From 1 February 2015 all applicants wanting to be a public accountant will need to have at least 2,500 hours of Qualifying Audit Experience (QAE). In acquiring this QAE, the applicant will need to have carried out an audit management role and where applicable, an audit quality review role or an audit technical role, independently and competently under an Audit Principal (AP) or APs as the case may be. FAQs about the requirements are set out below.
[Refer to the new practical experience requirements for registration as a public accountant.]
For Applicants
For Audit Principals (AP)
For Applicants
- What is Qualifying Audit Experience (QAE)?
QAE is the experience acquired in carrying out an audit management role, audit quality review or audit technical role. In carrying out the audit management role, the applicant will need to have performed the key audit functions (KAFs) on audit engagements under the direct supervision of an engagement partner.
- What are Key Audit Functions (KAFs)?
KAFs are work performed in an audit engagement in the area of planning, leading and reporting. Please refer to the detailed KAFs as set out in the chapter "Practical Experience Requirements for Registration as Public Accountants ".
- What is considered an audit quality review role?
An audit quality review role means the role of:
(a) assessing or reviewing the quality of an audit engagement performed for an accounting entity, ACRA or a professional accountancy body in Singapore; or
(b) carrying out an audit inspection under a practice monitoring programme, or another similar programme for ACRA or a professional accountancy body in Singapore.
- What is considered an audit technical role?
Generally, this would apply to individuals performing technical audit or accounting consultation roles at managerial level and above, and reporting directly to the partner or director in the public accounting entity.
- Since QAE includes audit quality review and audit technical roles, can I accumulate 2,500 hours in these roles only and be considered to have gained the required QAE?
If you rely on experience in an audit quality review or audit technical role, you must have at least 1,250 hours of experience in performing the KAFs within the 5 years immediately preceding application.
- Is QAE the same as the practical experience required to complete the Singapore Chartered Accountant Qualification (Singapore CA Qualification)?
The practical experience requirements for registration as a public accountant are not the same as the required experience to complete the Singapore CA Qualification. Registration as a public accountant is for the purpose of taking responsibility for audits of financial statements and the practical experience requirements are designed for this purpose.
From 1 January 2019, applicants will need to have completed the Singapore CA Qualification or a recognised equivalent professional qualification to register as a public accountant. Applicants who gain the Singapore CA Qualification or a recognised equivalent professional qualification after 1 January 2019 will need to have gained their QAE after completion of their qualification.
- My QAE was not gained continuously. Can I count the hours from the individual periods towards the 2,500 hours?
Yes. The QAE can be accumulated in parts as long as you satisfy the requirements that:
(a) The total 2,500 hours of QAE are gained within the 5 years immediately preceding application
(b) At least 1,250 hours of QAE must be gained with the same firm or gained under the direct supervision of the same AP.
- How should I record the QAE to ensure that it is verifiable?
You, as the applicant, are responsible for maintaining sufficient and proper records of your experience. This is to enable the AP to perform his or her role to sign-off on the QAE. The records should enable you to provide evidence that you have:
(a) Acquired at least 2,500 hours of requisite QAE during the 5 year period preceding the application;
(b) Performed the KAFs and if applicable, carried out the audit quality review role or audit technical role, as the case may be, independently and competently; and
(c) Performed (a) and (b) under the direct supervision or overall oversight of an AP or APs, as the case may be.
While obtaining your QAE, you may find it useful to keep a record of the audit engagements worked on, the role performed, and the person or persons supervising you.
A specimen template of how you may record your QAE can be found at this link (Word, 36KB). Please note that this specimen template is not a mandatory document for submission as part of your registration to be a public accountant. You and your AP(s) may record and track the QAE acquired in such other manner as deemed appropriate and fit that allows for the QAE to be verified by ACRA where such need arises.
Applicants must however submit a declaration form to be signed off by the applicant and a declaration form from his or her AP(s) in connection with the QAE acquired. Refer to the template declaration forms in the "Downloads" section here.
- What is considered foreign QAE?
