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Revised Findings from Review of Financial Statements Filed in XBRL Format


ACRA has completed an independent review of the companies’ financial statements submitted in XBRL (XBRL FS). Based on a limited review, and our experiences in dealing with the XBRL filings, we have identified findings for companies to take note in their future preparation of XBRL filings to improve the quality of the filings.

These findings and examples (provided for illustrative purposes) are not meant to be a comprehensive list of all errors identified during the reviews. Companies should continue with their due diligence in ensuring the high quality of their filings with the Registrar.

Companies which note errors in their past XBRL filings, including findings that are reflected here, should file a Notice of Error (NOE) to rectify the errors if the errors are typographical or clerical in nature. Companies may face prosecution if the errors are found to be materially false or misleading.

The e-guide to filing NOE through BizFile is available here.

Note: Terminologies used in this page are in accordance with FRS 1 Presentation of Financial Statements (effective date 1 January 2007). With the adoption of FRS 1 (R) Presentation of Financial Statements (effective for financial periods beginning on or after 1 January 2009), certain terminologies will have changed. However, the findings and comments here remain valid.

* Applicable for Option A (Full XBRL) and Option B (Partial XBRL) Filings

- Differences between AGM FS and XBRL FS, where XBRL FS should be Modelled Closely After 
  (or for Option A Filing, Identical in Content to) the AGM FS

Omission or Incomplete Provision of Comparative Figures
Omission or Incomplete Provision of Group / Company Figures
Inappropriate Use of User-Described Fields
Inappropriate Use of Prescribed Fields
Incorrect Selection of Currency
Incorrect Selection of Currency Unit
- Incorrect Selection of Taxonomy Versions
Incorrect Disclosure of Audit Exemption
- Incorrect Disclosure of "True and Fair Override"
- Inconsistent Disclosure of Company Type and Listing on Securities Exchange
- Incorrect Selection of Presentation Format for the Four Primary Statements

* Applicable for Option A (Full XBRL) Filings only

- Incomplete Notes to the Financial Statements
- Omission of Name(s) of Signing Director(s) in FS Manager
- Inconsistent Page Number between Statement by Directors and / or Independent Auditors’ 
  Report and PDF Copy

- Recommended Creation of Text and Tables Directly in FS Manager

Applicable for Option B (Partial XBRL) Filings only

Incomplete Mandatory Fields in Cash Flow Statement
- Inaccurate Disclosure of “0” Share Capital
- Missing Full Set of AGM FS in PDF

Applicable for Option A (Full XBRL) and Option B (Partial XBRL) Filings

Description

Examples

Differences Between AGM FS and XBRL FS

XBRL FS should be modelled closely after (or for Option A Filing, identical in content to) the financial statements tabled at or used for purposes of the Annual General Meeting (AGM FS).

Where items are presented in the AGM FS, the same items should be provided in the XBRL FS and vice versa. There should not be any omission or change of details, unless necessary.

 

Differences in Details Between AGM FS and XBRL FS

AGM FS (Balance Sheet)

Trade and Other Receivables 10,000
Trade Receivables 6,000
Other Receivables 4,000

XBRL FS (Balance Sheet)

Trade and Other Receivables 10,000

Textual error
(1)
AGM FS: "the property was mortgaged for short-term revolving loans…"

XBRL FS: "the property was mortgaged for long-term loans…"

(2)
AGM FS is not audited. However, it is indicated in the directors’ report in XBRL FS that the auditors are willing to accept reappointment and that the financial statements were audited.

Numerical error
AGM FS: $1,041
XBRL FS: $1,014

Omission or Incomplete Provision of Comparative Figures

A company, which is not a newly incorporated company preparing its financial statements for the first time since incorporation, should

- Answer "No" to the question of “Is the company preparing financial statements for the first time since its incorporation?” (this is NOT a question of whether the company is preparing XBRL financial statements for the first time) in the section of “Enter Company Registration Number” in FS Manager; and

- Ensure that the XBRL FS contain complete comparative information.

In general, prior period figures should be provided in XBRL FS when it is available in the AGM FS.

