Skip to main content

Doc 20 — Professional Review and Filing Authorisation Terms

  • Document: 20 — Professional Review and Filing Authorisation Terms
  • Version: 20-professional-review-filing-authorisation-2026-08 (in force on publication)
  • Party / entity: the Customer and Upvue Pte Ltd (UEN 201201846Z) (the "Firm"); DPW Pte. Ltd. (UEN 202017982R) ("DPW") is referenced only as Platform operator
  • Audience: Customers; also referenced by Participating Firms and Professionals

1. Purpose

1.1 These Professional Review and Filing Authorisation Terms (these "Filing Terms") describe exactly how a filing comes to be made in your Engagement: the distinct steps, who performs each one, and — just as importantly — what each step does not mean. They are incorporated into Doc 03 — Singapore Terms of Business.

1.2 One principle governs everything below: no software output, and no third-party check result, is ever a decision. Every approval and every filing is a human professional act by the Firm.

2. The eight steps

2.1 The workflow consists of eight distinguished steps. No step collapses into, substitutes for, or automatically triggers any later step.

Step 1 — AI recommendation. The Platform's AI-assisted tooling may extract, organise, classify or suggest information (see Doc 09 — AI / Automation Terms ("AI Terms")). Actor: Platform software, operated by DPW. An AI recommendation is advisory input only. It is not advice, not a compliance result, not an approval, and creates no entitlement to any outcome.

Step 2 — KYC provider result. A Third-Party Service Provider may return an identity-verification or screening result (for example a "clear", "match" or error result). Actor: external provider, engaged as a tool of the Firm's due diligence. A provider result is raw input to the Firm's client due diligence. A "clear" or "pass" result is not approval of any person or engagement, and does not by itself verify anyone: automated classification assists, but no engagement is approved and no filing is made without a human professional decision. Any match, inconsistency or error always creates a mandatory human task.

Step 3 — Staff review. Authorised staff review the collected information, documents and provider results, resolve queries and prepare the matter for decision. Actor: the Firm's authorised staff (using Platform tooling as the Firm's tool). Staff review is preparation. It is not the Firm's approval and not authority to file.

Step 4 — Professional approval. The Firm's authorised persons decide whether the client due diligence is satisfied and the matter may proceed, applying the Firm's professional judgement and its obligations under the Corporate Service Providers Act 2024. For certain roles and risk profiles this requires approval by two authorised persons (dual approval). Actor: the Firm's authorised approvers. Professional approval is a decision about the client and the pack. It is not yet authority to file anything, and it does not bind the Firm to file.

Step 5 — Filing authorisation. You authorise the Firm to submit the approved filing pack, under Section 4 below. Actor: the Customer (through its Authorised Representative). Your authorisation permits — it does not compel — submission (see Section 5). It is not the filing itself.

Step 6 — Filing submission. A qualified Professional of the Firm personally submits the filing to ACRA through BizFile using the Firm's own credentials. Actor: the Firm's qualified Professional. Submission is the Firm's act, never DPW's and never the software's. Submission is not acceptance: the authority may still query or reject it.

Step 7 — Government acceptance. ACRA (or another authority) processes the filing at its own discretion and on its own timetable, and may accept, query or reject it. Actor: the government authority. Acceptance is the authority's act alone. Neither the Firm nor DPW controls or guarantees it, and pending acceptance is not incorporation.

Step 8 — Incorporation completion. On acceptance of an incorporation filing, the authority issues the company's Unique Entity Number (UEN); the Firm's Professional records the UEN and the Firm confirms completion to you. Actor: the authority (issuance) and the Firm's Professional (recording and confirmation). Completion of one filing is not approval of any future filing; each subsequent filing restarts at the appropriate step.

3. The two human gates

3.1 Two steps are absolute human gates and can never be automated, delegated to DPW, or bypassed by any Platform feature:

(a) KYC approval (Step 4) — made only by the Firm's authorised persons, with dual approval where applicable under the Firm's controls; and

(b) ACRA filing (Step 6) — performed only by the Firm's qualified Professional on BizFile, who also enters the resulting UEN.

3.2 No result from any AI feature or Third-Party Service Provider — including any "clear", "pass" or zero-match result — automatically approves any person, engagement, document or filing, or moves a matter through either gate.

4. Your filing authorisation

4.1 By giving filing authorisation for a filing, you authorise the Firm to submit the approved pack for that filing to the relevant authority.

4.2 Your filing authorisation is:

(a) per-filing — it applies only to the specific filing and pack identified to you, and is not a standing or general authority;

(b) conditional on your review — you must first review and approve the final documents in the pack; you must not authorise a filing you have not reviewed; and

(c) revocable until submission — you may withdraw it through the Platform or in writing at any time before Step 6 occurs. Once the Firm's Professional has submitted the filing, it cannot be recalled, and withdrawal has no effect on it.

4.3 Withdrawal of filing authorisation does not by itself terminate the Engagement; Doc 10 — Payment Terms, Doc 03 Section 16 and Doc 14 Section 9 govern the consequences, including fees for work performed.

5. The Firm's independent right to decline

5.1 Your filing authorisation permits the Firm to file; it never obliges the Firm to file. The Firm may decline to submit, or may pause, any filing until its professional review and client due diligence are complete and it is satisfied that filing is proper and lawful.

5.2 You cannot use the Platform contract (Doc 02), a Service Order, payment of fees, or any Platform feature to compel the Firm to make a filing. Doc 03 Section 8 (anti-money laundering) applies, including the Firm's right to decline or exit without giving reasons where the law restricts it.

5.3 If the Firm declines to file, fees and refunds are handled under Doc 10 — Payment Terms.

6. Government rejection and queries

6.1 A rejection of, or query raised on, a filing by an authority is not a breach of the Engagement by the Firm and is not a failure of the Professional Services.

6.2 On a rejection or query the Firm will tell you what is required. Any re-work, re-submission and associated fees are handled under Doc 10 — Payment Terms, and additional Government Fees for a re-submission are allocated under Doc 03 clause 15.4 (the Firm bears them where the re-submission results from its own error; they are payable by you where it results from your error or from government discretion). A re-submission is a new filing for the purposes of Steps 4 to 6, and a fresh filing authorisation is required where the pack has materially changed.

7. Records and evidence

7.1 The Platform keeps an audit trail of each step in Section 2 — including who acted, in what capacity, and when — and the Firm keeps the client due diligence and engagement records the law requires it to keep. These records are retained in accordance with Doc 17 — Document Retention / Records Notice ("Retention Notice"), including the statutory minimum retention of client due diligence records for at least five years after the end of the relationship.

7.2 The audit trail evidences that each human gate in Section 3 was performed by a human. It is available to the Firm without restriction and, where the law requires, to regulators.

8. Relationship to AI features

8.1 The AI Terms (Doc 09) govern the Platform's AI-assisted features. For the purposes of these Filing Terms it is sufficient to state: AI output may be incomplete or incorrect, is advisory only, may be reviewed by humans, and is never professional advice, professional approval (Step 4), filing authority (Step 5) or a filing act (Step 6).

9. General

9.1 These Filing Terms are governed by Singapore law and follow the precedence, dispute-resolution and general provisions of Doc 03 — Singapore Terms of Business. If these Filing Terms conflict with any other description of the workflow in the suite, these Filing Terms prevail for the subject matter of professional review and filing authorisation.

Version: 20-professional-review-filing-authorisation-2026-08 · Approval: management-attested