Short answer: A liquidator’s fees are not set by the liquidator alone. Depending on the type of winding up, they are fixed by the committee of inspection, by creditors or members, or by the court. Members holding 10% of the capital, and in voluntary winding ups any member or creditor, can ask the court to review the amount.

Searches for liquidator fees Singapore usually come from a creditor, shareholder or director who has just received a fee notice or a meeting invitation and wants to know whether the figure can be questioned. The answer depends on how the liquidator was appointed, because the Insolvency, Restructuring and Dissolution Act 2018 (IRDA) gives different bodies the power to approve remuneration and gives different people the right to go to court. This guide sets out who fixes the fees, what the practitioner must disclose, and how a review works.

Key facts at a glance

  • In a court winding up, a liquidator other than the Official Receiver is paid as agreed with the committee of inspection, failing which as resolved by creditors (at least 75% in value and 50% in number of those present and voting), failing which as determined by the court (IRDA section 139(3)).
  • In a creditors’ voluntary winding up, the committee of inspection or, if there is none, the creditors fix the remuneration (section 167(3)). In a members’ voluntary winding up, the company in general meeting may fix it (section 164(1)).
  • In a court winding up, members holding at least 10% of the issued capital (excluding treasury shares) may ask the court to confirm or vary the fee determination (section 139(5) and (6)).
  • In a voluntary winding up, any member, creditor or the liquidator may apply to the court at any time before dissolution to review the remuneration, and the court’s decision is final and conclusive (section 175).
  • A licensed practitioner claiming remuneration must give disclosure detailed enough for the approving body to judge whether the fees are reasonable and valid (Ministry of Law licence condition 27).
  • The High Court has said remuneration must be fair, reasonable and proportionate (Kao Chai-Chau Linda v Fong Wai Lyn Carolyn [2015] SGHC 260).

Who fixes liquidator fees Singapore companies are charged, in each type of winding up?

It depends on the route into liquidation. The Act names a different approving body for court-ordered, creditors’ voluntary and members’ voluntary winding ups, and the right to challenge follows the same split.

Type of winding up Who fixes the remuneration Who can ask the court to review
Court-ordered winding up (private liquidator) In order: agreement with the committee of inspection, if any; failing that, a creditors’ resolution (75% in value and 50% in number of those present and voting); failing that, the court (section 139(3)) Where the committee agreed it: members holding at least 10% of issued capital. Where creditors resolved it: the liquidator or those members (section 139(5), (6))
Provisional liquidator (other than the Official Receiver) The court (section 139(2)) The court has already set it
Official Receiver as liquidator As prescribed, subject to any court order (section 139(7)) Subject to any order of the court
Creditors’ voluntary winding up The committee of inspection or, if none, the creditors (section 167(3)) Any member, creditor or the liquidator, at any time before dissolution (section 175)
Members’ voluntary winding up The company in general meeting (section 164(1)) Any member, creditor or the liquidator, at any time before dissolution (section 175)

We read these provisions on Singapore Statutes Online as they appear in the 2020 Revised Edition. Check the current text there before relying on a section number, because the Act is amended from time to time.

What does the Act say about how a creditors’ meeting votes on fees?

In a court winding up where there is no agreement with a committee, the liquidator must call a meeting of creditors by notice to each creditor. The notice must attach a statement of all receipts and expenditure and the amount of remuneration sought (section 139(4)).

That attachment is the creditor’s first tool. Before the meeting, compare the amount sought against the receipts and expenditure statement and ask for anything that is unclear. The resolution needs a majority of at least 75% in value and 50% in number of the creditors present and voting, in person or by proxy, whose debts have been admitted for voting. Voting mechanics are covered in our guide to the creditors’ meeting, proxies and the committee of inspection.

What must a liquidator disclose before fees are approved?

A licensed practitioner must tell the client in writing the terms and the basis of fees before accepting an appointment, and must give enough detail later for the approving body to judge the claim. Both duties come from the Ministry of Law’s licence conditions.

  • Before accepting an appointment, the practitioner must inform potential clients in writing of the material terms, including the type of work involved, the basis on which fees will be charged (for example time-cost or commission) and which services those fees cover (condition 23).
  • A practitioner claiming remuneration must give “sufficiently detailed, meaningful, open and clear disclosure” to the persons authorised by the IRDA to approve it, so that they can understand the nature, quantity and relevance of the work done and decide whether the proposed remuneration is reasonable and valid (condition 27).
  • Past and existing business interests that may affect independence must be disclosed to the client and to creditors, including the committee of inspection, with consent obtained to act (condition 21). A new conflict during the appointment must be disclosed as soon as reasonably practicable (condition 22).
  • A licensee must not accept or pay referral fees unless safeguards protect independence, and disclosing the arrangement is one such safeguard (conditions 24 to 26).

The full text is in the Ministry of Law’s General Licence Conditions. Our guide to choosing a licensed insolvency practitioner explains how to compare engagement terms before an appointment.

How does the court decide whether the fees are reasonable?

The High Court has held that remuneration must be fair, reasonable and proportionate, read together rather than separately. It must be commensurate with the nature, complexity and extent of the work, and not out of proportion to the value of the estate.

The leading discussion is in Kao Chai-Chau Linda v Fong Wai Lyn Carolyn and others [2015] SGHC 260, a case about court-appointed receivers and managers. The judge spoke of insolvency practitioners generally and borrowed a list of factors from English practice. We summarise the points a reviewing court looks at.