Foreign QAE is QAE acquired by the applicant which satisfies all of the following conditions:
(a) the QAE is acquired by the applicant in the course of auditing any financial statements in an audit entity in a country or territory outside Singapore (i.e. foreign audit entity);
(b) the country or territory in which the foreign audit entity is registered or licensed adheres to auditing standards which the PAOC considers to be equivalent to the standards applicable in Singapore; and
(c) the PAOC is satisfied with the quality of the QAE having regard to one or more of the following factors:
i. whether the foreign audit entity has implemented, or has taken steps to implement, quality controls in accordance with standards which the PAOC considers to be equivalent to the standards applicable in Singapore (including the Singapore Standard on Quality Control 1);
ii. whether the foreign audit entity has been subject to any audit inspection carried out by or on behalf of the regulator of the audit profession in the country or territory of its registration or licensing, and whether the regulator is satisfied with the findings of such audit inspection;
iii. whether the PAOC is of the opinion that the foreign audit entity is of good standing in the country or territory of its registration or licensing;
iv. whether http:// the QAE would meet the criterion of the practical experience required for qualifying the applicant as an auditor in the country or territory in which the applicant has acquired the QAE.
(d) the QAE is acquired in the period of 5 years immediately preceding the date of the application.
Testimonials and supporting documents from the foreign audit entity will be required by ACRA to support the application. Please refer to the Addendum to the Application to be Registered as a Public Accountant (PDF, 123KB) for further details on the supporting documents to be submitted.
- When can I start counting my QAE if I am a member of ISCA at the point of acquiring my QAE?
If you are a member of ISCA before you start to acquire your QAE, the QAE is to be gained only after you become a full member of ISCA or after you have satisfied the professional accountancy experience requirements for qualifying as a Chartered Accountant of Singapore. The current professional accountancy experience requirements for qualifying as a Chartered Accountant of Singapore, as set in ISCA’s website are:
(a) 3 years of post-qualification experience; or
(b) 5 years of pre-and-post qualification experience, of which one year should be post qualification experience.
Pre-qualification and post-qualification experience refers to experience gained before and after passing the final examination in accountancy of a recognised academic or professional qualification referred to in ISCA’s membership rules, respectively. You may visit ISCA’s website at www.isca.org.sg for further details on the recognised academic or professional qualifications accepted by ISCA.
Please refer to Practice Direction No. 2 of 2015 Professional Accountancy Experience Required Before Acquiring Qualifying Audit Experience for Registration as a Public Accountant (PDF, 363KB).
- Where can I gain my professional accountancy experience before I start acquiring the QAE?
ISCA’s practical experience requirements allow for the professional accountancy experience to be gained in any sector or industry as long as the job scope includes accounting/finance functions. However, to ensure relevant and sufficient seniority of the QAE acquired, it would be reasonably expected that the applicant would have gained some of his or her professional accountancy experience in performing audit work before progressing to acquire his or her QAE in an audit management, audit quality review or audit technical role.
- When can I start counting my QAE if I am not a member of ISCA at the point of acquiring my QAE?
If you are not a member of ISCA before you start to acquire your QAE, the QAE is to be gained only after you have acquired the professional accountancy experience which the Public Accountants Oversight Committee (PAOC) has determined to be equivalent to the requirements as to professional accountancy experience that are as set out in the ISCA’s membership rules for qualifying as a Chartered Accountant of Singapore.The PAOC has determined the equivalent amount of professional accountancy experience to be either one of the following:
- 3 years of professional accountancy experience gained after obtaining an accountancy degree; or
- 3 years of professional accountancy experience gained after passing the final examination in accountancy of a recognised professional examination; or
- 5 years of professional accountancy experience gained before or after passing the final examination in accountancy of a recognised professional examination, of which at least one year must be gained after passing the final examination.
The list of recognised professional examinations is as set out in paragraph 2 of the Second Schedule to the Accountants (Public Accountants) Rules available at the following link.
Please refer to Practice Direction No. 2 of 2015 Professional Accountancy Experience Required Before Acquiring Qualifying Audit Experience for Registration as a Public Accountant (PDF, 363KB).
- Can I be directly supervised by more than one AP?
Yes. At least 1,250 hours of QAE must be gained with the same firm or under the direct supervision of a single AP. If more than one AP is involved, you will need to provide:
(a) declarations from all the relevant APs; and
(b) a testimonial from the firm collating the experience you have gained under the relevant APs in the same firm.
