Parliament House abuts the Singapore River
During the September 2025 sitting of Parliament, the Ministry of Manpower (MOM) provided replies to several questions relating to migrant labour. This three-part article archives those replies and adds our comments. In Part 2 will be discussed the two parliamentary questions relating to the Training Employment Pass; in Part 3, the question relating to the Change of Employer option for migrant workers with valid employment claims. In this part are all the other questions touching on migrant workers.
Primary Care Plan and medical insurance for other work pass holders
Member of Parliament Patrick Tay Teck Guan (PAP) asked the Minister for Manpower (a) whether the Ministry is considering requiring employers to purchase the Primary Care Plan (PCP) for Work Permit and S Pass holders who do not stay in dormitories or work in the Construction, Marine Shipyard and Process sectors; and (b) whether the Ministry is considering requiring employers to purchase medical insurance for Employment Pass holders.
MOM replied:
The Primary Care Plan (PCP) is mandated only for Work Permit and S Pass holders who live in dormitories or work in the Construction, Marine Shipyard and Process sectors. This is because most of these workers live in communal dormitories and face a higher risk of infectious disease outbreaks. The PCP also improves accessibility of primary care as PCP clinics are usually located near where they stay. Employers may choose to purchase the PCP, which is under a fixed capitation rate, for their other migrant workers to have better cost certainty.
2. The Ministry of Manpower does not require employers to purchase medical insurance for Employment Pass (EP) holders, as they would have the means to purchase personal medical insurance, or may be receiving medical benefits as part of their employment contract.
TWC2’s comment
It is a good idea to make it mandatory to sign up all Work Permit and S-Pass holders with Primary Care Plans (PCP). Under the present scheme, PCP providers are anyway zone-based so employers can choose one operating in the same zone where the employee is housed.
PCP plans indeed provide a much higher degree of cost predictability than ad hoc clinic visits, so it may seem obvious that employers would be motivated to bring all their non-dormitory Work Permit and S-Pass employees under a PCP, but in reality, things may work out differently. There are employers known to be quick to bully workers to self-medicate and not seek healthcare at all. Zero cost, in their minds, is cheaper than the $5 PCP visits.
Regulatory pressure has value otherwise progress is just harder to achieve.
Publication of Employment Claims Tribunal judgements
Member of Parliament He Ting Ru (Workers’ Party) asked the Minister for Manpower whether the Ministry can give an update about its deliberations on whether it will make it the default position to publish the judgment and grounds of decision for cases brought before the Employment Claims Tribunal on an anonymised basis.
MOM replied:
1. In general, the Executive leaves it to the Courts to decide on which judgments to publish.
2. The Courts have determined that judgments delivered in the Employment Claims Tribunals (ECT) need not be published by default. Going forward, given the considerable body of case law developed since the establishment of the ECT in 2017, the Judiciary will be publishing selected ECT judgments which serve as useful reference to parties and the general public. The publication of a curated set of ECT judgments, targeted to be made available in phases from the second half of 2026, aims to provide greater awareness and a better understanding of the legal rights and responsibilities in employer-employee relationships. This in turn enhances access to justice. The Courts may also make judgments available upon request by any party and with the Courts’ approval. This approach strikes a balance between helping the public understand the law and how it is applied, ensuring that the ECT continues to dispense justice in a timely manner, and maintaining the confidential nature of such proceedings.
TWC2’s comment
This was a good question posed to the minister, and an encouraging reply. However, much will depend on the extent of any redaction applied and the manner of curation. We shall see.
Surveys on recruitment fees paid by Work Permit holders
Member of Parliament Eileen Chong Pei Shan (Workers’ Party) asked the Minister for Manpower (a) whether the Ministry has conducted surveys on recruitment fees paid by work permit holders in Singapore and in their home countries; (b) if so, whether the Ministry will release its findings with breakdowns by (i) country of origin (ii) sector and (iii) gender; and (c) if not, whether the Ministry will consider conducting such surveys in the near future.
MOM replied:
The Ministry of Manpower (MOM) conducts ad hoc surveys on the total recruitment fees paid by work permit holders. Among first-time non-domestic work permit holders who indicated paying recruitment fees, the typical total recruitment fees in 2024 by sector are as follows:
a. Construction sector: between $1,000 and $7,800;
b. Marine shipyard sector: between $1,200 and $4,800;
c. Process sector: between $600 and $7,200;
d. Manufacturing sector: between $1,500 and $7,400; and
e. Services sector: between $900 and $7,100.
2. The typical fees by gender are as follows:
a. Males: between $1,000 and $7,200; and
b. Females: between $300 and $5,600.
3. MOM does not publicly disclose data broken down by nationality, in view of sensitivities bilaterally and among different communities in Singapore.
TWC2’s comment
It was a bit of a surprise to see in this answer that MOM “conducts ad hoc surveys” on recruitment fees. Over more than ten years, TWC2 does not recall seeing any published. Might the data be too embarrassing for MOM?
As for the numbers revealed in this parliamentary answer, TWC2’s sense is that they are lower than where the truth may lie. For example, we have documented cases of construction workers paying well over $10,000 for their first jobs. See: Average recruitment cost hit $15,000 in 2015 for first-time Bangladeshi construction workers, and Recruitment cost in some cases about 20 times monthly salary.
As for workers in the marine engineering industry, see this article: Recruitment cost up to 22 months’ salary for shipyard workers where the first-time workers paid between $7,000 and $9,000 for their jobs.
