The Accounting Standards Committee (ASC), under the Accounting and Corporate Regulatory Authority (ACRA), has issued a reminder to stakeholders to provide feedback on the proposal to make FRS 119 Subsidiaries without Public Accountability: Disclosures available to eligible small entities. This consultation remains open until 30 May 2025 (Friday), and responses may be submitted via the FormSG survey accessed through the QR code or URL provided in the ASC’s communication.
1. Objective of the Consultation
The ASC is seeking industry feedback on whether the reduced-disclosure framework under FRS 119 should be extended beyond subsidiaries to include small entities that currently meet the criteria under the Singapore Financial Reporting Standard for Small Entities (SFRS for Small Entities).
This proposal aims to:
- Enhance flexibility for small entities choosing between SFRS for Small Entities and full FRSs;
- Reduce reporting burden through the application of a simplified disclosure framework; and
- Improve comparability by aligning more entities with full FRS recognition and measurement requirements.
2. Potential Impacts and Considerations for Preparers
2.1 Reduction in Financial Reporting Effort
Small entities applying full FRSs could benefit from substantially reduced disclosure requirements, improving efficiency in:
- Preparation time
- Review processes
- Audit procedures
However, preparers need to evaluate whether the recognition and measurement requirements of full FRSs introduce complexity compared to SFRS for Small Entities.
2.2 Transition Implications
Entities currently applying SFRS for Small Entities may incur transitional costs if moving to full FRSs, including:
- Accounting policy changes
- Restatement of comparatives
- Updates to systems and templates
These impacts should be weighed against long-term benefits of improved alignment with full FRSs.
2.3 Stakeholder Communication
Entities should assess how changes may affect:
- User expectations
- Comparability with industry peers
- Lender or investor familiarity with FRS-based financial statements
Proactive communication with stakeholders is recommended if the extension is implemented.
3. Considerations for Professional Firms and Advisors
Firms with clients potentially affected by the proposed extension should:
- Review client profiles to identify eligible small entities
- Assess possible cost-benefit outcomes for each client
- Prepare to advise on transition pathways and practical implementation issues
- Encourage timely participation in the consultation process
The ASC’s survey is a key opportunity for the profession to highlight operational challenges, transitional issues, and industry-specific considerations.
4. Action Required
Stakeholders are encouraged to:
- Submit their input by 30 May 2025
- Provide constructive feedback on practical application challenges, expected benefits, and transitional considerations
- Engage internal finance teams, audit committees, and advisors in evaluating the proposal
Timely feedback will help the ASC calibrate the scope and application of FRS 119 to better serve the needs of smaller reporting entities.
Source: ACRA, 23 May 2025.