Introduction
Singapore’s Employment Pass (“EP”) serves as a critical entry point for skilled professionals aiming to work in the country and potentially attain permanent residency. However, recent updates to the Ministry of Manpower (“MOM”) regulations have introduced more stringent criteria for EP applications and renewals, underscoring the necessity for applicants and employers to be well-informed and meticulously prepared.
Evolving Challenges in EP Applications
As of 1 January 2025, MOM has implemented significant changes to the EP framework to maintain a high-quality and complementary foreign workforce. These changes encompass both salary thresholds and a points-based assessment system known as the Complementarity Assessment Framework (“COMPASS”).
- Enhanced Qualifying Salary Requirements
The EP qualifying salary has been increased to align with the top one-third of local Professionals, Managers, Executives, and Technicians (“PMET”) salaries, varying by sector and age:
- General Sectors (excluding Financial Services Sector): The minimum qualifying salary is now S$5,600 per month (for applicants aged 23 or younger). This escalates progressively with age, up to S$10,700 per month (for applicants aged 45 and above).
- Financial Services Sector: Given higher wage norms, the minimum qualifying salary is now S$6,200 per month (for applicants aged 23 or younger). This escalates progressively with age, up to S$11,800 per month (for applicants aged 45 and above).
- Implementation of the COMPASS Framework
Beyond meeting the salary criteria, EP candidates must now pass COMPASS, a points- based system evaluating both individual and firm-related attributes to ensure a holistic assessment:
Individual Attributes:
- Salary (C1): Points are awarded based on how the candidate’s fixed monthly salary (assuming it already fulfils the EP qualifying salary) compares to local PMET salaries benchmarks in the relevant sector.
| Candidate’s fixed monthly salary compared to salary benchmarks by sector
(Must meet EP qualifying salary) |
COMPASS points |
| 90th percentile and above | 20 |
| 65th to less than 90th percentile | 10 |
| Below 65th percentile | 0 |
- Qualifications (C2): Recognised educational and professional qualifications contribute to the scoring. The general trend is that a degree or a degree- equivalent qualification is minimally required.
| Candidate’s qualifications | COMPASS points |
| Highly-recognised degree-equivalent (e.g. Singapore Autonomous Universities, Top 100 QS World-Ranked Universities, highly-recognised and agency-endorsed institutions in a particular field ) | 20 |
| Well-recognized degree-equivalent (e.g. foreign qualifications comparable to a bachelor’s degree in the UK system, professional qualifications that are well-recognised in the industry and agency-endorsed) | 10 |
| No degree equivalent | 0 |
Firm-Related Attributes:
- Diversity (C3): Assesses the firm’s workforce diversity by considering the candidate’s nationality relative to the organization’s existing PMET composition (assuming that there are at least 25 PMETs).
If there are less than 25 PMETs, 10 points are scored by default.
| Share of candidate’s nationality among firm’s PMETs | COMPASS points |
| There are fewer than 25 PMETs (regardless of nationality) in the firm | 10
Please disregard the rest of this table. |
| Less than 5% | 20 |
| 5% to less than 25% | 10 |
| 25% or more | 0 |
- Support for Local Employment (C4): Evaluates the firm’s commitment to nurturing local employment, reflected by the proportion of local PMETs within the organization (assuming that there are at least 25 PMETs).
If there are less than 25 PMETs, 10 points are scored by default.
If there are at least 25 PMETs and the local PMET share is at least 70%, at least 10 points will be scored. Scoring 20 points still depends on the percentile which the firm’s > 70% local PMET share stands in its sector.
| Firm’s local PMET share relative to sector | COMPASS points |
| There are fewer than 25 PMETs (regardless of nationality or sector) in the firm | 10
Please disregard the rest of this table. |
| There are at least 25 PMETs and > 70% local PMET share in the firm | At least 10
To score 20, please refer below. |
| 50th percentile and above | 20 |
| 20th to less than 50th percentile | 10 |
| Below 20th percentile | 0 |
Bonus Attributes:
- Shortage Occupation List (C5): Bonus points will go to candidates who are applying for jobs which require highly specialised skills that are in short supply. However, it must also be noted that this is partially influenced by the share of the candidate’s nationality within the firm.
| Skills bonus | COMPASS points |
| Candidate is applying for a job that is on MOM’s Shortage Occupation List and the share of the candidate’s nationality among the firm’s PMETs is less than one-third | 20 |
| Candidate s applying for a job that is on MOM’s Shortage Occupation List and the share of the candidate’s nationality among the firm’s PMETs is at least one-third | 10 |
- Strategic Economic Priorities (C6): A bonus of 10 points will go to firms that partner up with economic agencies to engage in ambitious investment, innovation and internation – alisation activities. Details on eligible programmes are available through MOM. The 10 bonus points (if confirmed by MOM) will last up to 3 years or the duration which the firm participates in the eligible programme (whichever is shorter).
