COMPASS 2026: What Singapore SMEs Must Fix Before Their Next Employment Pass Renewal

If you have Employment Pass holders whose passes expire between now and the end of 2027, the work that decides whether those renewals succeed has to happen this quarter — not at renewal time. COMPASS scores your company as much as it scores your employee, two of the four foundational criteria are firm-level and relative to your sector, and the underlying benchmarks are refreshed periodically rather than fixed. A pass holder who cleared 40 points last cycle can land at 30 next cycle without a single thing changing about their salary or qualifications. The fix is a roster, an honest headcount pull from payroll, and two or three decisions made in Q4 that only take effect in January. All of it is doable in an afternoon a week for the next month.

What is actually changing with COMPASS in 2026?

COMPASS — the Complementarity Assessment Framework — has applied to new Employment Pass applications since September 2023 and to renewals since September 2024. Candidates need 40 points to pass, drawn from four foundational criteria worth 0, 10 or 20 points each: C1 salary measured against local PMET salaries in your sector, C2 qualifications, C3 nationality diversity within your PMET workforce, and C4 your share of local PMET employees relative to your industry. Two bonus criteria sit on top: C5 for roles on the Shortage Occupation List, and C6 for firms recognised under strategic economic programmes.

The part SMEs miss is that C1, C3 and C4 are all measured against moving benchmarks. MOM refreshes the local PMET salary benchmarks and the sector-level diversity and local-share benchmarks as the labour market shifts. When those numbers step up, your score steps down. Layer on the Employment Pass qualifying salary floor — S$5,600 for most sectors and S$6,200 for financial services, rising with age — which applies to renewals from 1 January 2026, and a renewal that was comfortable in 2024 can be marginal in 2026. Treat any published benchmark you are working from as a snapshot: confirm the current figures in MOM's Self-Assessment Tool before you commit to a salary decision.

Why do renewals fail when nothing about the employee has changed?

Because C3 and C4 describe your organisation, and your organisation changed even if the employee did not. If you hired three more foreign PMETs over the past year and no locals, your nationality concentration worsened and C3 can drop from 20 to 10, or 10 to 0. If two experienced local executives resigned and you backfilled with contractors or overseas hires, your local PMET share falls against the industry median and C4 moves the same way. That is a 20-point swing available across two criteria you never explicitly decided to change.

There is also a threshold trap worth knowing about before you grow into it. Small firms — those below MOM's PMET headcount cut-off, currently set at 25 — are given a default 10 points each on C3 and C4, on the reasoning that ratios in a nine-person company are too volatile to score fairly. Cross that line and you stop receiving the default and start being scored against your sector. Depending on your mix, that is worth up to +20 or down to -20 overnight. Firms approaching 25 employees are already watching that number for other reasons — the Workplace Fairness Act's coverage threshold sits in the same neighbourhood — so put both on the same tracker rather than discovering each one separately.

Which COMPASS points can you still move before Q4?

Ranked by how quickly they respond to a decision made this quarter:

• C5, Skills Bonus. Check whether the role sits on the Shortage Occupation List. This is the cheapest 10 or 20 points on the board, it costs you nothing, and most SMEs never look.
• C1, Salary. Points follow actual fixed monthly salary, so an increment has to be real and declared. That means deciding it in Q4 for a January payroll cycle — not the week the renewal is filed.
• C2, Qualifications. Fixed for the individual, but verification against MOM's recognised-institution list takes time. If a degree needs third-party assessment, start now, not in the renewal window.
• C3 and C4. These respond only to hiring and retention decisions, and they are measured on your workforce profile rather than a single day's snapshot. Anything you want to show at a mid-2027 renewal has to start in Q4 2026.

How do you check your score without guessing?

Run MOM's COMPASS Self-Assessment Tool for every pass holder due for renewal in the next twelve months — not just the next quarter — and record the criterion-by-criterion breakdown, not only the total. A candidate at 40 and a candidate at 60 need very different amounts of attention, and the total alone hides which criterion is carrying them.

Then build the roster: name, pass expiry date, renewal window opening (employers can generally file from around six months before expiry), current fixed monthly salary, current SAT score, and points margin above 40. Anyone under 50 goes on a watch list. Anyone under 45 gets a decision in Q4, because January is your last clean increment cycle before mid-2027 renewals.

The hard part is usually the headcount. C4 is about your local PMET share, and most SMEs cannot answer "how many local PMETs did we average over the last six months" without three people reconciling a spreadsheet, a payroll export and someone's memory. Your CPF contribution records are the authoritative source for the local count — use them, not the org chart, which is always out of date and always optimistic.

What does an HR data problem have to do with an EP renewal?

Everything, and this is where most of the avoidable failures live. If your payroll system, your leave tracker and your headcount spreadsheet disagree, you cannot see a C3 or C4 slide coming — you discover it when a renewal is rejected and you have weeks, not months, to respond.

The fix is unglamorous and takes about a day. Make payroll the single source of truth for headcount. Export a monthly snapshot with residency status and role band, and append it to one table so you have a trend line rather than a series of one-off panics. That single table answers your COMPASS exposure, your Workplace Fairness Act threshold question, and your CPF and IR8A year-end reconciliation from the same data — three obligations, one export, no double entry.

It also reframes the harder question honestly. When a renewal is genuinely going to fail, the useful response is rarely to fight the score. It is to ask whether the role should be redesigned — which parts are judgement that needs an experienced person, and which parts are routine processing that a workflow should have absorbed two years ago.

What should you do in the next two weeks?

1. By 5 September: list every EP holder with an expiry date before 31 December 2027, with expiry and current salary.
2. By 12 September: run the SAT for each one and record the full breakdown.
3. By 19 September: pull a twelve-month PMET headcount split — local versus foreign — from payroll and CPF records.
4. By 30 September: decide January 2027 increments for anyone whose C1 points are marginal.
5. By 31 October: escalate every renewal scoring below 50 to whoever owns the hiring budget, with the option analysed: increment, redesign the role, or plan for the pass not being renewed.

None of this requires an immigration consultant. It requires a list, a payroll export and one decision-maker in a room for an hour.

Frequently asked questions

Does COMPASS apply to renewals, or only to new Employment Pass applications?
Both. COMPASS has applied to new applications since September 2023 and to renewals since September 2024. A pass issued before COMPASS existed will be assessed under it at renewal, which is why long-tenured pass holders are often the biggest surprises.

My company has twelve staff. Do C3 and C4 still matter to me?
Right now you receive default points on both because you are under MOM's small-firm PMET headcount cut-off. The risk is growth: cross the threshold and you are scored against your sector instead, which can move your total by up to twenty points in either direction. Track your PMET headcount monthly so the crossing is a planned event rather than a rejection letter.

Can I raise an EP holder's salary just before renewal to pick up C1 points?
The points follow declared fixed monthly salary, so an increase has to be real, paid and reflected in your submission — a paper adjustment is not a strategy. Practically, that means folding it into your normal January increment cycle, which is exactly why the decision belongs in Q4 rather than in the renewal window.