The Fair Consideration Framework in Singapore is the set of rules from the Ministry of Manpower (MOM) that requires employers to consider Singaporeans fairly before hiring foreigners on an Employment Pass (EP) or S Pass. In short: before most EP or S Pass applications and renewals, the firm must advertise the role on MyCareersFuture for at least 14 consecutive days and genuinely review local candidates who apply.
The framework, usually shortened to FCF, pairs this job advertising duty with the Tripartite Guidelines on Fair Employment Practices, an FCF watchlist for firms that show discriminatory hiring patterns, and the COMPASS points system for EP assessment. This guide explains what the FCF covers, who is exempt, how it connects to COMPASS, and what is changing with the Workplace Fairness Act, all drawn from MOM.
Key Takeaways
- Core duty: employers must fairly consider Singaporeans before hiring EP or S Pass holders, and usually must advertise the job on MyCareersFuture first.
- Advertising rule: the listing must run on MyCareersFuture for at least 14 consecutive days before the firm applies for or renews an EP or S Pass.
- Exemptions: firms with fewer than 10 employees, jobs paying a fixed monthly salary of $22,500 or more (since 1 September 2023), and intra-corporate transferees are exempt from advertising.
- Watchlist: MOM places firms with signs of discriminatory or non-merit hiring on the FCF watchlist for closer scrutiny, and can curtail their work pass privileges.
- What is changing: the Workplace Fairness Act, passed in 2025, is expected to take effect around the end of 2027 and will give discrimination protections the force of law for employers with 25 or more staff.
What the Fair Consideration Framework Is
MOM introduced the Fair Consideration Framework to make sure local professionals, managers, executives and technicians (PMETs) get a fair shot at jobs before those roles go to foreigners. It does not stop firms from hiring from overseas; it requires them to open the role to Singaporeans first and to hire on merit, not on nationality, age, sex or race.
The FCF has two halves that work together. The first is a hard process rule: most EP and S Pass roles must be advertised on the national jobs portal, MyCareersFuture, before the work pass is applied for or renewed. The second is a fair-employment standard, set out in the Tripartite Guidelines on Fair Employment Practices, that applies to every employer in Singapore regardless of pass type.
Why It Matters for EP and S Pass Hiring
If a firm skips the advertising step when it is required, or cannot show it considered local applicants fairly, MOM can reject or refuse to renew the work pass. The framework therefore sits at the front of the work pass application process, before MOM even scores an Employment Pass candidate under COMPASS.
The MyCareersFuture Advertising Requirement
The most concrete FCF duty is job advertising. Before submitting or renewing most EP and S Pass applications, the employer must post the role on MyCareersFuture and keep it open for a minimum period so that local jobseekers can apply and be considered.
- Where: the role must be advertised on MyCareersFuture, the government jobs portal run for the local workforce.
- How long: the advertisement must stay open for at least 14 consecutive days before the firm applies for or renews the EP or S Pass.
- Fair review: the employer must genuinely consider every candidate who applies, including Singaporeans, on merit rather than on nationality or other non-job factors.
- Records: firms should keep evidence of how they assessed local applicants, since MOM can ask for it.
The advertising rule is a prerequisite, not a points-scoring exercise. Meeting it does not guarantee the pass; the candidate still has to clear the EP qualifying salary and the COMPASS points test. But failing to advertise when required can sink an otherwise eligible application.
FCF Advertising Exemptions
Not every role has to be advertised. MOM exempts categories where open advertising would not be practical or where the local workforce is unlikely to be displaced. Even where an exemption applies, MOM still encourages firms to advertise and reminds them that fair-consideration duties continue to apply.
| FCF requirement | Detail | Exemption |
|---|---|---|
| Advertise on MyCareersFuture | List the EP or S Pass role on the national portal before applying or renewing | Firms with fewer than 10 employees are exempt from advertising |
| Keep the advertisement open 14 days | The listing must run for at least 14 consecutive days | Jobs paying a fixed monthly salary of $22,500 or more are exempt (since 1 September 2023) |
| Fairly consider local applicants | Review Singaporeans and other candidates on merit | Intra-corporate transferees (ICT) under Singapore's WTO commitments are exempt from advertising |
| Apply or renew the work pass | Submit the EP or S Pass after the advertising window | Exemption claims must still be supported, and fair-employment standards still apply |
How the $22,500 Salary Exemption Works
MOM exempts roles with a fixed monthly salary of $22,500 or more because, per its own explanation, these tend to be senior management, C-suite or specialist positions that are comparable to the top 10% of EP holders and are not typically filled through open advertising. This threshold took effect on 1 September 2023. Firms claiming any exemption must still be ready to justify it in the application.
Small Firms and Transferees
Companies with fewer than 10 employees are exempt from the advertising step, as are intra-corporate transferees who move within the same group of companies. For an ICT, the employee usually has to have worked for the company outside Singapore for at least one year and hold a manager, executive or specialist role. The exemption only removes the advertising step; the EP or S Pass still has to meet the other eligibility rules.
How the FCF Connects to COMPASS
For Employment Pass applications, the FCF and COMPASS are two separate gates that a firm must clear in order. The FCF advertising rule comes first: advertise on MyCareersFuture (unless exempt) and consider locals fairly. Only then does MOM assess the candidate under COMPASS, the Complementarity Assessment Framework, which scores the application on points.
