AI-assisted Disclosure Advisory Initiative
Find out how ACRA uses AI to review financial statement disclosures of listed companies and what to do when you receive a Disclosure Advisory Letter (DAL).
ACRA's Disclosure Advisory Initiative
ACRA has developed CLAIR (Compliance Lens for Accounting IRregularities), an AI tool that screens financial statements of Singapore-incorporated listed companies against selected Singapore Financial Reporting Standards (International) (SFRS(I)s) (opens in new tab) to identify potential disclosure gaps for further assessment by ACRA officers.
What CLAIR covers
CLAIR currently covers two standards: SFRS(I) 1-36 (Impairment of Assets) and SFRS(I) 13 (Fair Value Measurement). We will expand coverage to additional standards over time. Where potential disclosure gaps are identified by CLAIR and validated by ACRA officers, we may issue a Disclosure Advisory Letter (DAL) to your company’s Board of Directors.
Note: The absence of observations on other accounting standards does not mean ACRA has reviewed or assessed compliance with them. Your company remains responsible for ensuring your financial statements comply with all applicable SFRS(I)s.
How companies are selected
ACRA uses a risk-based approach to select financial statements for review. A DAL will only be issued where CLAIR and ACRA officers' validation identifies potential disclosure gaps which require your company's attention.
We also intend to conduct thematic reviews to identify trends and common disclosure issues across listed companies. Findings from these reviews will be shared publicly as market-wide observations.
What to do when you receive a DAL
The DAL sets out observations for the company's consideration to help improve future financial reporting.
The observations reflect areas where disclosures could potentially be enhanced. You and your auditors should carefully evaluate each observation, taking into account materiality, your company's specific facts and circumstances, and professional judgment. No response to ACRA is required, as the DAL is advisory in nature.
This initiative is separate from the Financial Reporting Surveillance Programme (FRSP). Companies that receive a DAL are not necessarily subject to a formal FRSP review, and vice versa. However, where ACRA officers identify potential material disclosure non-compliance during validation, such cases may be escalated to the FRSP for further assessment.
While there are no regulatory consequences from the DAL, you should consider enhancements to your future disclosures and remain responsible for ensuring that your financial disclosures comply with the applicable accounting standards.
Frequently asked questions (FAQs)
Will ACRA share the DAL or its observations with other regulators such as SGX?
No. As the DAL is advisory in nature, observations will not be routinely shared with other regulators. ACRA does not intend to publish individual DALs or identify specific companies that receive them. However, we may publish anonymised, market-wide observations based on common themes identified across multiple companies for educational purposes.
Will ACRA inform my external auditor about the DAL?
No. The DAL is addressed to the Board of Directors. ACRA will not separately notify your external auditor. It is your company's responsibility to share the DAL with your auditors as appropriate.