Provision of only current year figures for Statement of Changes in Equity in XBRL FS when it is not a newly incorporated company (with comparative figures available in AGM FS).

Omission or Incomplete Provision of Group / Company Figures

A company, which is required to prepare consolidated financial statements according to the Companies Act, Chapter 50, should select “Consolidated accounts” to the question of “Are the accounts prepared on group or consolidated level” in the section of “Enter Accounts Reporting Options” in FS Manager.

Group/company figures should be provided in XBRL FS when it is available in the AGM FS.

Provision of only company level figures in XBRL FS when there are group level figures in AGM FS (consolidated accounts).

Inappropriate Use of User-Described Fields

Whenever possible, a company should use the prescribed fields in the ACRA Taxonomy/FS Manager. The user-described fields should not be used for items of the same or similar concept as that of the prescribed fields.

"Property, Plant and Equipment, Total" is a prescribed field in ACRA Taxonomy/FS Manager but the company creates a user-described field "Property, Plant and Equipment" or "Fixed Assets" in XBRL FS.

Inappropriate Use of Prescribed Fields

A company should leave non-mandatory prescribed fields in FS Manager blank (i.e. not to be completed with “0”) if the item is not reflected in the AGM FS.

The company does not have any interest income and this line item is not reflected in the AGM FS.

However, this line item was indicated as a “0” value in XBRL FS even when it is not a mandatory field.

Incorrect Selection of Currency

The same currency should be used in the XBRL FS and the AGM FS.

When the AGM FS is presented in SGD, the XBRL FS should also be presented in SGD.

Currency error

AGM FS: SGD
XBRL FS: USD

Incorrect Selection of Currency Unit

Preparers are reminded to exercise caution in the selection of currency unit in the section of “Enter Accounts Reporting Options” in FS Manager. The same currency unit precision should be used in the AGM FS and XBRL FS.

When the figures in the AGM FS is presented to the nearest thousand (‘000), the same should be shown in the XBRL FS.

Currency unit error

Revenue in AGM FS: $3,000 (with currency unit “in units”)

Revenue in XBRL FS: $3,000,000 (when the currency unit of “in thousands” was wrongly selected and value entered in the field was $3,000)

Incorrect Selection of Taxonomy Versions

For filings from 31 August 2009 onwards, there are three taxonomy versions available for selection.

Preparers should ensure the correct selection of the taxonomy version according the financial period start date of the XBRL FS, unless certain standards of the Singapore Financial Reporting Standards (FRS) have been early adopted (before its effective date).

Guidance on the various taxonomy versions and selection of the correct taxonomy version is provided inside FS Manager, under the section on “Enter Company Registration Number” in FS Manager.

Taxonomy Selection Error

Financial period start date: 1 July 2008
FRS early adopted (according to notes to financial statements): None
Taxonomy version selected: V2.10

The above company should have selected taxonomy V1.23 instead, as V1.23 is applicable for financial periods beginning on or before 31 December 2008. The company may only select taxonomy V2.10 if it has early adopted the revised FRS 1 (applicable for financial periods beginning on or after 1 January 2009).
   

Incorrect Disclosure of Audit Exemption

Companies should only answer yes to the question of “Is company exempted from audit” under the section of “Independent Auditors’ Report”, if they are exempted from audit. Audit exemption applies only in the following circumstances:

- Exempt private company (EPC) with revenue not more than S$5million for the financial year starting on or after 1 June 2004; or

- Any company, including an EPC, that is dormant for the financial year starting on or after 15 May 2003.

-

Incorrect Disclosure of "True and Fair Override"

In the Independent Auditors’ Report section, a company should only answer “Yes” to the question “Is there a true and fair override?” when non-compliance with any requirement(s) of the accounting standards is necessary for the accounts or consolidated accounts, to give a true and fair view of the matter concerned.

True and fair override is different from modifications in the auditors’ report (i.e. emphasis of matter, qualified opinion, disclaimer of opinion or adverse opinion).

Applicable references in the Companies Act, Chapter 50, are sections 201(14B)(a) and 207(2)(aa).

-

Inconsistent Disclosure of Company Type and Listing on Securities Exchange

Private companies are not to be listed in any securities exchange or in the process of initial public offering (IPO).

