A GTO audit is an independent check of the gross turnover a retail tenant reports to its landlord, resulting in a signed certificate of gross turnover. Most Singapore mall leases require one within 30 to 90 days of the lease year end, because the landlord uses the certified figure to calculate turnover rent. It is a separate engagement from your statutory audit and is required even if your company is exempt from statutory audit.

If you lease space in a Singapore mall, there is a clause in your tenancy agreement that most tenants only read once: the one requiring you to submit an audited statement of gross turnover after each lease year. Miss it and the landlord is usually entitled to appoint its own auditor at your cost, or to assess turnover rent on its own estimate. This article explains what a GTO audit actually tests, what belongs inside the turnover figure, and why certificates come back rejected.

What is a GTO audit?

GTO stands for gross turnover. A GTO audit is an agreed-scope engagement in which a public accountant examines a tenant’s sales records for a defined lease period and certifies the gross turnover figure reported to the landlord. The deliverable is short: a certificate or statement of gross turnover, signed by the auditor, usually on a template the landlord supplies.

It exists because of how retail leases in Singapore are priced. Most mall tenancies charge base rent plus turnover rent, where turnover rent is a percentage of sales above a threshold. The landlord is therefore relying on a number that the tenant itself produces. The audit is the landlord’s control over that number.

Two things follow from this that tenants regularly get wrong. First, a GTO audit is not a statutory audit and does not replace one. Second, the obligation comes from your lease, not from the Companies Act, so it applies even if your company qualifies for small company audit exemption. A company with no statutory audit obligation at all can still owe its landlord a GTO certificate every year.

Who needs a GTO audit in Singapore?

In practice, the requirement appears in leases for:

• Retail units in shopping malls managed by REITs and large landlords, where turnover rent is standard
• Food and beverage outlets, including kiosks and food court stalls
• Concession counters and shop-in-shop arrangements inside department stores
• Airport, transport hub and attraction retail, where concession fees are turnover-linked
• Some service outlets such as salons, clinics and fitness studios in mall locations

If your lease contains a percentage rent, turnover rent or concession fee clause, assume a GTO certificate is required and check the submission window. Multi-outlet operators should note that landlords normally require a certificate per unit, not one consolidated figure across the chain.

What counts as gross turnover, and what does not

This is where most disputes start. Gross turnover is defined by your lease, not by accounting standards, and definitions differ between landlords. The auditor works to the lease definition. Still, the pattern across Singapore mall leases is consistent enough to plan around.

Usually included in gross turnover	Usually excluded
All cash, card, e-wallet and QR sales at the unit	Goods and services tax collected on behalf of IRAS
Online or app orders fulfilled from or attributed to the unit	Bona fide refunds and returns to customers
Gift voucher redemptions at the unit	Gift vouchers sold but not yet redeemed
Delivery platform sales attributed to the outlet, usually at gross value before commission	Staff meals and genuine internal consumption, where the lease allows
Service charge billed to customers, in many leases	Inter-company transfers of stock at cost

Two items deserve particular attention. Delivery platform sales are commonly required at gross order value before the platform’s commission, which surprises operators who book only net receipts in their ledger. And service charge is included under many leases even though tenants often treat it as a pass-through. Read the clause before you assume.

What the auditor actually tests

A GTO engagement is narrow but not shallow. The core of it is a three-way reconciliation.

• Point of sale system reports for the lease period, agreed to daily Z-readings or system-generated summaries
• The sales figures recorded in your general ledger for the same period
• GST returns filed with IRAS for the quarters covering the period

A mismatch usually means the lease year cuts across filing periods rather than anything being wrong, but it is worth confirming your GST returns are filed and reconciled against the ledger before the engagement starts, because the auditor will raise any difference either way.

Where those three do not agree, the auditor asks why. Legitimate reasons exist, and the most common is a mismatch between your financial year and the lease year: leases typically run on their own anniversary date, so a lease year ending 31 August cuts across two GST quarters and two halves of your financial year. That is a reconciliation exercise, not a problem, provided you can produce the supporting cut.

Beyond the reconciliation, the auditor will normally review the completeness of daily sales records for gaps, test a sample of voided and discounted transactions, check that the exclusions claimed are permitted by the lease, and confirm that the turnover of any concession or consignment arrangement has been treated the way the lease requires.

