VCC Act 2018 — Section 90 auditor approval — Complete 2026 guide

Section 90 of the vcc act 2018 (VCC Act 2018) requires every Variable Capital Company to appoint a public accountant approved by ACRA as auditor. In 2026 the appointment must be made within three months of the VCC’s incorporation, and the audit must be completed annually under Singapore Standards on Auditing as adopted by the Institute of Singapore Chartered Accountants (ISCA).

Raffles Corporate Services works with a panel of corporate and employment law firms; this article is general information, not legal advice.

What Section 90 imposes

Section 90 of the Variable Capital Companies Act 2018 establishes that every VCC must appoint an auditor who is a
public accountant approved by ACRA under the Accountants Act 2004. The audit must be conducted in accordance with the
Singapore Standards on Auditing. The auditor’s report must be tabled at the VCC’s annual general meeting (or
provided to members where the AGM is dispensed with under Section 175A of the Companies Act 1967, applied to VCCs by
Section 80 of the VCC Act 2018).

For wider VCC structuring see our companion guide and for the directors’ employment-pass and operational
staffing context see incorporation companion piece.

Auditor eligibility

• Must be a public accountant registered with ACRA under the Accountants Act 2004.
• Must hold a current Practising Certificate.
• Must be independent of the VCC, its directors and its fund manager — under the ISCA Code of Professional
  Conduct and Ethics.
• Must have the technical capability to audit fund-vehicle financial statements, including NAV verification,
  investor capital accounts and performance fee mechanisms.

See VCC Compliance and Provider Checklist for Indonesian Business Families for the related fund administrator regime in Section 86.

Sub-fund audit treatment

For umbrella VCCs with multiple sub-funds, the VCC may either: (i) appoint one auditor to audit all sub-funds; or
(ii) appoint different auditors for different sub-funds — subject to disclosure in the financial statements. ACRA’s
VCC FAQ (December 2020 edition, still current in 2026) confirms this flexibility.

Cost and timeline benchmarks

• Annual VCC audit fee (single fund): S$8,000–S$25,000 depending on AUM and investor count.
• Annual VCC audit fee (umbrella with 3 sub-funds): S$25,000–S$60,000.
• Audit timeline from FYE: 6–10 weeks for an Asian fund of moderate complexity.
• Sub-fund segregation testing: typically adds 2 weeks to the audit timeline.

The appointment process

1. Within 3 months of VCC incorporation, directors appoint the auditor by resolution.
2. Notify ACRA via the BizFile+ portal of the auditor’s particulars.
3. Establish the audit engagement letter scoping the financial reporting framework
   (Singapore Financial Reporting Standards or International Financial Reporting Standards).
4. Conduct annual audit; auditor issues opinion under SSA 700.
5. File audited financial statements with the Annual Return.

Common mistakes

The recurring issues in 2026: (1) appointing an auditor without a current Practising Certificate, voiding the
appointment; (2) failing to maintain auditor independence — common where the auditor’s firm also provides tax-compliance
services to the manager; and (3) confused treatment of sub-fund audit fees in the offering document, leading to
investor disputes over expense allocation.

Authoritative references

Authoritative sources: Variable Capital Companies Act 2018 at Singapore Statutes Online,
the Accounting and Corporate Regulatory Authority (ACRA)‘s VCC and public accountant registers, and
the MAS Explainer on VCCs.

FAQs

Can a VCC have a different auditor for each sub-fund? Yes — ACRA permits sub-fund-specific
auditor appointments subject to disclosure.

Is auditor rotation mandatory? Not for VCCs in 2026 (unlike listed companies). Best practice is
to consider rotation every 5–7 years.

Can the auditor be an overseas firm? No — the auditor must be an ACRA-registered public accountant
or firm in Singapore.

What financial reporting framework applies? The VCC’s constitution must specify either Singapore
Financial Reporting Standards, IFRS, or US GAAP. SFRS is the default.

When is the first audited report due? Within 7 months of the VCC’s first FYE (mirroring the
Annual Return deadline for private companies under the Companies Act 1967).

Need help with this? Call, SMS or WhatsApp +65 8501 7133, or email hello@rafflescorporateservices.com. Raffles Corporate Services works with a panel of corporate and employment law firms; this article is general information, not legal advice.