The onus is on you to ensure that the combined submissions of QAE from all APs meet the total required experience.
- Am I allowed to change employment to another firm while accumulating QAE?
You are not restricted from changing employers as long as you satisfy the requirement that at least 1,250 hours of QAE is gained with the same firm or under the direct supervision of the same AP.
- What if my AP is unable to continue supervision as a result of having failed practice review under the Practice Monitoring Programme (“PMP”)?
If your AP has received a hot review order, your AP may apply to the Public Accountants Oversight Committee (PAOC) for consent to continue as an AP.
If the application is unsuccessful, or if your AP is subjected to other orders such as prohibition from being an AP, or a restriction or suspension order, you and your AP should arrange for an alternative AP to ensure that you continue to obtain the necessary supervision.
The experience gained by you prior to the AP’s cessation as an audit principal due to the circumstances described above can still be counted for the purpose of determining whether you have satisfied the QAE requirements.
- What if my current AP moves on to a new audit firm before I complete 1,250 hours of QAE with the AP?
As you are required to gain 1,250 hours of QAE with the same firm or under the supervision of the same AP, you can either:
(a) continue with the current firm to fulfil the requirement, as long as you continue to be directly supervised by another AP with the same firm; or
(b) transfer to a new firm with the current AP. The 1,250 hours of QAE would still be considered continuous as it is with the same AP.
- How is the supervision by the AP different if the qualifying audit experience is acquired in an accounting entity which has implemented quality controls in accordance with the SSQC 1, and those quality controls have been reviewed by ACRA to ACRA’s satisfaction?
In such an accounting entity, besides being directly supervised by the AP, the pupil can also be directly supervised by other public accountants in the accounting entity (who need not be the pupil’s AP) who are the engagement partners of the audit engagements in which the applicant has gained his or her experience. However, the pupil will still be under the overall oversight of an audit principal who will be providing the declaration that the pupil has acquired the QAE independently and competently. The AP will make this declaration, after being reasonably satisfied that such declaration is true based on the particulars and records of QAE gained by the pupil under the direct supervision of other public accountants in the accounting entity.
- How do I know if the firm in which I am acquiring my QAE or intending to acquire my QAE is an accounting entity which has implemented quality controls in accordance with the SSQC 1, and those quality controls have been reviewed by ACRA to ACRA’s satisfaction?
Broadly, this category of firms would currently only apply to public accounting entities in the public interest entity (PIE) segment for which ACRA has conducted firm-level inspections. To ascertain whether the public accounting entity’s quality controls has been reviewed by ACRA to ACRA’s satisfaction, the public accounting entity must write-in to ACRA to enquire. Upon receipt of the enquiry, ACRA will notify the public accounting entity on whether it has or has not met the requirements as such. Pupils or aspiring pupils seeking to acquire qualifying audit experience in the firm may wish to ask their firm on whether it has met the requirements as such.
- I am a public accountant from a firm which has just implemented quality controls in accordance with the SSQC 1. Can ACRA review my firm to assess whether the quality controls are to ACRA’s satisfaction?
ACRA does not carry out firm-level inspections at the request of firms. Selection of firms for firm-level inspections is based on ACRA’s assessment of the public interest risk and to complement the detailed engagement inspections carried out under ACRA’s Practice Monitoring Programme. Should your firm be selected for a firm-level inspection, ACRA will notify your firm accordingly.
- If I apply to be a public accountant after 1 February 2015 under the new requirements, can I count the practical experience I have gained, before the announcement of the change, and before 1 February 2015?
Your practical experience gained before 1 February 2015 will count if it satisfies the requirements to be counted as QAE, and was gained under the direct supervision of either:
(a) an Approved Principal within the meaning of Rule 2 of the Accountants (Public Accountants) Rules in force before 1 February 2015; or
(b) a public accountant in an accounting entity which, at all times when the QAE was acquired, had implemented quality controls in accordance with the Singapore Standard on Quality Control 1 (SSQC 1), and those quality controls have been reviewed by the Authority to the Authority’s satisfaction.
- How is the new required practical experience different from the previously required practical experience?
Please refer to the chapter - " Practical Experience Requirements for Registration as Public Accountants " under the Guide to Professional Requirements for Registration as Public Accountants which sets out the key differences between the requirements that apply before and after 1 February 2015.