Why GTO certificates get rejected

Landlords reject certificates more often than tenants expect. The recurring causes:

• The period audited does not match the lease year defined in the tenancy agreement
• The certificate is issued on the tenant’s own wording rather than the landlord’s prescribed template
• Turnover is reported net of GST in one place and gross in another, without reconciliation
• Delivery platform sales are reported net of commission where the lease requires gross
• The auditor is not a public accountant registered with ACRA
• Voids and discounts are material but unexplained, so the landlord queries whether sales were suppressed
• The certificate is submitted after the deadline in the lease, which in many agreements triggers the landlord’s right to audit at the tenant’s cost

Most of these are avoidable by sending the auditor the tenancy agreement itself at the start of the engagement, not just the sales figures. The lease is the scoping document.

What to prepare before the engagement starts

Have these ready and a GTO audit is a short engagement:

• The tenancy agreement, including any supplemental letters varying the turnover clause
• The landlord’s prescribed certificate template, if one exists
• POS reports covering the full lease year, with daily breakdowns
• Monthly sales summaries already submitted to the landlord during the year
• GST returns for the quarters spanning the lease year
• General ledger sales accounts for the same period
• Reports of voided, discounted and refunded transactions
• Delivery platform statements, showing gross order value and commission separately

The single biggest time saver is the monthly sales declarations you already sent the landlord. If the year-end certified figure differs from the sum of those declarations, expect a query, so reconcile them before the auditor does. Tenants without an in-house finance function often have this handled as part of their bookkeeping services in Singapore.

When the GTO audit has to be done

The window is set by your lease. Thirty to ninety days after the lease year end is the common range, with sixty days frequent in mall tenancies. Because lease years rarely align with financial years, this deadline usually sits nowhere near your statutory audit and needs its own reminder in the compliance calendar.

Plan for a second constraint too. If you operate several outlets under different leases, the anniversary dates will be scattered across the year, and each unit has its own deadline. Operators with more than a handful of units generally move to a single auditor handling all certificates so the reconciliation approach stays consistent.

How a GTO audit relates to your other audits

A GTO audit sits alongside, not inside, your other assurance work. If your company also requires a statutory audit, the two engagements use overlapping records but answer different questions: the statutory audit opines on whether your financial statements give a true and fair view, while the GTO engagement certifies one figure for one landlord for one lease period. For the difference between the kinds of audit a Singapore company can face, see internal audit vs external audit at /blog/internal-audit-vs-external-audit/, and for whether a statutory audit is required at all, see /blog/when-is-audit-required-singapore/.

There is a practical benefit to using the same firm for both. The GTO reconciliation surfaces exactly the revenue cut-off issues that a statutory auditor tests, so problems get found once rather than twice.

Frequently asked questions

What is a GTO audit in Singapore?

A GTO audit is an independent examination of a retail tenant’s gross turnover for a lease period, resulting in a certificate of gross turnover signed by a public accountant. Landlords require it because turnover rent is calculated as a percentage of that figure.

Is a GTO audit the same as a statutory audit?

No. A statutory audit covers your full financial statements under the Companies Act and results in an audit opinion. A GTO audit covers one turnover figure for one lease period and results in a certificate. They are separate engagements with separate deadlines.

Do I need a GTO audit if my company is exempt from statutory audit?

Yes, if your lease requires one. Small company audit exemption under the Companies Act removes the statutory audit obligation. It has no effect on a contractual obligation to your landlord.

Does gross turnover include GST?

In most Singapore mall leases, no. GST collected on behalf of IRAS is excluded. Check your lease wording, because the definition of gross turnover comes from the tenancy agreement rather than from accounting standards.

Are delivery platform sales included in gross turnover?

Usually yes, and usually at gross order value before the platform’s commission. Tenants who record only net receipts should prepare a reconciliation from platform statements.

When is the GTO certificate due?

Within the window stated in your lease, commonly 30 to 90 days after the lease year end. The lease year is set by the tenancy anniversary and often does not match your financial year end.

What happens if I submit the GTO certificate late?

Most leases entitle the landlord to appoint its own auditor at the tenant’s cost, or to assess turnover rent on its own estimate. Both outcomes are worse for the tenant than filing on time.

Who can sign a GTO certificate?

A public accountant registered with ACRA. Landlords check this, and certificates signed by an unregistered preparer are rejected.

Need a GTO certificate before your landlord’s deadline?

AG Singapore performs sales and GTO audits for mall and F&B tenants, working from your tenancy agreement so the certificate matches the landlord’s definition and template first time.