To successfully obtain an EP, candidates must accumulate at least 40 points under COMPASS. Notably, candidates with a fixed monthly salary of S$22,500 or more are exempt from COMPASS, though their EP applications will still be subject to MOM’s approval.
Based on the COMPASS framework, it can be observed that clients who plan to start up new businesses (e.g. Single Family Office, operating companies etc.) in Singapore and apply EP for themselves would generally secure at least 20 points – 10 in C3 (Diversity) and 10 in C4 (Support for Local Employment) – due to the small size of a new business’s workforce. As such, the main hurdle is the remaining 20 points, to be scored through any of the remaining categories.
Other Noteworthy Challenge in EP Applications
- MOM Self-Assessment Too (“SAT”)
Besides the COMPASS framework, the SAT is another vital aspect of EP applications – an MOM online tool that can be used by firms or employment agents. By furnishing each EP candidate’s data (e.g. age, nationality, work experience, qualifications, salary, role, industry etc.), and utilising the COMPASS framework to assess both the candidate and the firm’s data, the SAT provides an indication of the candidate’s eligibility. According to MOM, should a SAT result indicate ineligibility, the EP application will be rejected; should a SAT result indicate eligibility, there is an approximately 90% chance of approval (though not guaranteed).
The key points to note with the SAT are:
- While the SAT can provide a helpful indication of how an EP application is likely to fare, it does not guarantee any outcome as this still depends on MOM’s discretion.
- A SAT result is dynamic, based on various factors unique to each EP candidate. While there are set guidelines (e.g. EP qualifying salary, COMPASS framework etc.) that are available for public reference, it is fairly common for a SAT result to indicate higher requirements to be met by a particular EP candidate – especially where salary is concerned – thus, there may be differences in COMPASS scores.
As such, where possible, EP candidates may consider getting their prospective employers or employment agents to generate a SAT beforehand.
- Additional documents requested by MOM during the EP application process
Even if an eligible EP candidate submits the EP application to MOM, MOM may on a case-by- case basis request for additional documents before processing the application and providing an outcome. Such additional checks are made to ensure that the EP application and its related work/business arrangements in Singapore are legitimate and premised on genuine commercial needs.
From past observations, such requested documents include but are not limited to:
- Employment agreements
- Business contracts / invoices / agreements signed with vendors / working partners
- Detailed list of employees
- Proof that the firm has the means to pay the EP candidate’s salary
- Proof of operating premises
- Financial statements
Should MOM impose such additional documentary requirements on a case-by-case basis, this may pose significant challenges, especially for clients who plan to start up new businesses in Singapore and apply EP for themselves. A conservative approach to consider would be to complete as much of the business set-up procedures as possible, before proceeding with the EP application.
Conclusion
The recent enhancements to Singapore’s EP framework reflect the nation’s commitment to fostering a high-calibre and diverse workforce. While these changes present additional challenges for applicants and employers, seeking professional guidance can significantly mitigate potential pitfalls. By leveraging expert insights and support, stakeholders can navigate the evolving landscape effectively, aligning with Singapore’s strategic vision for economic growth and talent development.
SMTP’s Experience
As a private client firm, SMTP has over the years assisted many clients to set up Single Family Offices and operating companies in Singapore, and successfully apply for their EPs thereafter. For Single Family Offices in particular, SMTP’s Immigration and Family Offices department possesses extensive experience in helping clients meet the S13O/U tax incentive award requirements, which involves EP applications (and renewals) for foreign investment professionals.
Our lawyers work closely with clients and their advisors, adopting a tailored approach to address families’ specific needs and requirements. Should clients face issues during their EP applications (and renewals), especially where additional documents are requested by MOM on a case-by-case basis, we leverage on our extensive resources to formulate a bespoke solution that addresses such issues.
Should you or your clients require any assistance or advice, please feel free to contact our Business Development Team to schedule a consultation.
