By Lucas Seah, Founder of Excellence Singapore Group | Last Updated: October 2026

A Singapore law practice can write up its own books, or it can engage an outside bookkeeper. If it engages one, Rule 11A of the Legal Profession (Solicitors’ Accounts) Rules requires the solicitor to obtain the written approval of the Council of the Law Society of Singapore first, and the application is made again every year. The bookkeeper must be independent of the practice, meet the qualifications in the Law Society’s practice direction, and undertake to report certain problems to the Council.

This guide covers who can keep a law practice’s books, how the approval works, what the Law Society checks and how to choose a law firm bookkeeper. The rules spell it book-keeper; we write bookkeeper except in names and quotations.

Key Takeaways

  • The duty to keep proper books under Rule 11 stays with the solicitor, even when someone else writes them up.
  • Engaging an outside bookkeeper under Rule 11(8) needs the Council’s written approval first, and a fresh application every year.
  • The bookkeeper must be independent (no employee or family link) and hold a listed qualification or enough law practice experience.
  • The bookkeeper undertakes to tell the Council if, for example, the client account cannot be reconciled in any month.
  • With a bookkeeper engaged under Rule 11(8), client account withdrawals of up to S$30,000 need only one solicitor’s signature.

Who can keep the books of a Singapore law practice?

Rule 11(1) requires every solicitor to “at all times keep properly written up in the English language” the cash books, ledgers and journals that show all dealings with client’s money and other money through a client account, and with conveyancing money through a conveyancing account. A practice can do this in two ways:

  • In-house, usually through its own accounts staff.
  • Through an outside bookkeeper engaged under Rule 11(8), “to keep his books and accounts properly written up and reconciled”, subject to Rule 11A. Under the Law Society’s Practice Direction 3.3.2, that bookkeeper can be an individual, an accounting firm, corporation or LLP, or another firm or company providing book-keeping services.

An individual engaged under Rule 11(8) must declare that he is not the solicitor’s employee, so in-house staff are a separate arrangement and the Rule 11A approval applies only to the outside route. Either way, the responsibility stays put: the Law Society’s Guide to Solicitors’ Accounts says it “falls on the solicitor himself”, shared by all partners (including salaried partners) in a partnership and by all directors in a law corporation. The annual accountant’s report on a practice’s compliance is a separate document, given by a public accountant under the Legal Profession (Accountant’s Report) Rules.

If you are weighing the two routes, our comparison of in-house and outsourced accounting sets out the trade-offs.

What does Rule 11A require?

Rule 11A(1) is short: “A solicitor shall not engage a book-keeper for the purposes of rule 11(8) unless he has obtained the written approval of the Council to do so.” The application must come with a statutory declaration from the bookkeeper’s side.

Type of bookkeeper Who signs the statutory declaration
An individual The bookkeeper personally
An accounting firm The sole proprietor or managing partner
An accounting corporation The managing director
An accounting LLP The manager
Another firm or company providing book-keeping services The sole proprietor, managing partner or managing director

Source: Legal Profession (Solicitors’ Accounts) Rules, rule 11A(2), current version, October 2026.

The declaration confirms independence: for example, that no proprietor or partner of an accounting firm is an immediate family member of the solicitor, meaning a spouse, child, adopted child, step-child, sibling or parent of the solicitor or of any partner or director of the practice (Rule 11A(11)). It states whether the person doing the work has completed the course the Council specifies, the Law Society’s Book-Keeping for Law Practices Course, with an undertaking to complete it within 12 months if not. It also contains the reporting undertakings described below.

How the application works

The Law Society sets out the steps:

  1. The sole proprietor, managing partner or a director of the practice who holds a current practising certificate makes the application.
  2. The bookkeeper signs the statutory declaration before a Commissioner for Oaths: BK Form 1 and SD1 for an individual or sole proprietorship, BK Form 2 and SD2 for a firm or company.
  3. The declaration exhibits an ACRA Bizfile profile dated within two months and certified true copies of qualification certificates. A lawyer from the applying practice cannot certify them.
  4. Practice Direction 3.3.2 asks for the declaration two weeks before the engagement.
  5. The engagement starts only after the Council’s written approval.
Rule 11A: from application to annual renewalFive steps: check eligibility; the bookkeeper’s statutory declaration; the practice’s application to the Council; written approval before the engagement starts; a fresh declaration every year within two weeks after the approval anniversary. Reporting duties apply throughout.Rule 11A: from application to annual renewalEngaging an outside bookkeeper for a Singapore law practice1Check eligibilityQualifications or law practice experience (PD 3.3.2), the LawSociety course, and no family or employment link with the practice2The bookkeeper signs a statutory declarationSworn before a Commissioner for Oaths, with a recent ACRA Bizfileprofile and certified copies of qualification certificates3The practice applies to the CouncilBy the sole proprietor, managing partner or a director, on BKForm 1 or BK Form 2, about two weeks before the engagement4Written approval, then the engagement startsRule 11A(1): no engagement under Rule 11(8) without theCouncil’s written approval5Every year after thatA fresh declaration no later than two weeks after eachanniversary of the approval (Rule 11A(10))Throughout: tell the Council at once if the client account cannotbe reconciled in any month, the books cannot be written up,or the practice does not answer the bookkeeper’s queriesSources: Solicitors’ Accounts Rules, rules 11(8) and 11A; Law Society PD 3.3.2.

Is the approval renewed every year?

Yes. Rule 11A(10) requires the bookkeeper to submit a statutory declaration every year, no later than two weeks after each anniversary of the Council’s approval. Practice Direction 3.3.2 puts it the same way: the declaration goes to the Council “on an annual basis and whenever there is a change of book-keeper”. Diarise the anniversary date on your approval letter.

What does the Law Society check?

Qualifications

Practice Direction 3.3.2, Part B, sets the qualifications for an individual bookkeeper, and for the person doing the work for a firm or company that is not an accounting firm, corporation or LLP:

Qualification Law practice experience also needed
London Chamber of Commerce and Industry At least 1 year writing up a law practice’s books and accounts
Association of Accounting Technicians At least 1 year
Certified Accounting Technician At least 1 year
A diploma in accounts from a polytechnic None stated
Passed ACCA level 2 None stated
A degree in accountancy None stated
None of the above At least 5 years writing up a law practice’s books and accounts

Source: Law Society of Singapore, Practice Direction 3.3.2, Part B.

For any type of bookkeeper, the Council can refuse approval if, in its opinion, the person who will do the work lacks the requisite qualifications or experience (Rule 11A(3)(a)).

Independence

The Council can also refuse if the bookkeeper, or a relevant person in a bookkeeping firm or company, is an immediate family member of the solicitor, or is unlikely to act independently of the solicitor (Rule 11A(3)).

Reporting

Under Rule 11A(8), the bookkeeper undertakes to tell the Council immediately if it cannot reconcile the client cash book with the bank statements for any client, conveyancing or conveyancing (CPF) account in any month; cannot properly write up the books; finds that client’s conveyancing money was received, held or withdrawn in breach of the rules; or cannot get the solicitor to answer the queries it needs answered. Trivial clerical errors fixed on discovery, with no loss to the client, are excluded (Rule 11A(9)). The Law Society’s declaration forms add an undertaking to report any client account withdrawal over S$30,000 made without a second signatory.

Why it matters for client account withdrawals

Rule 8(5) says no sum over S$5,000 may leave a client account unless two solicitors sign the cheque or instruction, or authorise the online digital payment. Rule 8(6) lifts this where the solicitor has engaged a bookkeeper under Rule 11(8) and the sum is S$30,000 or less. For a sole proprietor, that is a practical difference: otherwise every withdrawal over S$5,000 needs a second eligible solicitor, who must carry out the checks in the Law Society’s Practice Direction 3.3.10.

What should a law firm bookkeeper do for you?

Rule 11 sets the minimum, and the monthly routine should be built around it:

  • Keep client and office money apart in the books. A client cash book and a client ledger with a separate account for each client, a journal for transfers between clients, and nothing else recorded there (Rule 11(1) to (2B)).
  • Record every bill, with profit costs and disbursements shown separately (Rule 11(3)).
  • Reconcile every month. Rule 11(4) requires the client cash book to be reconciled with the client bank statements at least once a month, with the reconciliation statement kept on file.
  • Flag problems early. The Law Society’s guide notes that a client ledger in debit means other clients’ money has been used.
  • Keep records retrievable for at least six years, in a system that can print them within a reasonable time (Rule 11(5) and (6)), ready for any inspection the Council requires (Rule 12).
  • Handle the declarations on time, before the engagement and every year after.

