Types of Complaints Against Professional Conduct

For Public Accountants For Public Accounting Firms/Corporations/LLPs
Any improper or dishonourable conduct on the part of a public accountant in the discharge of his professional duty Any improper act or conduct on the part of a public accountant, an accounting corporation, a public accounting firm or an accounting limited liability partnership

Examples of Issues Relating to Professional Conduct by the Public Accountants or Public Accounting Entities

  • breach of independence requirements under the Code of Professional Conduct and Ethics for Public Accountants and Accounting Entities (for example public accountant undertaking audit of a company in which the spouse was a director or secretary of the company)
  • failure to exercise adequate professional competence and due care in carrying out audits
  • misappropriation of monies by the public accountant while acting as a liquidator
  • misappropriation or unauthorised use of funds belonging to the public accounting entities by the public accountant
  • acting as an approved liquidator when his/her liquidator’s approval had expired

When to Lodge a Complaint

Commonly, complaints are lodged when there is evidence to support improper acts or dishonourable conduct.

Ideally, complaints are lodged as soon as improper acts have been observed or committed.

How to Lodge a Complaint

Step 1: Prepare

Prepare a written complaint and a statutory declaration (PDF, 77KB) sworn before a commissioner of oaths or notary public. Clearly state the nature of the professional misconduct alleged against the public accountant.

Step 2: Attach

Attach all relevant supporting documents. Please note that all information submitted may be made available to the public accountant and public accounting entity concerned for his/her/its response.

Step 3: Submit

Submit the documents to: 
Public Accountants Oversight Committee 
Accounting and Corporate Regulatory Authority 
10 Anson Road 
#05-01/15 International Plaza 
Singapore 079903

Attention: The Registrar of Public Accountants

Review of Complaint by the Registrar of Public Accountants (Registrar)

Upon receiving a complaint,  the Registrar will review the complaint to determine if the complaint is frivolous, vexatious, misconceived or without merit.  If so, the Registrar will dismiss the complaint.  Otherwise, the Registrar will recommend to the Public Accountants Oversight Committee (PAOC) to refer the complaint to a Complaints Committee (CC) or a Disciplinary Committee (DC) for an inquiry.  A complaint is referred directly to the DC where it relates to the conviction of the public accountant or the public accounting entity of an offence involving fraud or dishonestly or implied defect in character which makes the public accountant concerned unfit for his profession.

The duration of the review will vary on a case-by-case basis and could take up to 6 months.  ACRA will notify you on the outcome of the review.

What To Do After Lodging

Wait for a Full Response

After lodging, ACRA will acknowledge receipt of the complaint within 3 working days.   

In reviewing the complaint, ACRA may need clarification or more information from the complainant to support his/her allegations.  ACRA will write to the complainant to seek such information as necessary.

Review of Complaint by the Registrar of Public Accountants (Registrar)

Upon receiving a complaint,  the Registrar will review the complaint to determine if the complaint is frivolous, vexatious, misconceived or without merit.  If so, the Registrar will dismiss the complaint.  Otherwise, the Registrar will recommend to the Public Accountants Oversight Committee (PAOC) to refer the complaint to a Complaints Committee (CC) or a Disciplinary Committee (DC) for an inquiry.  A complaint is referred directly to the DC where it relates to the conviction of the public accountant or the public accounting entity of an offence involving fraud or dishonestly or implied defect in character which makes the public accountant concerned unfit for his profession.

The duration of the review will vary on a case-by-case basis and could take up to 6 months.  ACRA will notify you on the outcome of the review.

Complaints Referred to Complaints Committee (CC)

The Committee comprises 3 public accountants and 1 layperson from the Complaints and Disciplinary Panel.

Generally the process involves the CC reviewing the documents on hand and seeking clarifications from the public accountant / public accounting entity concerned.  The CC may also request for oral evidence.

Inquiry

The CC has 3 months to complete its inquiry. An extension may be granted by the PAOC if more time is needed.

Outcome of Inquiry

Upon completing the inquiry, the CC may:

  • dismiss the complaint and notify the PAOC and all parties involved
  • recommend to the PAOC to:
    • issue a warning; or
    • order a letter of advice; or
    • make such other order (E.g. orders a public accountant to reviews his engagements and provide confirmation that is in compliance with certain areas of the Code of Professional Conduct and Ethics); or
    • constitute a DC to hold a formal inquiry.

Complaints Referred to the Disciplinary Committee (DC)

The Committee comprises 4 public accountants and 1 layperson from the Complaints and Disciplinary Panel.

Generally the process involves ACRA setting out the charges against  the public accountant / public accounting entity for them to submit theirdefence.  A pre-hearing conference is usually held by the DC to expedite disposal of the proceedings, allow the DC to better manage the inquiry, and improve the quality of the proceedings and involves the public accountant / public accounting entity and ACRA’s Counsel.  Affidavits of evidence-in-chief (if applicable) are exchanged and the formal inquiry hearing will commence. 

Formal Inquiry

The Committee has 6 months to complete its formal inquiry. An extension may be granted by the PAOC if more time is needed.

Outcome of Formal Inquiry

Upon completing the formal inquiry, the DC could make any one of the following recommendations to the PAOC.  The PAOC will make its decision thereafter.

For Public Accountants For Public Accounting Firms/Corporations/LLPs
  • cancel the public accountant’s registration
  • suspend the public accountant from practice for up to 2 years
  • impose conditions necessary to restrict the practice of the public accountant for a period of up to 2 years
  • impose a penalty of up to S$10,000
  • write a censure to the public accountant
  • recommend that the public accountant to give such undertaking as PAOC thinks fit (e.g. undertake not to perform audits on listed companies for 3 months)
  • revoke the approval granted to the accounting corporation/firm/LLP
  •  suspend the accounting corporation/firm/LLP from providing public accountancy services for up to 2 years
  • impose conditions necessary to restrict the provision of public accountancy services for up to 2 years
  • impose a penalty of up to S$100,000
  • write a censure to the accounting corporation/firm/LLP
  • require the accounting corporation/firm/LLP to give such undertaking as the Disciplinary Committee thinks fit (e.g. undertake that for all charities audited by the entity, to have a reviewing partner in addition to a signing partner)

Legal Obligations of Public Accountants

Under the provisions of the Accountants Act (Cap 2), all public accountants and public accounting entities (accounting firms / corporations / limited liability partnerships (LLPs)) are required to:

  • comply with the legal and regulatory requirements of the profession 
  • conduct themselves professionally when dealing with their clients and other third parties and to avoid improper conduct that would bring the profession of public accountancy into disrepute

ACRA does not regulate:

  • accountants in general (including accountants providing bookkeeping services)
  • the manner in which the public accounting entities operate their business or the quality of service provided by the entities

Who Can Lodge a Complaint

Any member of the public can make a complaint to ACRA against public accountants and public accounting entities (accounting firms / corporations / LLPs).

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