VCC Compliance: Avoiding ACRA Annual Return Filing Issues

Under the Variable Capital Company (VCC) Act, VCCs are required to file an Annual Return with ACRA within seven (7) months of the financial year-end (FYE). For most VCCs with a 31 December FYE, this means the filing must be completed by 31 July each year.

This article highlights key filing requirements, common mistakes, and how fund managers stay ahead of compliance obligations.

Why Timely Filing Matters

Timely submission of the Annual Return is not just a formality; it's a statutory obligation. Missing the deadline can lead to:

Compliance breaches under the VCC Act.
Reputational risks for regulated fund managers.
Investor concerns about operational risk.
Late filing penalties of up to S$600 per return.

Filing on time demonstrates good governance and avoids avoidable administrative issues.

Key ACRA Annual Return Filing Requirement

Item	Requirement
Who files	VCC (through officers or registered filing agent).
Key deadlines	Issuance of audited financial statements: within five (5) months after FYE to qualify for exemption from holding an Annual General Meeting (AGM); or at least 14 days before AGM date. AGM: within six (6) months after FYE. Annual Return filing deadline: within seven (7) months after FYE.
Information/ Documents required	VCC details: Verify that the type of VCC, registered office address, particulars of the VCC officers and manager, business activity and information relating to any sub-funds are accurate and up to date. Update ACRA records if any changes have occurred. Investment strategy of the VCC and each of its sub-funds. Signed audited financial statements of the VCC and individual signed audited financial statements of any sub-funds in PDF format. AGM date or date when audited financial statements were sent to all persons entitled to receive notice of AGM (for VCCs exempted from holding an AGM).
Filing method	Via BizFile+ on VCC Register portal.

Common Filing Mistakes Observed

Late initiation - Filing often left to the last week of July.
Incorrect dates - Errors in financial period or approval dates.
Entity confusion - Confusion between VCC and its sub-funds in reporting.
Financial statements - Not preparing separate audited financial statements for the VCC and each of its sub-funds.

What Fund Managers Should Do Now

Set internal timelines by early May (to qualify for exemption from holding an AGM) or by early June (to hold an AGM).
Review financial statements and sign off ahead of AGM-exemption or AGM deadline.
Coordinate with your fund admin and company secretary early.
Keep documentation ready for members' resolutions to be passed by written means or AGM minutes.

Supporting VCC Fund Managers

We assist fund managers in staying on top of VCC obligations. Our services include:

Checklist and reminders tailored to your VCC structure.
Review and preparation of Annual Return documentation for smooth submission.
Full BizFile+ submission support.

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References

VCC Act - Section 97 - Annual Return
ACRA Guideline on Annual Return

Need help with your 31 July deadline?

Connect with us at vcc@crowe.sg, to ensure timely and accurate ACRA filing.