IRAS Record Keeping Requirements: The Document Trail a Singapore SME With No Finance Team Can Actually Produce

If IRAS or ACRA asks a Singapore SME to substantiate a figure, the company must be able to produce source documents, accounting records and — if GST-registered — tax records covering the last five years. Most owner-run companies technically meet that requirement: the paper exists somewhere. The failure is retrieval. Invoices sit in one person's inbox, supplier receipts in a WhatsApp thread, bank statements in a folder nobody has opened since the last financing application, and the one person who knows where everything is happens to be on leave. Between now and the 30 November corporate tax deadline is the cheapest window all year to fix this, because you are already handling the same documents to close Q3 and prepare Form C-S.

What records does a Singapore company actually have to keep?

Three categories, and it helps to stop treating them as one pile.

• Source documents — sales invoices, supplier invoices, receipts, delivery orders, purchase orders, credit notes, bank statements, contracts and employment records. These are the evidence.
• Accounting records — the ledgers, journals, bank reconciliations and schedules that turn evidence into financial statements. Under the Companies Act, these must be kept for five years from the end of the financial year they relate to.
• Tax records — tax computations, capital allowance schedules, and for GST-registered businesses the tax invoices, import permits and GST account. IRAS also works to a five-year retention period.

Records may be kept electronically. You do not need a filing cabinet of originals. What you do need is a system where an electronic record is complete, legible, and traceable back to the transaction it supports.

What does IRAS actually ask for when a query lands?

Rarely everything. Almost always a specific chain: a figure in the return, the ledger entry behind it, the invoice behind that, and the bank payment that settled it. A director's fee, a large repair expense claimed as deductible, an unusually high input tax claim, a related-party transaction — these are the kinds of lines that draw a question.

The practical test is not whether you kept the invoice. It is whether you can hand over four linked documents for one transaction without reconstructing the week around it. An SME that can do that in an afternoon is in a completely different position from one that needs three weeks and an ex-employee's cooperation — even though both technically complied.

Where do SME document trails break down?

Four points, in roughly this order of frequency:

Documents live in personal accounts. The supplier invoice went to the owner's Gmail. The delivery order was photographed on a staff member's phone. When that person leaves, the record leaves with them, and no retention policy in the world helps.

Nothing links to anything. Files are named scan_0043.pdf. The bookkeeper knows which payment cleared which invoice because she remembers, not because a reference number connects them.

Payments are made outside the invoice flow. PayNow to a supplier from the owner's phone, reimbursed later, recorded as a lump sum. The money moved, the substantiation never existed.

The bookkeeper holds the only copy. External bookkeepers are common and perfectly sound, but if the ledgers and working files sit exclusively on their machine, the company does not control its own accounting records. That is a structural exposure, not a service complaint.

What does a working document trail look like without a finance department?

It looks boring, and that is the point. The structure that survives staff turnover is a shared drive organised by financial year, then by document type, with one consistent naming convention:

FY2026 / 02-Supplier-Invoices / 2026-08-14_SupplierName_INV1234_S$2,850.pdf

Date first so files sort chronologically. Counterparty, document number and amount in the filename so the drive itself is searchable without opening anything. Sub-folders for sales invoices, supplier invoices, bank statements, payroll, CPF, GST returns and workings, contracts, and the fixed asset register. Nine folders covers most SMEs.

Then two rules that do the real work. First, every invoice arrives at a company-owned address — accounts@ or invoices@ — not a person's inbox, and suppliers are told so in writing. Second, no payment is released without a document reference recorded against it, so the bank line and the invoice can be matched later by anyone.

Does InvoiceNow change any of this?

It improves the front half. An invoice transmitted through the InvoiceNow network arrives as structured data rather than a PDF attachment, which means it can flow into accounting software without rekeying, and the transmission itself is evidenced. For GST-registered businesses, the phased GST InvoiceNow requirement makes this a direction of travel rather than an option.

What it does not do is organise your supplier receipts, your petty cash, your payroll files or your contracts. E-invoicing solves invoice capture. The document trail is broader than invoices, and the unglamorous folder structure still has to exist underneath it.

How do you build this before 30 November?

Use the close you are already doing. Over three sessions:

1. This week — create the FY2026 folder structure and the accounts@ address. Redirect your ten largest suppliers to it by email. Ten covers most of your spend.
2. Mid-October — as you assemble figures for the Q3 close, file the supporting documents into the structure instead of back into the inbox. You are handling them anyway; the marginal cost is the naming.
3. Early November — before Form C-S preparation, ask your bookkeeper for a copy of the ledgers, trial balance and schedules into your own drive. Repeat this quarterly from now on.

Then run one test. Pick a transaction at random from June, and time how long it takes someone other than you to produce the invoice, the ledger entry and the bank payment. Under fifteen minutes means the system works. Over an hour means you have a retrieval problem that a compliance deadline will eventually find for you.

Frequently asked questions

How long must a Singapore company keep its accounting records?

Five years. Under the Companies Act, accounting records and supporting documents must be retained for five years from the end of the financial year to which they relate. IRAS applies a comparable five-year period for income tax and GST records. Electronic copies are acceptable provided they are complete and legible.

Can we throw away the paper originals once documents are scanned?

Generally yes — IRAS accepts records kept in electronic form, provided the images are complete, readable and retrievable for the full retention period. The sensible practice is to verify the scan is legible before disposal, keep a backup copy in a second location, and retain physical originals of anything with independent legal weight, such as signed contracts, leases and share certificates.

Our external bookkeeper keeps everything. Is that sufficient?

The obligation sits with the company and its directors, not the bookkeeper. Outsourcing the work is fine; outsourcing custody of the only copy is not. Request a quarterly export of the ledgers, trial balance and supporting schedules into a drive the company controls, so that a dispute, a resignation or a service change never leaves you unable to produce your own records.