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As a globally renowned hub for business and international talent, Singapore’s work pass regulations directly impact the sustainable operation and long-term development of companies. This article outlines 10 key work pass compliance issues frequently raised by employers, based on the latest 2025 updates from the Ministry of Manpower (MOM), to help businesses navigate policy changes and avoid compliance risks effectively.

1. Q: Can an Employment Pass (EP) holder be a shareholder of a Singapore-registered company?
   A: Yes, an EP holder is allowed to own shares in a Singapore-registered company.

2. Q: Can an EP holder be appointed as a director of another company that is not their primary employer?
   A: Yes, but the EP holder must obtain a Letter of Consent (LOC) from MOM.
   MOM generally permits EP holders to take up such secondary directorships through the issuance of a LOC.
   If the directorship is for an unrelated entity, the application may be assessed by the relevant sector lead agency. If the agency supports the application, MOM may grant the LOC.

3. Q: Can an EP be transferred to a subsidiary company without a new application?
   A: No. The subsidiary must submit a new EP application for the individual. EPs are tied to specific employers.

4. Q: Is a work pass required if a foreigner is appointed as a director of a Singapore company but does not reside in Singapore?
   A: No. Foreigners who are not based in Singapore (e.g., social visit pass holders) may be registered as directors of a Singapore company without holding an EP.

5. Q: What are the qualifying salary requirements for EP holders in the financial services sector from 2025 onwards?
   A:

New applications (from 1 January 2025):

• • Financial services sector: Minimum fixed monthly salary of S$6,200, increasing progressively with age, up to S$11,800 for candidates aged 45 and above.
  • All other sectors: Minimum of S$5,600, increasing with age to S$10,700 for older candidates.

Renewals:

• • For passes expiring in 2025:
    • Financial sector: Minimum S$5,500 (up to S$11,500 for age 45 and above)
    • Other sectors: Minimum S$5,000 (up to S$10,500 for age 45 and above)
  • For passes expiring from 1 January 2026: New application criteria will apply to renewals as well.

6. Q: Can an employer refuse to cancel an EP, S Pass, or Work Permit?
   A: No. Employees have the right to resign at any time with due notice or payment in lieu.
   As work passes are issued for the purpose of employment, employers are required to cancel the pass within one week after the employment ends.

7. Q: Must the employer pay for repatriation costs when an EP or S Pass holder leaves the company?
   A: Yes. Employers must bear the full cost of employing foreign workers, including repatriation expenses. This includes:

1. 1. A one-way air ticket to the worker’s home country or region;
   2. Pre-departure COVID-19 testing (if required);
   3. Transit transport costs (if applicable).

Unless the employee has explicitly agreed in writing to bear these costs, the employer remains responsible.

8. Q: Can the Foreign Worker Levy (FWL) be passed on to foreign employees?
   A: No. The FWL is a pricing mechanism to regulate the number of foreign workers in Singapore. Employers benefit from hiring foreign manpower and are responsible for paying the levy.

Under the Employment of Foreign Manpower Act (EFMA), employers are prohibited from recovering the levy or any employment-related costs from their employees. MOM will take enforcement action against non-compliant employers, which may include fines, imprisonment, or debarment from hiring foreign workers.

9. Q: If my employee switches from an EP to a Personalised Employment Pass (PEP), do I need to cancel their EP?
   A: Yes. Once the PEP is approved, the existing EP must be cancelled. The employee will need to present the EP cancellation letter from the company when collecting the PEP.

You may continue to employ the individual as you would a Singapore citizen or Permanent Resident (PR). You simply need to notify MOM that the individual is now employed under a PEP.
Note: The PEP is tied to the individual and not to an employer, so the cancellation of the previous EP is necessary to maintain compliance in the pass system.

10. Q: I’m a newly approved EntrePass holder. Can I begin working if I haven’t registered my company yet?
    A: Yes. You are allowed to carry out activities related to setting up your business, including but not limited to:

1. 1. Registering the company and securing necessary licenses and approvals;
   2. Conducting market research, participating in networking or fundraising activities, signing commercial agreements or letters of intent;
   3. Sourcing for office space and hiring employees.

Conclusion
If you have any questions regarding work pass applications in Singapore, feel free to contact us. Our team of experts will provide personalised guidance to support your company’s growth and compliance as you expand in Singapore.