Before a Singapore employer can submit most Employment Pass or S Pass applications, there is a step that has nothing to do with MOM’s online portal at all: advertising the job to Singaporeans first. This is the Fair Consideration Framework (FCF), and getting the advertising step wrong is one of the most common, and most avoidable, reasons an otherwise strong work pass application gets delayed or rejected.

This guide sets out exactly who must advertise, for how long, where, and what the advertisement must say, so that by the time you submit the actual pass application, this box is already safely ticked.

What the Fair Consideration Framework Requires

The FCF is a Ministry of Manpower policy requiring employers to fairly consider Singaporean candidates before hiring a foreigner on an Employment Pass or S Pass. In practice, the central obligation most employers encounter is the job advertising requirement: the vacancy must be advertised on MyCareersFuture, the national jobs bank, before the pass application is lodged.

The 14-Day Minimum Advertising Period

The current minimum advertising period is 14 consecutive calendar days. This has not always been the case, the requirement was temporarily doubled to 28 days in 2020 in response to labour market conditions during that period, before being restored to 14 days with effect from 1 September 2022. Employers relying on older guidance, templates, or advice from 2020-2021 should double check they are not still over-advertising (or under-advertising) based on an outdated rule.

The advertisement must run for the full 14 days before an application is submitted, and critically, the employer must not make a firm job offer to anyone, Singaporean or foreigner, during that window. Making an offer mid-advertisement undermines the entire point of fair consideration and can be treated as a breach of the framework.

Who Must Advertise, and Who Is Exempt

The job advertising requirement generally applies to Employment Pass applications where the fixed monthly salary is below the threshold set by MOM for FCF purposes, and to most S Pass applications, subject to periodic adjustment. Several categories of employers and roles are exempt, including:

– Companies with fewer than 10 employees;
– Roles paying a fixed monthly salary at or above the FCF exemption threshold set by MOM;
– Intra-corporate transfers of fewer than 1 year, in some circumstances;
– Renewal applications, since the job is not newly created; and
– Specific short-term or other narrowly defined categories MOM designates from time to time.

Because these exemption thresholds and categories are reviewed periodically, an employer should always check the current rules on the MOM website before assuming an exemption applies, rather than relying on last year’s checklist. A related and frequently confused exemption applies when an employee is switching employers within a related company group, which our companion article covers in detail.

What a Compliant Job Advertisement Must Include

MOM does not accept a token listing. A compliant advertisement on MyCareersFuture must:

1. Be open to all candidates, without any wording that discourages Singaporean applicants or signals the role is reserved for a specific foreign candidate;
2. Describe the job accurately, including the actual duties, requirements, and the salary range actually being offered;
3. Not be written to match a single named candidate’s qualifications so narrowly that no genuine Singaporean applicant could realistically qualify; and
4. Remain live and unchanged in its key particulars for the full minimum period.

MOM has, in past enforcement rounds, penalised employers who post vague, overly narrow, or clearly non-genuine advertisements purely to tick the compliance box. Repeated poor practice can result in a firm being placed on the Fair Consideration Framework watchlist, with consequences for all its future work pass applications, not just the one in question, a risk closely related to the broader EP and S Pass ecosystem employers need to manage carefully.

Documenting Fair Consideration

Beyond simply posting the advertisement, employers are expected to be able to show that Singaporean applicants, if any came forward, were genuinely considered, interview records, reasons for non-selection, and a hiring process that treats local and foreign applicants consistently. Keeping this paper trail is far easier if it is built into the recruitment process from the start, rather than reconstructed after MOM asks questions.

Sequencing: Advertise First, Apply Second

A frequent and entirely avoidable error is submitting the Employment Pass or S Pass application before the 14-day advertising window has run its full course, or before it has even started. MOM’s system will generally reject or query an application where the advertising dates do not line up correctly, which can cost weeks in a process that is often already time-sensitive, particularly where the candidate is expected to start work, or an existing pass is close to expiry (see our related guide on S Pass timelines for specialised roles for how tight these windows can get in practice).

The safest sequence is: confirm whether FCF applies and whether an exemption is available; if not exempt, post a genuinely compliant advertisement; let the full 14 days run without making any offer; then prepare and submit the EP or S Pass application referencing the completed advertisement.

How This Interacts with COMPASS

The Fair Consideration Framework advertising requirement sits alongside, not instead of, the points-based COMPASS framework that now governs most Employment Pass eligibility assessments. Satisfying FCF does not automatically mean a candidate scores enough points under COMPASS, and conversely, a strong COMPASS score does not excuse an employer from the advertising obligation where it applies. Both checks need to be run in parallel well before the intended start date.

Frequently Asked Questions

Does the 14-day advertisement need to be a brand new listing, or can an existing listing be extended?

MOM generally expects a fresh, genuine listing created for the specific role being filled, running for the full consecutive 14-day period immediately before the pass application. Recycling an old listing, or quietly extending one that was originally posted for a different purpose, is unlikely to satisfy the requirement and risks the application being queried or rejected outright.

What if the employer genuinely cannot find a suitable Singaporean candidate during the 14 days?

This is the expected and entirely normal outcome of many compliant searches, the Fair Consideration Framework requires genuine consideration, not a guaranteed local hire. Provided the advertisement was compliant and candidates (if any applied) were genuinely considered and reasonably assessed, the employer can proceed to hire the foreign candidate and submit the pass application referencing the completed advertisement period.

Does a job advertised on LinkedIn or a recruitment agency’s own site satisfy the FCF requirement?

No. The core FCF obligation specifically requires advertising on MyCareersFuture, the national jobs bank portal. Advertising elsewhere, even extensively, does not substitute for this specific requirement, although there is of course nothing wrong with advertising on other platforms in parallel for genuine recruitment purposes.

Conclusion

The Fair Consideration Framework’s job bank advertising requirement is a procedural step, but it is not a formality to rush through. Advertise for the full 14 consecutive days, write a genuine and accurate listing, make no offers during the window, and keep records of how Singaporean applicants were considered. Get the sequencing right, and the rest of the Employment Pass or S Pass application process runs far more smoothly.

For end-to-end assistance with work pass applications, including checking whether your vacancy is FCF-exempt and managing the MyCareersFuture advertisement correctly, our associated licensed employment agency handles the full submission process with MOM, working alongside the corporate secretarial team at Raffles Corporate Services.

To speak with the team at Raffles Corporate Services, you can email [email protected] or call, SMS, or WhatsApp +65 8501 7133. We are happy to assist with any queries.

The Editorial Team, Raffles Corporate Services