In return, the practice must supply bank statements, bills and client instructions promptly: unanswered queries are themselves reportable under Rule 11A(8).

How to choose a bookkeeper for your law practice

  1. Check eligibility first. Approval is per engagement and per year, so check the qualifications, the course and the independence of the person who will do the work.
  2. Ask about the declarations. A bookkeeper who has been through Rule 11A before will know the forms, the Commissioner for Oaths step and the annual deadline.
  3. Test their knowledge of the rules. Ask how they would treat money on account of costs before a bill, a conveyancing float, or a client ledger in debit.
  4. Agree the timing. When each reconciliation will be ready, who reviews it, and how exceptions reach the partner responsible.
  5. Think about the wider work. Payroll, tax and annual accounts can sit with the same provider. Our guides on choosing an accounting firm and what accounting services cost can help you compare.

How Excellence Singapore Group can help

Our founder, Lucas Seah, is named on the Law Society of Singapore’s list of book-keepers, under Excellence Singapore Advisory Pte Ltd. As with any bookkeeper, a practice can engage us under Rule 11(8) only after the Council approves that engagement, renewed each year. Our accounting team can keep your client and office books written up and reconciled every month, and we also handle payroll and tax filings for the practice.

Frequently Asked Questions

Do law firms need approval to hire a bookkeeper?

Yes, if the bookkeeper is engaged under Rule 11(8) of the Legal Profession (Solicitors’ Accounts) Rules to keep the practice’s books written up and reconciled. Rule 11A requires the solicitor to obtain the written approval of the Council of the Law Society of Singapore before the engagement starts. A practice that writes up its own books through its own staff is not making a Rule 11(8) engagement.

How often must Rule 11A approval be renewed?

Every year. The bookkeeper must submit a statutory declaration to the Council no later than two weeks after each anniversary of the date the Council approved the engagement, and Practice Direction 3.3.2 also requires a fresh declaration whenever the practice changes bookkeeper.

Can a law firm employee be its Rule 11A bookkeeper?

No. An individual bookkeeper engaged under Rule 11(8) must declare that he is not an employee or an immediate family member of the solicitor. A practice can still have its own accounts staff write up its books, but that is not a Rule 11(8) engagement, so the single signature allowance in Rule 8(6) does not apply.

What qualifications does a law firm bookkeeper need?

Practice Direction 3.3.2 accepts a polytechnic diploma in accounts, ACCA level 2 or a degree in accountancy. London Chamber of Commerce and Industry, Association of Accounting Technicians and Certified Accounting Technician qualifications count with one year of law practice experience. Otherwise, five years of law practice experience is needed. The Law Society’s Book-Keeping for Law Practices Course must also be completed within 12 months of appointment, if not done before.

What does a law firm bookkeeper do each month?

Writes up the client cash book, the client ledger with a separate account for each client, and the journal; records every bill with profit costs and disbursements shown separately; and reconciles the client cash book with the client bank statements at least once a month under Rule 11(4), keeping the reconciliation statement on file. A client ledger in debit should be flagged at once, because it means other clients’ money has been used.

Can one solicitor sign withdrawals above S$5,000?

Only in one case. Rule 8(5) requires two solicitors to sign or authorise any client account withdrawal over S$5,000. Rule 8(6) lifts this where the solicitor has engaged a bookkeeper under Rule 11(8) and the sum does not exceed S$30,000.

Looking for a bookkeeper for your law practice?

Most of the work in Rule 11A happens before the engagement starts. If you are setting up a new practice, changing bookkeepers or catching up on your books, talk to us.

Lucas Seah, CEO & Founder, Excellence Singapore Group

CA (Singapore) · ASEAN CPA · Accredited Tax Practitioner (Income Tax & GST) · EMBA · CEI-Certified MOM-Registered Employment Agency Key Appointment Holder

Lucas founded Excellence Singapore in 2013 and has guided 4,000+ SMEs through incorporation, accounting, tax, corporate secretarial, work passes, trademark and intellectual property, and corporate finance matters. A Chartered Accountant (Singapore) and Accredited Tax Practitioner, he is also the MOM-registered, CEI-certified Key Appointment Holder for the group’s employment agency, which holds a Comprehensive Licence (All) under EA Licence 16C7944. He writes on Singapore business compliance, tax, immigration and corporate strategy.