Audit principal requirements & responsibilities
Requirements and responsibilities for audit principals (APs) who supervise public accountant pupils gaining QAE for PA registration.
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What is an audit principal (AP)
An audit principal supervises pupils1 gaining qualifying audit experience (QAE) to register as a public accountant (PA).
As an AP, you will either:
Directly supervise pupils as the engagement partner of the audit engagement
Provide overall oversight if your firm has SSQC 12, SSQM 1 and SSQM 2 quality controls reviewed by ACRA to ACRA's satisfaction
Who qualifies as an AP
As a registered public accountant, you must:
Have at least five years of experience in public practice3
This may include foreign public practice experience4 that meets specific criteria
Not be subject to any of these orders:
Order prohibiting you from being an AP under section 52(2)(g) of the Act
Hot review order5 (unless the Public Accountants Oversight Committee, or PAOC, approves your application to continue as an AP)
Restriction order6
Suspension order7
Eligibility details
Foreign public practice experience
You can count your experience towards the five-year requirement if all of these apply:
You gained the experience while working as a foreign auditor8 auditing financial statements in a foreign audit entity9.
The foreign audit entity operated in a country that uses auditing standards the PAOC considers equivalent to Singapore standards.
The PAOC is satisfied with the quality of your foreign experience based on factors such as:
Whether the foreign audit entity has implemented quality controls equivalent to Singapore standards (including SSQC 1)
Whether you or the entity were subject to audit inspections by local regulators
Whether the PAOC considers the foreign audit entity to be in good standing
Any other relevant factors
You cannot count periods when your foreign auditor's licence or registration to audit financial statements was withdrawn, suspended, cancelled, or revoked in that jurisdiction.
Other eligible persons
You can also qualify as an AP if you hold any of these roles (or are a designated senior officer of these roles):
Commissioner of inland revenue
Accountant-general
Auditor-general or designated senior officer
Registrar of public accountants
Registrar of companies
Chief executive of any professional accountancy body or organisation in Singapore
Your responsibilities as an AP
As an AP, you need to supervise the pupil throughout their QAE. Ensure the pupil independently and competently performs:
Key audit functions
Audit quality review role
Audit technical role (where applicable)
Supervision requirements
AP supervision requirements
If your firm | Then |
|---|---|
Does not have SSQC 1, SSQM 1 and SSQM 2 quality controls reviewed by ACRA to ACRA's satisfaction |
|
Has SSQC 1, SSQM 1 and SSQM 2 quality controls reviewed by ACRA to ACRA's satisfaction |
|
Declaration requirements
Signing QAE declarations
Steps | Details |
|---|---|
Review records | Before signing the declaration, verify your pupil's experience through:
|
You must sign a declaration stating:
Note: If other APs also supervised the pupil, you only need to sign off on the QAE under your supervision period. The pupil is responsible for ensuring they meet the total QAE requirement. |
Note: A pupil cannot be your parent, sibling, spouse, child, or adopted child.
When you cease to be an AP
You will immediately cease to be an AP in these situations:
AP cessation
Circumstance | Effective date of cessation |
|---|---|
You receive any of these orders:
| Date of the order |
You receive a hot review order, and do not apply to PAOC for consent to continue as an AP | 30 days after the order becomes effective |
You receive a hot review order, and the PAOC rejects your application to continue as an AP | Date the PAOC informs you of the decision |
Note: You must immediately inform your pupils when you cease to be an AP. Any QAE your pupils acquired before you ceased being an AP will still count towards their total QAE requirements.
Hot review orders
If you receive a hot review order and want to continue as an AP, you must seek consent from the PAOC:
Download and complete the Application for Consent to Continue to Be an Audit Principal [PDF, 203 KB]
Submit this to the PAOC within 30 days of the order's effective date.
Tip: View Practice Direction No. 5 of 2020 [PDF, 144 KB] for application guidance
Glossary of key terms
Pupil: A person gaining QAE to register as a PA under the Accountants Act. The pupil must work under either:
Direct supervision of one or more APs; or
Overall oversight of an AP if the pupil works in an accounting entity that has:
Implemented quality controls according to SSQC 1, SSQM 1 and SSQM 2
Had these quality controls reviewed to ACRA's satisfaction
SSQC 1 (Singapore Standard on Quality Control 1): A standard issued by the Institute of Singapore Chartered Accountants (ISCA). It sets out quality control requirements for audits, reviews of financial statements, and other assurance and related services engagements.
Public practice: Practise as a PA in one of these capacities:
Sole proprietor
Partner in an accounting firm
Director or corporate practitioner in an accounting corporation
Partner or corporate practitioner in an accounting limited liability partnership (LLP)
Foreign public practice experience: Practical audit experience gained by a foreign auditor while auditing financial statements at a foreign audit entity.
Hot review order: A certain number of audit engagements to be reviewed by another PA (“Hot Reviewer”) before the PA signs the audit reports.
Restriction order: Restriction on the auditing and reporting of financial statements of certain entities, such as:
Auditing and reporting on financial statements of any entity, for which an audit is required by written law;
Auditing and reporting on the financial statements of:
Any public company that is not dormant
Any private company that is not dormant and not an exempt private company ("EPC"); and
Any EPC that is not dormant and has annual revenue of more than $10 million;
Auditing and reporting on the financial statements of all public interest entities; and
Auditing and reporting on the financial statements of entities in specific industries.
Suspension order: Suspension of the PA's registration. While the PA remains suspended, the PA must not:
Practise as a public accountant
Hold himself or herself out to be a PA; and
Advertise any title or description tending to convey the impression that he or she is a registered PA or that he or she is authorised to provide public accountancy services in Singapore, during the period of suspension.
Foreign auditor: A foreign auditor is an individual licensed or registered to audit financial statements outside Singapore by the audit regulator in their country or territory.
Foreign audit entity: An entity formed outside Singapore that is licensed or registered to audit financial statements in that country.
Engagement partner: A partner or other person in an accounting entity who is responsible for the engagement, its performance, and the report issued on behalf of the accounting entity. Where required, this person has appropriate authority from a professional, legal, or regulatory body.
Audit engagement: A reasonable assurance engagement where a PA examines financial statements. The PA then expresses an opinion on whether they comply with applicable financial reporting frameworks in all material respects.
