Starting a new company in Singapore is a straightforward and business-friendly process. However, when it comes to hiring foreign professionals—especially when the company is newly incorporated—obtaining an Employment Pass (EP) becomes significantly more challenging. MOM (Ministry of Manpower) applies much stricter scrutiny to new companies because they lack historical financial track records, operational evidence, and established hiring patterns.

Many EP applications from new companies get rejected simply because employers are unaware of MOM’s expectations and therefore submit incomplete, weak, or poorly justified applications.

This article highlights the most common mistakes new companies make when applying for an EP and provides practical insights on how to avoid these pitfalls.

1. Applying for an EP Too Soon After Incorporation

One of the biggest mistakes new companies make is submitting an EP application immediately after incorporation, without first building operational credibility.

Why this is a mistake:

The company has no business activity
No website, marketing materials, or branding yet
No clients or pipeline
No proof of financial strength
No operational structure

To MOM, this raises suspicion that the company was formed just to obtain an EP for the individual, instead of being a real commercial business.

How to avoid:

Before applying, ensure your company has:

✔ A professional website
✔ Marketing materials
✔ A business plan
✔ Sales leads or discussions
✔ Operational structure
✔ Paid-up capital that reflects seriousness

Even 3–8 weeks of preparation significantly improves EP approval chances.

2. Setting an Unrealistically Low Paid-Up Capital

Technically, a Singapore company can be incorporated with S$1 paid-up capital, but submitting an EP application with such low capital is almost guaranteed to be rejected.

Why this is a mistake:

Paid-up capital reflects the company’s:

Financial commitment
Ability to pay salaries
Ability to support business operations
Ability to scale and hire locals

Low capital suggests that the company is not serious and is financially incapable.

Recommended paid-up capital for strong EP cases:

Minimum required: S$1
Minimum advisable: S$20,000
Good range: S$50,000–S$100,000

Injecting sufficient capital is one of the easiest ways to improve EP success.

3. Weak or Generic Job Description

This is one of the most common reasons EPs get rejected.

New companies often submit job scopes that are:

Too short
Generic
Not aligned with the applicant’s experience
Not technical or strategic
Easily filled by locals

Examples of weak job scopes:

“Handle sales and marketing tasks”
“Manage daily operations”
“Assist in business development”

These descriptions do not justify why a foreign professional is required.

How to avoid:

Craft a specific, detailed, strategically important job scope that clearly shows:

Specialist or technical responsibilities
Seniority and leadership
Regional duties
Skills not commonly found locally

A strong job description greatly increases EP approval chances.

4. Offering a Salary That Doesn’t Match Seniority or Market Rates

Salary is a major factor under the COMPASS scoring framework. New companies often make salary mistakes such as:

❌ Too low for the applicant’s age

A 40-year-old applying with S$6,000 is almost always rejected.

❌ Too low for the job scope

A “Regional Director” earning S$7,000 is not credible.

❌ Too low for the industry

Finance, tech, and engineering roles require higher salaries.

General salary guidelines for EP:

Young PMETs: S$5,600–S$7,000
Mid-career: S$8,000–S$12,000
Senior professionals: S$12,000–S$18,000
Director-level: S$15,000+

Solution:

Benchmark salary using MOM tools and offer a figure that reflects:

Experience
Seniority
Industry norms

Salary is one of the strongest ways to boost COMPASS scoring.

5. Submitting an EP Without a Business Plan

Many new companies submit EP applications without including a business plan. This is a costly mistake.

Why it matters:

MOM wants to know:

What your business does
How it will make money
Why the foreign applicant is essential
What economic contribution the business provides
Whether the company is viable

Without a business plan, MOM has no visibility into the company’s intentions.

A strong business plan includes:

Company overview
Products/services
Market analysis
Business model and revenue plan
Operational plan
Financial projections
Hiring plans (especially local staff)
Justification for hiring the foreigner

A good business plan is often the deciding factor for EP approval for new companies.

6. Lack of Proof of Business Activity

New companies often assume that being newly incorporated is enough. Unfortunately, MOM expects more.

