COMPASS: 2-Stage EP eligibility framework
MOM has applied a 2-stage eligibility framework to new EP applications from 1 September 2023, and will apply it to renewals of EPs expiring from 1 September 2024. However, an increasing number of employers in Singapore face difficulties when renewing the EPs of existing EP holders. Some of these existing EP holders no longer qualify for EPs due to the increased EP qualifying salary or due to the introduction of COMPASS.
1. Example 1: failing the EP qualifying salary requirement
Stage 1 of the EP eligibility framework requires the candidate to meet a qualifying salary requirement. For further guidance on this requirement, please see our alert: Singapore: Increase in Employment Pass application salary requirements.
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Scenario: ABC Singapore Branch applies for an EP for Jane Doe.
Jane Doe, an American national, was hired by ABC Singapore Branch in 2019 as a banking associate. Jane will be 30 years old in September 2024, and is paid a fixed monthly salary of SGD 7,000. Jane's EP was successfully renewed under the old MOM EP eligibility requirements in October 2021, and her EP will expire in September 2024. The two-stage EP eligibility framework will apply to the renewal of her EP.
Under the EP qualifying salary requirement, foreign candidates working in the financial services sector require a minimum fixed monthly salary of SGD 7,409 at age 30. Accordingly, the application for the renewal of Jane's EP will fail as it did not pass the first stage of the EP Eligibility Framework.
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2. Example 2: failing to earn 40 points on COMPASS
Stage 2 of the EP eligibility framework requires the candidate to pass COMPASS with at least 40 points from the four foundational criteria or by scoring points under the bonus criteria. For further guidance on COMPASS, please see our alert: Minister for Manpower introduces points-based rubric for EP applicants.
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Scenario: ABC Singapore Branch applies for an EP for John Doe.
John Doe, an American national, was hired by ABC Singapore Branch in 2019 as a Vice President. John will be 47 years old in October 2024, and is paid a fixed monthly salary of SGD 18,000. John's EP was successfully renewed under the old MOM EP eligibility requirements in November 2021, and his EP will expire in October 2024. The two-stage EP eligibility framework will apply to the renewal of his EP.
Under the EP qualifying salary requirement, foreign candidates working in the financial services sector require a minimum fixed monthly salary of SGD 11,500 at age 45 and above. Accordingly, the application for the renewal of John's EP satisfies the first stage of the EP Eligibility Framework.
Subsequently, the application did not earn enough points to pass COMPASS for the reasons below.
| Foundational criteria |
Attributes |
Points earned |
| C1: candidate's salary |
John's salary was above the 90th percentile compared to local Professionals, Managers, Executives and Technicians (PMET) salaries at age 45 or above. |
20 |
| C2: candidate's qualification |
John has no degree-equivalent qualifications. |
0 |
| C3: diversity |
John's nationality (i.e., American) is 26.3% of ABC Singapore Branch's PMETs. |
0 |
| C4: support for local employment |
ABC Singapore Branch's share of local PMETs is at the 25th percentile of its sector. |
10 |
| Bonus criteria |
Attributes |
Points earned |
| C5: skills bonus |
John's occupation is not on the Shortage Occupation List (SOL). |
0 |
| C6: Strategic Economic Priorities (SEP) bonus |
ABC Singapore Branch does not participate in any SEP programmes. |
0 |
| Total Score |
30 |
Accordingly, the application for the renewal of John's EP will fail as it did not pass the second stage of the EP Eligibility Framework.
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Considerations for renewal
Assuming that employers cannot significantly change their COMPASS scoring for C2 (candidate's qualification), C3 (diversity), and C4 (support for local employment), we suggest possible approaches that employers can take to enable their employees to continue working in Singapore.
- Salary increase
- Increase the base salary: employers may choose to increase the base salary of their employees to position these salaries at a higher percentile compared to local PMET salaries. However, this is not always feasible for reasons such as budget constraints.
- Reallocate variable salary component to base salary: if an employee generally attains their variable compensation targets, employers may re-organise a portion of the employee's variable salary under their base salary instead. This increases the employee's fixed monthly salary for the purposes of the EP eligibility framework, but does not add to the employer's overall cost.
- Bonus categories
- C5 – skills bonus: employers must work with employees in advance to confirm that their job duties fulfil the requirements under the SOL Guidebook.
- For example, firms hiring a cloud specialist (s/n 15 of the SOL Guidebook) should ensure that their candidates have a bachelor's degree in a relevant field of study and that they have at least three years of relevant work experience in the field.
- C6 – SEP bonus: employers must coordinate internally as a company to fulfil the programme criteria of an economic agency or the National Trade Union Congress (NTUC) under the eligible programmes for SEP bonus.
- For example, firms committed to working with NTUC to strengthen local workforce development through NTUC's Company Training Committees may qualify for NTUC's programme (s/n 15 of the eligible programmes for SEP bonus). However, companies may need to be prepared to have a close working relationship with NTUC or its trade unions, including entering into a collective agreement. We would be happy to advise further on matters pertaining to industrial relations.
- Change of pass type
- Encourage S Pass and EP holders to apply for Singapore Permanent Residency (PR) to reduce likelihood of pass renewal difficulties for these individual employees: the processing time for PR is generally six months, and the approval of PR is at the discretion of the Immigration & Checkpoints Authority (ICA). Some applicants may also have to reapply several times before their PR application is approved.
- Apply for an S Pass: EP holders who are not eligible to have their EP renewed may also apply for an S Pass. The company needs to have a sufficient S Pass quota.
- Apply for a Work Permit: for employers with insufficient S Pass quota, they may apply for a Work Permit instead if their employee is from Malaysia, the People's Republic of China (PRC), Hong Kong SAR, Macau SAR, South Korea or Taiwan. If the company has any S Pass holders from Malaysia, PRC, Hong Kong SAR, Macau SAR, South Korea or Taiwan, employers may consider applying for a Work Permit for the S Pass holder instead, to allow an existing EP holder to use the S Pass quota. However, employers must note that Work Permit holders are not eligible to apply for PR, and that there are several other restrictions such as not getting pregnant or delivering a child in Singapore during the validity of their Work Permit unless they are already married to a Singapore citizen or permanent resident with MOM's approval.
- Apply for a Dependant's Pass (DP): for a foreign employee married to another EP or S Pass holder, the spouse's company may apply for a DP for the foreign employee. Once the foreign employee becomes a DP holder, the foreign employee's employer can subsequently apply for a Work Permit for the DP holder, provided that the company has sufficient Work Permit quota. DP holders who apply for Work Permits can be of any nationality. They are also not subject to medical examination, security bond, or pregnancy restrictions.
- We would be happy to advise further on managing employee concerns or workforce turnover considerations when changing their pass types.
Preparing for your renewal of EPs
To avoid disruptions, we encourage employers to plan ahead and review internal compensation and mobility guidelines to ensure that the renewal of their employees' EPs will progress as smoothly as possible. We also suggest that clients use the MOM's Self-Assessment Tool to evaluate, in advance of existing EP expiry dates, whether current foreign employees will continue to qualify for EPs. We would be happy to advise further on how to manage anticipated challenges.
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