- Separate who initiates, approves and reconciles company bank payments.
- Increase approval requirements as payment amounts and transaction risks rise.
- ACRA requires internal accounting controls for public companies and their subsidiaries, not private companies.
- Keep accounting records for at least five years after the end of the relevant financial year.
A small company should have clear bank account controls that separate who initiates, approves and reconciles payments, with approval levels increasing as payment amounts rise. While ACRA requires internal accounting controls for public companies and their subsidiaries, private companies should adopt similar safeguards as good practice. Keep accounting records for at least five years after the financial year in which transactions take place.
This guide covers payment approval matrices, bank mandates and monthly reconciliation, with Sleek’s accounting services in Singapore available to help manage your company’s books and financial reviews.
What internal controls does a small company need over its bank account?
A small company’s bank account needs three things: a clear split between who starts a payment, who approves it and who reconciles the account; an approval rule that rises with payment size; and a monthly review against bank statements. Keep records for at least five years after the end of the financial year in which the transactions were completed.
A word on what the law says. ACRA says public companies and their subsidiaries must maintain a system of internal accounting controls, and its page does not state the same duty for private companies. So treat everything below as good practice for a Pte Ltd, not a legal requirement.
That is not a reason to skip it. Controls are how you show your accountant, your co-founder or an investor that money left the account for a reason.
Why do bank account controls matter even in a company of two?
Because the risks in a small team are mostly ordinary ones, not dramatic ones.
- Errors: a supplier invoice paid twice, or a payment sent to the wrong account, is easier to catch when a second person looks first.
- Mixed money: personal spending that runs through the company account leaves entries your accountant has to untangle later.
- Audit trail: an approval you can point to turns “I think we agreed this” into a record.
There is a duty behind the habit too. ACRA’s directors’ key obligations say directors must ensure the financial statements give a true and fair view, and our guide to directors’ duties in Singapore covers the wider picture.
What are the three roles: who initiates, approves and reconciles?
Every payment passes through three jobs, and the segregation of duties small business teams can manage starts with naming them.
- Initiate: the person who creates the payment or uses the card, such as a finance lead entering a supplier transfer.
- Approve: the person who confirms the payment is expected, correctly priced and going to the right payee.
- Reconcile: the person who matches the bank statement to the books each month and queries anything unmatched.
Where team size allows, one person should not do all three. Say your finance lead enters a SGD 2,400 supplier payment twice by mistake: if the same person approves and reconciles, nobody else ever looks at it.
In a company of two, you will not get a perfect split. The segregation of duties small business owners can reach with two people is limited, so the practical compromise is that one person may hold two roles as long as someone independent, such as your accountant, sees the result.
What does a sample approval matrix look like?
Here is a four-tier matrix you can copy. The thresholds are illustrative: set your own based on how much a mistake would hurt, and do not treat any figure as a rule.
| Payment tier | Illustrative size | Who initiates | Who approves | Check afterwards |
|---|---|---|---|---|
| 1. Small routine payments | Up to SGD 300 | Card holder or finance lead | Finance lead or founder, one approver | Monthly reconciliation |
| 2. Supplier payments | SGD 300 to 3,000 | Finance lead | Founder or a second director | Invoice matched before release |
| 3. Payroll | Each pay run | Finance lead or accountant | Founder, with a second person confirming the total | Payroll report compared with the bank debit |
| 4. Large or unusual payments | Above SGD 3,000, any new payee, or anything off-pattern | Finance lead | Two approvers | Written reason kept with the approval |
This is a bank account approval process small company Singapore teams can run with a shared spreadsheet and a monthly review. Start with the tier that worries you most: if large payments are the concern, set only tier 4 now and add the rest as the team grows.
Dual authorisation: when does it help and when does it slow you down?
Dual authorisation means a second person must approve a payment before it is released. A dual authorisation business bank account setup suits tiers 3 and 4 of the matrix, where a mistake costs real money.
It earns its friction in a few places:
- Large or unusual payments, where a second look is cheap insurance.
- Payroll, where one wrong figure repeats across every employee.
- New payees, which nobody has verified yet.