Lack of activity includes:

No website
No customers or leads
No marketing presence
No branding
No suppliers or partnerships
No actual work performed

How to fix this:

Provide:

Sales pipeline documents
Letters of intent from clients
Supplier or partner agreements
Website screenshots
Brochures/marketing decks
Draft contracts
Email correspondences with prospects

Even early-stage activity strengthens credibility.

7. Applicant’s Experience Does Not Match the Job Role

MOM checks whether the applicant’s experience directly aligns with the proposed job.

EP rejection examples:

Sales background → hired as “IT Specialist”
Hospitality graduate → hired as “Marketing Manager”
Fresh graduate → proposed as “Director of Operations”

New companies often make this mistake by giving applicants inflated or mismatched roles.

How to avoid:

Ensure the job role:

Is consistent with applicant’s background
Shows logical career progression
Matches qualifications and certifications

8. Hiring a Foreigner for a Role Easily Filled by Locals

Certain roles face extra scrutiny, especially in new companies.

High-risk roles include:

Sales
Marketing
Administrative work
HR
Business development
Customer service

These roles have many local applicants, so MOM will ask:

Why can’t this role be filled by a local?
What specialised skills does the applicant bring?

Solution:

If applying for such roles:

Emphasise regional experience
Emphasise specialised knowledge or language skills
Provide clear justification

9. Poor Company Compliance or Missing Documents

New companies sometimes rush the EP application and forget essential paperwork.

Common missing documents:

Applicant’s transcripts or certificates
Detailed CV
Contracts with clients
Paid-up capital evidence
Business plan
Job advertisement under FCF (where applicable)
Organisation chart

This makes MOM think the company is unprepared or non-operational.

10. Poorly Written or Unprofessional EP Submission

Presentation matters.
A sloppy submission gives MOM the impression that the company is not serious.

Common issues:

Poor English
Inconsistent job scope
Contradictions between documents
Missing details
Unclear explanations
Lack of structure in appeal letters

A well-organised, professional EP submission stands out positively.

11. Overestimating the Role of Nominee Directors

Some new companies assume that hiring a nominee director alone strengthens EP. It does not.

MOM knows that nominee directors:

Do not participate in real operations
Are hired purely for compliance
Cannot justify business activity

The EP approval depends on:

Business viability
Applicant quality
Job scope
Company activity

Not the nominee director.

12. Assuming Incorporation Guarantees EP Approval

Many new companies overestimate the ease of obtaining an EP.

Incorporation is easy.
EP approval is not.

EP approval requires:

Strong documentation
Demonstration of business need
Applicant relevance
COMPASS scoring compliance
Financial strength

Never assume that owning a Singapore company guarantees EP approval.

13. Weak or No Justification for Hiring a Foreigner

Every EP applicant must be justified based on:

Skills
Experience
Regional business value
Industry expertise
Network or technical ability

New companies often fail to clearly articulate why the foreigner is essential.

Strong justification example:

“Our applicant has 12 years of biotech R&D experience and has previously managed clinical trial expansions across APAC. This expertise is critical for our planned research collaboration with hospitals in Singapore.”

14. Not Strengthening the Company Before Appeal

Many companies submit an appeal within a few days using the same documents.
This is almost certain to fail.

To appeal successfully:

Increase paid-up capital
Improve job scope
Add new client evidence
Strengthen business plan
Add professional certifications
Increase salary if needed

A rushed appeal shows no improvement and signals weakness.

Conclusion

New companies face a steeper challenge when applying for an Employment Pass, not because MOM rejects new businesses, but because many applicants fail to prepare sufficiently or present a compelling case. The most common EP mistakes—like poor job descriptions, weak business activity, low paid-up capital, and mismatched roles—are avoidable with proper planning.

To avoid EP rejection, new companies should:

Build operational credibility first
Inject realistic paid-up capital
Prepare a detailed business plan
Align job scope with applicant’s skills
Provide evidence of business activity
Offer a salary aligned with age and industry
Strengthen COMPASS scoring
Create professional and well-documented submissions

With the right preparation and documentation, even newly incorporated companies can successfully secure an Employment Pass for their foreign founders or key employees.