COMPASS rewards firms that support local employment through one of its criteria, so a workplace that hires and retains Singaporean PMETs tends to score better. In that sense the FCF and COMPASS push in the same direction: both reward firms that build a fair, locally anchored workforce rather than relying on foreign hiring.
Two Gates, Not One
It helps to picture EP approval as a sequence. First, the FCF process check: was the role advertised and were locals fairly considered, or is the role exempt? Second, the COMPASS points check: does the candidate clear 40 points and the qualifying salary? For a deeper look at the points test, see our guide to the EP COMPASS framework and the Employment Pass salary threshold.
The FCF Watchlist and Enforcement
MOM actively monitors for signs of discriminatory or non-merit hiring. Firms that show suspect recruitment patterns, such as repeatedly favouring foreigners over comparable locals, can be placed on the FCF watchlist for closer scrutiny of their work pass applications. Being on the watchlist can mean slower processing, more questions, and in serious cases, curbs on hiring or renewing foreign workers.
Enforcement also reaches individual breaches. Since January 2020, the minimum work pass debarment for firms that breach fair-consideration rules rose to 12 months, up to a maximum of 24 months, and debarment now covers both new applications and renewals. Making a false declaration in a work pass application is an offence that can draw a fine of up to $20,000, imprisonment of up to two years, or both.
Tripartite Guidelines on Fair Employment Practices
Underpinning the FCF are the Tripartite Guidelines on Fair Employment Practices, agreed by the government, employers and unions. They set out that hiring and management decisions should be based on merit and not on age, race, gender, religion, nationality, marital status, family responsibilities or disability. The Tripartite Alliance for Fair and Progressive Employment Practices (TAFEP) handles complaints, and MOM can act against firms that ignore the guidelines.
What FCF Means for EP Applicants and Employers
For an EP or S Pass candidate, the FCF mostly plays out behind the scenes through the employer. There is little a candidate can do to satisfy it directly, but it pays to confirm with the hiring firm that the role was advertised or is properly exempt, since a process slip can delay or derail the pass.
For employers, the FCF is a compliance checklist to run before every non-exempt EP or S Pass submission. Catalyst Immigration helps firms confirm whether a role needs advertising, run a defensible MyCareersFuture posting, and document the fair consideration of local applicants.
- Check whether the role is exempt (fewer than 10 staff, salary of $22,500 or more, or an intra-corporate transfer).
- If not exempt, advertise on MyCareersFuture and keep the listing open for at least 14 consecutive days.
- Fairly review every applicant, including Singaporeans, and keep records of how candidates were assessed.
- Only then submit or renew the EP or S Pass, and proceed to the COMPASS assessment for EP roles.
What Is Changing: The Workplace Fairness Act
The fair-employment rules behind the FCF are moving from guidelines toward law. Singapore's Workplace Fairness Act was passed in 2025 and is expected to take effect around the end of 2027. It will prohibit discrimination on protected grounds such as age, nationality, sex, race, religion and disability, and will apply to employers with 25 or more employees, with the threshold to be reviewed within five years. Firms hiring under the FCF should expect fair-employment duties to carry legal weight, not just reputational risk, once the Act commences.
Frequently Asked Questions About the Fair Consideration Framework in Singapore
What is the Fair Consideration Framework in Singapore?
The Fair Consideration Framework (FCF) is MOM's set of rules requiring employers to consider Singaporeans fairly before hiring foreigners on an Employment Pass or S Pass. In most cases the firm must first advertise the role on MyCareersFuture and genuinely review local applicants.
How long must a job be advertised under the FCF?
The advertisement must run on MyCareersFuture for at least 14 consecutive days before the employer applies for or renews an Employment Pass or S Pass. The firm must also fairly consider every candidate who applies during that period.
Which jobs are exempt from the FCF advertising requirement?
Firms with fewer than 10 employees, jobs paying a fixed monthly salary of $22,500 or more (since 1 September 2023), and intra-corporate transferees are exempt from advertising. Even when exempt, employers must still uphold fair employment practices.
How does the FCF relate to COMPASS?
They are two separate gates for Employment Pass applications. The FCF advertising rule comes first, then MOM scores the candidate under COMPASS. A firm that supports local employment tends to do better on both.
What happens if an employer breaches the FCF?
MOM can place the firm on the FCF watchlist for closer scrutiny and curb its work pass privileges. Since January 2020, debarment runs from 12 to 24 months, and a false declaration can draw a fine of up to $20,000, jail of up to two years, or both.
Is the FCF becoming law?
The fair-employment standards behind the FCF are being put into statute through the Workplace Fairness Act, passed in 2025 and expected to take effect around the end of 2027. It will apply to employers with 25 or more employees and ban discrimination on protected grounds.
Official Sources and References
- MOM - Fair Consideration Framework
- MOM - Why jobs paying $22,500 and above are exempt from advertising
- MOM - ICT exemption from the advertising requirement
- MOM - Employment Pass eligibility and COMPASS
Explore Catalyst Immigration’s other services:
- EP COMPASS Framework in Singapore
- Employment Pass and Work Visa
- Employment Pass Salary Threshold
- Work Pass Application
- Switching Jobs on an Employment Pass
Talk to Catalyst Immigration
Catalyst Immigration helps employers run the Fair Consideration Framework correctly before every EP or S Pass submission, from checking exemptions to running a defensible MyCareersFuture advertisement and documenting fair consideration of local applicants. We then guide the full work pass application through COMPASS so you submit with confidence.