It slows you down when it is applied to small routine spend, or when only one person holds approval rights and goes on leave. Name a backup approver so payments do not stall.
Banks differ in what they offer and how it works, so ask yours before you design around it. A dual authorisation business bank account is a feature to confirm, not assume.
How do you set up the bank mandate and decide who can sign for a company bank account?
The bank mandate Singapore company directors sign is the bank’s record of who may operate the account and how. It is set through a company resolution and the bank’s own forms, and banks differ, so follow your bank’s process rather than a generic one.
Your corporate secretary can prepare the board resolution that records who is authorised. If you need help, see our corporate secretary services.
Before you meet the bank, decide who can sign for a company bank account and what each person may do. Take this checklist with you:
- Which people will be named, and what can each do: view, start a payment, approve one?
- Is a second approval available, and can it apply only above a set payment size?
- Can limits be set per person or per payment?
- Which resolution and bank forms does the bank need before it changes anything?
- How do you add or remove a signatory later, and what proof does the bank ask for?
We do not cover choosing or opening an account here. For that, see our guides to business bank accounts in Singapore and opening a company bank account.
What if you are the only director?
A sole director cannot second-sign, so the aim shifts from preventing a mistake to leaving evidence. Even the bank account approval process small company Singapore founders run alone needs a paper trail.
- Keep a written payment log: date, payee, amount, reason and the invoice it matches.
- Ask your accountant to review the account each month, since they are the independent pair of eyes you lack.
- Keep business and personal funds apart, and pay yourself through proper routes; see our guide to paying yourself as a sole director.
This does not replicate dual authorisation, and it is not meant to. It makes a problem visible within a month instead of a year.
How should you review the account and keep records each month?
Reconcile every account each month, and make sure the person who reconciles is not the sole approver. ACRA says companies must keep records for at least five years after the end of the financial year when the transactions or operations were completed, and that records must be usable to prepare true and fair financial statements.
Your accountant will want three things from the bank side:
- Bank statements for every account, covering every month.
- Your payment log, with the reason for each payment.
- Evidence of approvals, such as the email, message or system record.
What should you do when someone leaves or a signatory changes?
Remove access as soon as the person leaves, and update the bank. A card or login nobody monitors is an easy gap to leave open.
- Remove the person’s card, app access and approval rights.
- Pass a new resolution and complete the bank’s forms, so the bank mandate Singapore company directors signed matches reality, and keep the new resolution on file.
- Update your approval matrix and tell your accountant who now approves what.
- If the person was a director, your corporate secretary also updates the change in directors with ACRA.
Banks differ on how long a change takes, so ask yours and plan the handover around the answer. This guide is general information, not legal, audit or banking advice, so check your own bank’s process and confirm any legal question with a qualified professional.
How can Sleek help you set up approvals?
Sleek’s accounting services include monthly bookkeeping and management reports, with bank feeds syncing transactions into the books, so your monthly review starts from clean numbers. Our corporate secretary team prepares the board resolutions behind your mandate and handles director changes with ACRA.
To see how Sleek approaches business banking, look at the Sleek Business Account. For the wider picture of running your finances, start at our hub for accounting and tax for Singapore companies.
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FAQs on small company bank account controls
Can an accountant have view-only access to our bank account?
Ask your bank, because access types differ between providers and some may not offer view-only access at all. If yours does not, send your accountant monthly statements and your payment log instead. Either route gives them what they need to reconcile without any power to move money.
Can someone who is not a director sign for the company's bank account?
The bank decides who it accepts, and the company authorises people through its resolution. If you want a finance manager to approve payments, ask your bank whether it accepts a non-director in that role and what documents it needs. Record who can sign for a company bank account, and each person’s limits, in your approval matrix.
Does a nominee director have access to the company bank account?
No. Sleek’s Nominee Director is appointed for compliance purposes only and does not have executive power or access to the company’s bank accounts. Choose your approvers from your own team, and record them in the mandate and the approval matrix.
What will an investor expect to see about our bank account controls?
Ask the investor’s counsel for their request list, because requirements vary by deal. Having your approval matrix, the board resolution behind your mandate and recent monthly reconciliations ready lets you answer quickly. Your accountant can pull the reconciliations together.
