Do small companies need MOM employment verification?

Written by
RMI Team

Yes, MOM employment verification requirements apply to all Singapore-registered employers, regardless of company size. If your company is hiring a foreign professional on an Employment Pass (EP) and their educational qualifications are needed to score COMPASS points, you must engage an MOM-approved background screening provider to verify those credentials before submitting the work pass application. There is no SME exemption.

Singapore’s Ministry of Manpower (MOM) made education verification mandatory for all new Employment Pass applications from 1 September 2023, and extended this to EP renewals from 1 September 2024. The obligation is triggered by the pass type and the qualifications being declared, not by how many staff your company employs or your annual turnover.

For a detailed overview of what the verification process involves and how it fits into the broader EP application, download RMI’s MOM Employment Pass Best Practice Guide

Enhance your understanding of MOM Employment Pass requirements and streamline your HR processes.

When do small companies need to conduct background checks?

If you are applying for an EP for a foreign candidate and you are declaring their post-secondary diploma or higher qualifications to claim COMPASS points, you must provide proof of verification from an MOM-approved screening company.

There are two key conditions that must both be met to trigger the obligation:

  • The candidate holds a post-secondary diploma or higher qualification
  • That qualification is being declared in the EP application to contribute towards the candidate’s COMPASS score

If a qualification is not needed for COMPASS scoring, employers are not required to declare it, and therefore, verification is not required for that credential. However, in practice, most EP applications do depend on qualifications to achieve the minimum 40 COMPASS points required for approval.

From 1 January 2026, MOM also updated its list of top-tier institutions and qualifying degree-equivalent professional qualifications under COMPASS Criterion 2, as outlined in KPMG’s December 2025 Global Mobility Services (GMS) Flash Alert on COMPASS updates. This means employers who previously relied on certain institutions for automatic point allocations now need to verify more carefully which credentials still qualify and ensure their verification proof is in the correct MOM-approved format.

What happens if a small company skips MOM verification?

Failing to submit the required verification proof from an MOM-approved screening provider does not simply result in a delayed application, it typically results in EP rejection.

If the candidate’s declared qualifications cannot be verified, the COMPASS points associated with those credentials are not awarded, which may result in the application failing to meet the 40-point threshold.

Beyond rejection, employers who are found to have submitted inaccurate or unverified credentials risk being flagged by MOM, which could affect future work pass applications across the company.

 

Risk Category 

What It Means for Your Business 

Typical Impact 

EP Application Rejected  Unverified qualifications cannot earn COMPASS points; application may fall below 40-point threshold  Restart of application process; months of delay 
Candidate Start Date Missed  Delayed EP approval pushes back onboarding, affecting project timelines and client commitments  Revenue impact; potential client penalties 
MOM Compliance Flag  Employers with poor compliance track records face higher scrutiny on future EP applications  Reduced employer COMPASS scores 
Credential Fraud Exposure  Without third-party verification, employers cannot confirm a candidate’s qualifications are genuine  Legal and reputational risk if a fraudulent hire is discovered post-onboarding 
Wasted Recruitment Costs  A rejected EP after recruitment spend means starting the entire hiring process again  Average cost of a bad hire: 30–150% of annual salary 

 

Frequently asked questions

Does my startup need MOM employment verification for its first hire?

Yes. If your startup is sponsoring an Employment Pass for a foreign professional and declaring their educational qualifications to gain COMPASS points, you must use an MOM-approved screening provider to verify those credentials. There is no minimum headcount or revenue threshold that exempts companies. Startups with fewer than 25 PMETs do receive automatic COMPASS bonus points in two criteria, but this does not remove the verification requirement.

Are S Pass holders also subject to MOM verification requirements?

S Pass applications are not currently subject to the same mandatory education verification requirement as Employment Passes. However, conducting verification for S Pass candidates is considered best practice for employer due diligence, particularly in sectors where professional credentials are critical to the role. MOM has not yet announced an extension of mandatory verification to S Pass applications.

What happens if my EP application is rejected due to missing verification proof?

If an EP application is rejected because verification proof was not provided for declared qualifications, the employer must resolve the verification before resubmitting. This typically means engaging an MOM-approved agency, completing the verification process, and then resubmitting the application from scratch. The candidate cannot begin work in Singapore until the EP is approved.

Does the COMPASS framework change for small companies compared to large ones?

The COMPASS assessment framework applies equally to all employers. However, smaller firms with fewer than 25 PMETs receive automatic maximum scores for two firm-related criteria, local workforce support and workforce diversity, which partially offsets their typically higher proportion of foreign staff. This bonus does not affect the education verification requirement, which remains the same for all employers.