From 1 February 2026, the Inland Revenue Authority of Singapore (IRAS) has implemented material administrative changes to the Assisted Compliance Assurance Programme (ACAP). The revisions—detailed in the fifth and sixth editions of the respective e-Tax Guides issued 30 January 2026—eliminate the Renewal Post ACAP Review (PAR) requirement for qualifying businesses while introducing a mandatory FormSG declaration protocol.
These changes carry distinct operational implications for GST compliance officers, internal audit functions, and accredited tax professionals.
Background and Programme Context
ACAP remains a cornerstone of Singapore’s voluntary GST compliance ecosystem. Since inception in 2011, over 1,100 businesses have participated, with more than 900 holding active status as of March 2025 . The programme rewards robust GST control frameworks with reduced compliance interventions, expedited refunds, and preferential penalty treatment under the Voluntary Disclosure Programme.
Key Regulatory Amendments
1. Abolition of Renewal PAR for Standard Approvals
The most significant structural change pertains to renewal streamlining. Businesses granted ACAP Renewal status on or after 1 January 2025 are no longer required to perform a Renewal PAR. Previously, renewal candidates were required to conduct a post-renewal review to validate ongoing control effectiveness. IRAS has determined that the initial renewal review sufficiently demonstrates continued compliance .
Practical Concern: The exemption is not absolute. Entities that have been specifically directed by IRAS to perform additional review following the grant of renewal remain obligated to complete the PAR. Furthermore, taxpayers utilising the PAR as a substitute for the Assisted Self-help Kit (ASK) to support applications for GST schemes—including the Major Exporter Scheme (MES) and Import GST Deferment Scheme (IGDS)—must continue to satisfy PAR requirements. Accounting professionals should verify scheme application pathways before assuming exemption eligibility.
2. Mandatory Digital Declaration Protocol (Effective 1 February 2026)
A new administrative requirement now governs all PAR completions. Businesses that perform a PAR—whether mandatory or retained by election—must submit a “Declaration on Completion of Post ACAP Review” via FormSG .
This represents a deliberate migration from traditional form-based submissions to digital government infrastructure. The declaration requires taxpayers to particularise the specific circumstances necessitating the submission of either:
-
GST F28 – Post ACAP Review Report; or
-
GST F28A – Certified Post ACAP Review Report
The e-Tax Guides have been structurally amended to accommodate this change. Paragraphs 11.2.2 to 11.2.8 (ACAP main guide) and 9.3.2 to 9.3.4 (Renewal guide) have been inserted to delineate these circumstances .
3. Revised Reporting Instruments
IRAS has concurrently updated the underlying reporting templates. GST F28 (XLSX, 398KB) and GST F28A (XLSX, 426KB) both reflect January 2026 revision dates . Practitioners should discard previous template versions, as the updated workbooks align with the new declaration framework and incorporate revised footnote references (including new footnotes 52, 54–56, 62, and 63 across the respective appendices) .
Operational and Practical Issues for Accounting Professionals
A. Distinction Between Standard and Certified PAR
The updated guides maintain the distinction between standard PAR (GST F28) and certified PAR (GST F28A). The latter is required when the ACAP reviewer is an internal audit team rather than an external public accounting entity. Practitioners must ensure correct template selection; the certified report imposes additional attestation requirements. Paragraph 4.2 has been added to Appendix 3 of both guides to clarify the circumstances engaging certified review requirements .
B. Documentary Evidence and Audit Trail
While FormSG provides immediate acknowledgement of submission, the declaration does not substitute for the substantive PAR working papers. Entities must retain complete documentation substantiating the PAR scope, sample selection, testing outcomes, and error remediation. The declaration confirms completion; it does not constitute evidence of the review’s adequacy. Given IRAS’s increasing digitisation, taxpayers should anticipate potential data matching between FormSG submissions and historical GST F28/F28A lodgements.
C. Editorial Revisions and Interpretation Risk
Both e-Tax Guides contain unspecified “other editorial changes” aimed at clarity and consistency . While presented as non-substantive, such revisions often refine IRAS’s interpretation of existing requirements. Practitioners conducting renewal reviews should read the amended guides in their entirety rather than relying on redlined extracts. Particular attention is warranted for amended paragraphs 3.7 and 9.3.7 of the Renewal guide, which contextualise the removal of Renewal PAR obligations.
D. Interaction with GST Scheme Administration
For taxpayers concurrently holding ACAP status and GST schemes (MES, IGDS), the continued ability to utilise PAR as an ASK substitute remains critical. Entities pursuing scheme applications should not assume the Renewal PAR exemption extends to scheme support documentation. Explicit confirmation of the intended application pathway is advisable prior to scoping review engagements.
Compliance Timeline and Transition
| Effective Date | Requirement | Applicability |
|---|---|---|
| 1 Jan 2025 (retrospective) | Renewal PAR not required | ACAP Renewal status approved on/after this date |
| 1 Feb 2026 | FormSG declaration mandatory | All PAR completions on/after this date |
| 30 Jan 2026 | e-Tax Guides updated | Immediate adoption |
Observation
The amendments signal IRAS’s confidence in the ACAP renewal process while simultaneously tightening post-completion administrative compliance. The removal of Renewal PAR reduces compliance cost—a tangible benefit for the c.900 active status holders. However, the mandatory FormSG declaration introduces a new procedural step that, if overlooked, could result in administrative non-compliance despite substantive review completion.
Tax Accountants should:
-
Update internal ACAP renewal checklists to reflect the PAR exemption for qualifying approvals;
-
Integrate FormSG submission into PAR project plans as a non-delegable completion step;
-
Verify current scheme application methodologies (PAR vs ASK) to avoid unintended gaps; and
-
Refresh template inventories to the January 2026 revisions of GST F28 and GST F28A.
The full e-Tax Guides are available on the IRAS website. The FormSG declaration portal is accessible via the hyperlinks embedded in paragraph 16 (ACAP guide) and paragraph 13 (Renewal guide).
Source: IRAS website, 3 February 2026