All Singapore incorporated companies are required to file financial statements with ACRA, except for those which are exempted. Based on current ACRA updates, only solvent exempt private company (i.e. less than 20 shareholders, none of which is a corporation or private company owned by the Government that is declared in the Gazette to be an exempt private company) are exempted from filing financial statements.
Definition of Exempt Private Company:
A private company can have not more than 50 members. An exempt private company can be a private company with less than 20 members, and does not have any corporations holding beneficial interest in its shares (whether directly or indirectly). An exempt private company can also be a private company owned by the Government that is declared in the Gazette to be an exempt private company.
An exempt private company is insolvent if it is unable to meet its debts when they are due. Insolvent EPCs are required to file FS as mentioned.
Solvent EPCs only need to make an online declaration of their solvency, and filing FS is voluntary.