Factor What it asks
Time given The time properly given by the practitioner and the staff to the matter
Complexity How complicated the engagement was
Exceptional responsibility Any responsibility of an exceptional kind or degree that fell on the practitioner
Effectiveness How effectively the duties appear to have been carried out
Value and nature of the subject matter What the estate is worth and what kind of assets or issues are involved

The Court also said that its role is to consider matters of principle, such as flaws in the methodology of a bill or incorrect premises, rather than to examine every line. It added that the court’s inquiry is not confined to the points an objector has raised, so the absence of objectors does not remove the court’s duty to scrutinise. The same judgment set out a proposed “costs schedule” for court-appointed practitioners, listing the work expected, the time each category will take, the team, the basis of remuneration, hourly rates, a fee estimate, expected disbursements and whether other professionals such as lawyers are engaged. Whether a practitioner follows that format in your case is a matter to raise with your law firm, as we have not confirmed how it is applied today.

How do you challenge a liquidator’s fees, step by step?

Start with documents and the approving body, and go to court only when that route is open and the numbers justify the cost. The steps below are a general order of work, not advice on your matter.

  1. Identify the type of winding up from the notice or Bizfile, because that decides who approves the fees and who may apply to court.
  2. Ask the liquidator in writing for the engagement terms, the fee basis, a breakdown of work done by task and grade of staff, and the statement of receipts and expenditure.
  3. Compare the claim with the disclosure standard in licence condition 27 and with the factors above, and note anything vague, duplicated or out of proportion to the assets recovered.
  4. If there is a committee of inspection, raise your concerns with its members before they agree the fees. See our guide to the committee of inspection.
  5. If creditors are voting, attend or send a proxy and vote against an amount you cannot justify. A resolution needs 75% in value and 50% in number of those present and voting.
  6. If you are a member with at least 10% of the issued capital in a court winding up, or any member or creditor in a voluntary winding up, instruct a Singapore Advocate and Solicitor to prepare an application for the court to review the remuneration.
  7. Diarise the cut-off: in a voluntary winding up, a section 175 application must be made before the company is dissolved.

Proceedings are conducted by a Singapore Advocate and Solicitor. If you are weighing an application, speak to a law firm early, because the right to apply depends on the type of winding up and your standing in it.

Can a creditor apply to court if the winding up is by the court?

Under the text we read, the express right to ask the court to confirm or vary a fee determination in a court winding up belongs to the liquidator (where creditors fixed the fees) and to members holding at least 10% of the issued capital. An individual creditor is not named in section 139(5) or (6).

That does not leave creditors without options. Creditors vote at the meeting under section 139(3)(b), and a creditor or contributory may complain to the Official Receiver, who must inquire into a complaint about the liquidator’s conduct and take such action as the Official Receiver thinks expedient (section 137). Where the liquidator seems unfit to continue, our guide to removing a liquidator covers the separate court power. Section 175, with its wider right for any member or creditor, sits in the part of the Act dealing with voluntary winding up, so ask your solicitor whether any other route applies to your court winding up.

What can you do about the practitioner’s conduct, apart from the amount?

You can complain to the Licensing Officer at the Ministry of Law, which accepts an Insolvency Practitioners Complaints Form with supporting documents. This addresses improper conduct, not the quantum of fees, and it does not replace a court review.

The Ministry’s page on filing a complaint against an insolvency practitioner explains how to submit one. Typical grounds are a failure to disclose a conflict (conditions 21 and 22), inadequate fee disclosure (condition 27) or a lack of diligence. The Ministry’s register also lets you check that the practitioner is licensed before you write.

What do directors and the company secretary supply to the liquidator?

The liquidator needs accurate records to do the work, and poor records push the time-cost up. The company secretary or corporate service provider can reduce avoidable cost by preparing what the liquidator will ask for.

  • The statutory registers, minute books and constitution.
  • Annual returns, financial statements and tax filings, with the latest management accounts.
  • Lists of creditors, debtors, employees, bank accounts and contracts.
  • Director and shareholder loan balances, with supporting agreements.
  • Access details for the accounting system, bank portals and any Bizfile and CorpPass authorisations.

Disorganised records mean more hours spent reconstructing the position, and the order in which debts are paid means the liquidator’s costs come out of the estate before creditors are paid. Our guide to the priority of debts in a liquidation shows why that matters to recoveries. For the liquidator’s own duties, see powers and duties of a liquidator.

Frequently asked questions

Who decides how much a liquidator is paid in Singapore?

It depends on the winding up. In a court winding up it is the committee of inspection, then creditors, then the court (section 139(3)). In a creditors’ voluntary winding up it is the committee of inspection or the creditors (section 167(3)), and in a members’ voluntary winding up it is the company in general meeting (section 164(1)).

Can shareholders challenge a liquidator’s fees?

In a court winding up, members holding at least 10% of the issued capital (excluding treasury shares) may apply for the court to confirm or vary the determination (section 139(5) and (6)). In a voluntary winding up, any member may apply to review the remuneration (section 175).

Until when can I apply for a review in a voluntary winding up?

Section 175 allows an application at any time before the dissolution of the company. The court’s decision is stated to be final and conclusive, so prepare the application carefully.

Does the liquidator have to explain the fees?

Yes, in the sense that licence condition 27 requires disclosure detailed enough for the approving persons to understand the work done and decide whether the remuneration is reasonable and valid. A bare total with no breakdown is a reason to ask for more.

Can I report a liquidator who overcharges?

You can send an Insolvency Practitioners Complaints Form with supporting documents to the Licensing Officer at the Ministry of Law. In a court winding up, a creditor or contributory may also complain to the Official Receiver (section 137).

Need help with this?

Our team at Raffles Corporate Services can prepare the resolutions, registers and ACRA filings, and where court proceedings or legal advice are needed, we work with a panel of experienced Singapore law firms who offer cost-effective and efficient legal service and advice.

Email: [email protected]
Call, SMS or WhatsApp: +65 8501 7133

Last reviewed: 7 November 2026. The Editorial Team, Raffles Corporate Services.