Error

A private company answering yes to the questions of “Is the Company in its first year of IPO?” or “Is the Company listed in any securities exchange?”

Incorrect Selection of Presentation Format for the Four Primary Statements

For the four primary statements, companies are allowed to select from a choice of presentation/classification formats permitted by the Singapore Financial Reporting Standards (FRS). Preparers should ensure that the presentation approaches for each of the 4 primary statements selected for the XBRL FS is the same as the AGM FS. More information on the presentation approaches are as follows:

Primary Statement

Formats

Reference

Income Statement By Function By Nature FRS 1 "Presentation of Financial Statements" (effective date: 01/01/07) Paragraph 88 – 94
Balance Sheet By Current/Non-Current classification By Liquidity classification FRS 1 "Presentation of Financial Statements" (effective date: 01/01/07) Paragraph 51
Cash Flow Statement Indirect method Direct method FRS 7 "Cash Flow Statements" (effective date: 01/01/07) Paragraph 18 - 20
Statement of Changes in Equity Statement of Recognised Income and Expense Statement of Changes in Equity FRS 1 "Presentation of Financial Statements" (effective date: 01/01/07) Paragraph 96

Applicable for Option A (Full XBRL) Filings Only

Description

Examples

Incomplete Notes to the Financial Statements

To file XBRL FS under Option A (Full XBRL), the following requirements for the notes to the financial statements should be complied with:

- Similar to the AGM FS, the XBRL FS must be a complete set of financial statements. All the notes to the financial statements MUST be included with the 4 primary statements (i.e. Income Statement, Balance Sheet, Statement of Changes in Equity/Statement of Recognised Income and Expense and Cash Flow Statement) filed in XBRL;

- Similar to the AGM FS, XBRL FS should contain the references to the notes to the financial statements from the 4 primary statements. These references should be made using the “Add Note” function in FS Manager.

To file the XBRL FS under Option A (Full XBRL), preparers should also ensure that all the notes in the corresponding PDF copy of financial statements generated from FS Manager are legible.

-

Omission of Name(s) of Signing Director(s) in FS Manager

Preparers are reminded to select the name(s) of the director(s) who signed off the Directors’ Report and the Statement by Directors from the drop-down list via BizFile log-in. This is to reflect the name(s) of the signing director(s) in the PDF copy of the Directors’ Report and the Statement by Directors, generated from FS Manager.

-

Inconsistent Page Number between Statement by Directors and/or Independent Auditors’ Report and PDF Copy

If a company wishes to indicate the page numbers of the financial statements in the Statement by Directors and/or Independent Auditors’ Report, the page numbers should match the page numbers in the PDF copy generated by FS Manager.

-

Recommended Creation of Text and Tables Directly in FS Manager

The text and tables created directly using FS Manager “Financial Statements Form Editor” (Editor) generally have neater presentation and pose fewer issues to users when saving in Portable Document Format (PDF) as compared to text and tables copied and pasted into FS Manager Editor from an external source document (e.g. Microsoft Word/Excel using the “Copy” and “Paste” function).

-

Applicable for Option B (Partial XBRL) Filings Only

Description

Examples

Incomplete Mandatory Fields in Cash Flow Statement

A company must complete the 3 mandatory fields in the Cash Flow Statement with information from the AGM FS.

The 3 mandatory fields are:

- Net cash flows from (used in) operating activities
- Net cash flows from (used in) investing activities
-
Net cash flows from (used in) financing activities

The company’s cash flow statement in AGM FS contained values but it was indicated as nil value in XBRL FS.

Inaccurate Disclosure of “0” Share Capital

Share capital is a mandatory field to be completed in the balance sheet in XBRL FS. Companies should obtain the accurate share capital value to be entered into XBRL from either the face of the balance sheet in the AGM FS or the notes of AGM FS.

-

Missing Full Set of AGM FS in PDF

A company must submit a PDF copy of its FULL set of AGM FS, in addition to the Balance Sheet, Income Statement and other mandatory information in XBRL format (Option B – Partial XBRL filing).

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Last Updated/Reviewed on 08 Apr 2010