- Under the previous rules, practical experience has to be acquired within 7 years of the application. Will experience gained more than 5 years ago be recognised if I submit my application on or after 1 February 2015?
No. The new requirements will apply if your application is received on or after 1 February 2015, where only experience gained within the 5 years preceding the application may count towards meeting the requirements.
FOR AUDIT PRINCIPALS
- How is the role of the AP different from the previous role of the Approved Principal?
The APs will need to sign a declaration (Word, 27KB) stating the following:
(a) the number of hours of QAE acquired by the applicant under his or her direct supervision or overall oversight, as the case may be; and
(b) specifically, whether in acquiring such QAE, the applicant has independently and competently:
- performed the relevant KAFs; and
- if applicable, carried out the audit quality review role or audit technical role, or both, as the case may be,
to the satisfaction of the AP.
- What are the requirements for a public accountant to be an AP?
For a public accountant to qualify to be an AP, he or she must meet the following conditions:
(a) have at least 5 years’ experience in public practiceThis may include foreign public practice experience acquired by a foreign auditor in the course of auditing financial statements in a foreign audit entity. See “Requirements on Audit Principals” for more information on foreign public practice experience; and
(b) must not be subject to any of the following orders:
- an order imposed by the PAOC under section 38(1)(a)(iv) or 52(2)(g) of the Act prohibiting you from being an AP;
- a hot review order, unless the PAOC consents to your application to continue to be an AP*, if any, made under rule 6B(1) of the Accountants (Public Accountants) Rules;
- a restriction order; or
- a suspension order.
*Also read Practice Direction No. 5 of 2020: Application by a Public Accountant who is subjected to a Hot Review Order to continue to be an Audit Principal (PDF, 136KB).
- When and under which circumstances does a public accountant cease being an AP?
A public accountant should cease being an AP if he or she receives, the following:
| |
Circumstances under which an AP ceases to be an AP |
Effective date of cessation as an AP |
| 1. |
The AP is subject to any of the following: (i) an order by the PAOC prohibiting you from being an AP; (ii) a restriction order; or (iii) a suspension order |
The date of the order |
| 2. |
The AP is subject to a hot review order and does not apply to the PAOC for consent to continue to be an AP |
30 days after the order becomes effective |
| 3. |
The AP is subject to a hot review order and the PAOC refuses his or her application to continue to be an AP |
The date on which the PAOC informs the audit principal of its decision |
This is to ensure that the experience is gained in an environment in which audits are consistently performed in compliance with the Singapore Standards on Auditing.
- Do I, as an AP, have to directly supervise every pupil?
If you work for a firm which has quality controls in place that comply with the Singapore Standard on Quality Control 1 (SSQC 1) that have been reviewed by ACRA to ACRA’s satisfaction, you need not directly supervise every pupil. Under this circumstance, the QAE may be acquired under the direct supervision of other public accountant(s) in the accounting entity who need not be the pupil’s AP. The public accountant(s) must however be the engagement partner(s) for the audit engagement in which the pupil has gained his or her experience.
However, you as the AP must have overall oversight of the pupil’s acquisition of the QAE and will still need to ensure that the pupil has completed the QAE independently and competently to your satisfaction before signing off on the declaration. You should only do so, after being reasonably satisfied that such declaration is true based on the particulars and records of QAE gained by the pupil under the direct supervision of other public accountants in the accounting entity.
If your firm does not have such quality controls in place, you, as the AP would need to directly supervise the work of each pupil, subject to a maximum of 4 pupils at any point in time.
- How should I sign-off on the pupil’s QAE, and what supporting records should the pupil provide for me to make the declaration?
The pupil should provide you records that you deem sufficient, for example the records of audit engagements kept by your audit firm. You may wish to use the template declaration form (Word, 27KB).
- Do I have to ensure that the pupil is able to meet the total QAE requirement if there are other APs providing direct supervision to the pupil, or just the QAE gained under my direct supervision?
It is the pupil’s responsibility to ensure that he or she gathers enough experience to meet the total QAE requirement. You as the AP are only required to ensure that you duly sign-off on the period of experience which you have supervised the pupil for. Please refer to the illustrative declaration form (PDF, 384KB) which shows how the form should be completed.