Is It Safe to Submit XBRL Without Internal Review?

For many Singapore SMEs, XBRL preparation is often handled by an external accountant or corporate service provider. Once the file is generated and validation errors are cleared, it may feel safe to simply approve and submit.

But this raises an important governance question:

Is it safe to submit XBRL without internal review?

The short answer: No — it is not advisable.

Here’s why.

1️⃣ Directors Remain Legally Responsible

Under Singapore’s Companies Act, directors are responsible for:

• Ensuring financial statements give a true and fair view
• Confirming disclosures are complete
• Filing statutory documents accurately and on time

Outsourcing preparation does not transfer legal responsibility.

If errors exist in the XBRL submission, accountability still rests with the directors — even if the file was prepared externally.

Internal review is not optional governance. It is part of director duty.

2️⃣ XBRL Validation ≠ Financial Accuracy

ACRA’s XBRL system performs technical validation checks, such as:

• Numerical balance
• Required field completion
• Taxonomy consistency

But passing validation does not mean:

• The figures are commercially reasonable
• Disclosures are complete
• Classification is appropriate
• Year-on-year fluctuations are justified

Technical acceptance is not the same as financial correctness.

3️⃣ Common Risks Without Internal Review

Submitting without review increases risk of:

• Misclassified revenue or expenses
• Incorrect related-party disclosures
• Inaccurate director remuneration reporting
• Audit exemption misassessment
• Solvency declaration inconsistencies
• Outdated share capital information

Many of these issues are not caught by automated checks.

4️⃣ Material Errors Are Costly to Correct

If financial data must be revised after submission:

• Amended filings may be required
• Additional administrative effort increases
• Professional fees may rise
• Regulatory scrutiny may increase

Preventive review is significantly cheaper than corrective action.

5️⃣ What Should Internal Review Cover?

Directors do not need to review taxonomy coding, but they should confirm:

✔ Financial statements match business reality
✔ Large fluctuations are explained
✔ Liabilities and loans are properly disclosed
✔ Share capital and director information are accurate
✔ Audit exemption eligibility is confirmed
✔ XBRL figures match approved financial statements

This review protects both compliance and governance integrity.

6️⃣ Reduce Review Stress Through Continuous Discipline

Internal review becomes easier when:

• Bookkeeping is updated monthly
• Bank reconciliation is complete
• Financial statements are prepared early
• Documentation is organized

AI-powered platforms like ccMonet help SMEs strengthen financial foundations by:

• Automating bookkeeping
• Performing AI-driven reconciliation
• Standardizing categorization
• Providing real-time financial dashboards
• Combining automation with expert review

When financial data is structured and transparent throughout the year, internal review becomes confirmation — not investigation.

Final Takeaway

Submitting XBRL without internal review is risky.

Even if prepared by professionals, directors remain responsible for accuracy and completeness.

A short but structured internal review:

• Reduces error risk
• Protects governance credibility
• Prevents costly amendments
• Strengthens director oversight

Compliance should never be blind approval.

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