Family Office Circle. The Monetary Authority of Singapore (MAS) now processes family office tax incentives significantly faster, reducing approval times from 12 to 3 months, while private banks expedite account opening. Singapore has no estate duty, inheritance or gift taxes, which eases and reduces cost of wealth transfer. FAQs What are the requirements for setting up family offices in Singapore for SFOs? To qualify under Section 13U/13O tax incentive schemes, Single Family Office’s must meet several criteria: Meet the fund requirements as follows – Section 13O: Funds must maintain at least SGD 5 million in DI annually. Section 13U: Funds are now required to maintain the SGD 50 million AUM threshold annually, ensuring sustained investment activities. Employ at least three investment professionals, with at least one non-family executive. Subject to tiered spending requirements with a minimum spending of S$200,000 in local businesses. Have a private bank account with an MAS-licensed financial institution at the point of application and throughout the incentive period. The MAS should approve the Scheme. You can find more detailed information on MAS’s website. How much does a family office in Singapore cost? The charge

Essential Guide for Transitioning to ISSB Standards for Sustainability Reporting

Transitioning to ISSB standards marks a pivotal moment for companies in Singapore striving to enhance sustainability reporting and align with global ESG expectations.
This guide provides a clear roadmap for navigating the shift, ensuring compliance while unlocking long-term value through transparent and consistent sustainability reporting.

Are Sustainability Reports Required in Singapore?

In this blog we discuss what is sustainabily reporting, why is it important and is it mandatory to publish sustainability reports in Singapore.