Educating migrant workers on kickbacks
Member of Parliament Jamus Jerome Lim (Workers’ Party) asked the Minister for Manpower (a) how often does the Ministry or its agencies educate migrant workers on kickbacks; and (b) whether the Ministry will consider (i) increasing the frequency of such education and (ii) amending the law to strengthen protections for affected workers.
MOM replied:
The Ministry of Manpower (MOM) leverages various touch points to regularly educate migrant workers on kickbacks and to encourage them to report such offences. These include the Settling-In-Programme which is mandatory for all first-time, non-Malaysian migrant workers in the Construction, Marine, Process, and Manufacturing sectors, as well as through the FWMOMCare app, social media channels and partnerships with NGOs.
The collection of kickbacks is a serious offence. Under the Employment of Foreign Manpower Act, offenders may face up to two years of imprisonment, a fine of up to $30,000, or both. To date, the Courts have imposed substantial fines of $10,000 to $15,000 per charge or imprisonment terms. On top of these penalties, the Courts may order offenders to surrender the monies received from the affected workers if no restitution has been made.
These measures have been effective in keeping the number of kickback cases low. Migrant workers can report kickbacks without fear of reprisal from their employers as MOM will facilitate a change of employment for those who wish to continue working in Singapore. We will continue to monitor the situation and review the penalties where necessary.
TWC2’s comment
Ten years ago, reports of kickbacks were commonplace; such complaints have reduced since then, but we are not sure why. Kickbacks are payments demanded by employers from employees, with the implied threat that the Work Permit will be cancelled or not renewed should payment not be made.
We don’t think “educating” workers has much to do with the improvement seen, because it is obvious to any worker, even foreign workers, that such demands cannot be legitimate. Enforcement was probably the main driver for behaviour change among employers.
However, the problem has not totally gone away. As recently as January this year, we published Worker resists boss’ demand for kickbacks. “Don’t play with me,” warns boss complete with snapshots of the employer’s WhatsApp messages. Even S-Pass workers are victimised by such demands. This story about lifeguards contains a mention of $1,500 demands by the company manager: Entrusting children’s lives to sleepless lifeguards.
Registration and Enforcement of Settlement Agreements Mediated by TADM
Member of Parliament Kenneth Tiong Boon Kiat (Workers’ Party) asked the Minister for Manpower (a) whether the Ministry will provide that settlements mediated by the Tripartite Alliance for Dispute Management automatically become court judgments, with penalties for employer defaults; (b) if not, why not; and (c) how is the requirement for workers to commence separate court enforcement proceedings when an employer defaults assessed to balance employee interests against defaulting employers.
MOM replied:
The power to grant a court order is exercised by the Judiciary. The Ministry of Manpower (MOM) does not have the legal authority to exercise a judicial power to convert settlement agreements into court orders. Either party may instead register a settlement agreement recorded at the Tripartite Alliance for Dispute Management (TADM) with the District Court.
A registered settlement agreement is enforceable as an order of the District Court and entitles one party to take enforcement action against the defaulting party for breaching the settlement agreement. The Courts will determine if the terms of the court order have been breached. Whilst a settlement that is not registered with the District Court is still legally binding, a party must first successfully sue the defaulting party for breaching the terms of the settlement agreement and obtain a court order, before any enforcement action can be taken.
Notwithstanding the Court’s involvement, MOM and tripartite partners have put in place a process to ensure that workers receive the agreed payment as far as possible. Once a settlement agreement has been registered and is enforceable as a court order, if the worker did not receive payment by the due date, he can inform TADM who will help to engage the employer, advise the worker on the process to apply to the Courts to enforce the court order, and escalate as necessary to MOM for possible enforcement actions. Penalties such as warnings, fines, debarment from applying for work passes, and prosecution in court, may be imposed on errant employers.
TWC2’s comment
The minister’s reply, making the distinction between a court order arising from a judicial process and TADM’s administrative processes, is well-grounded. In any case, TWC2’s observation from our casework is that TADM does indeed monitor quite closely whether settlement agreements are honoured.
The problem is that MOM’s toolkit is quite limited. In the main, if an employer fails to pay up in accordance with a settlement agreement, it can only bar the employer from hiring more foreign workers. This has little bite if the company is going out of business anyway. Or, if MOM imposes a fine, this only means something if the employer is still in Singapore. Many foreigners have set up subcontracting companies here and, for reasons of ethnic and lingiuistic commonality, these bosses are often the ones hiring foreign workers. However, when things go south and salaries are not paid, the bosses often abscond back to their home countries.
What is helpful is the $5,000 security bond that employers must put up for each Work Permit holder. There is a process to forfeit this bond and pay most of the amount to the worker. This is of considerable comfort to workers – if the owed amount is under $5,000. The trouble is, many workers do not file salary complaints until much higher amounts are owed to them in unpaid salaries. Even when the security bond is forfeited, there simply isn’t enough money to make good.
But why do workers accrue so much in owed salary before coming forward? Two reasons:
1. The worker is afraid of losing the job when he has not earned enough to pay off the loans he amassed to fund the recruitment fee. He may think it wiser to keep hoping that the boss will make good on the owed salary – and not antagonising the boss by filing a salary claim would be essential to keep that hope alive – than to file a claim, anger the boss, and lose the job.
2. Even if a worker is debt-free, he may still prefer to keep working than trigger a Work Permit cancellation by filing a claim. He will be acutely aware that finding a new job will cost thousands of dollars in new recruitment fees.
What the above suggests is that the solution to employers reneging on settlement agreements isn’t entirely a question of court orders or (costly) enforcement action, though enforcement will always have a role to play. Stamping out excessive recruitment fees and making it easier for workers to move swiftly into new jobs will help considerably. Workers must not feel trapped in jobs with unpaid salaries. If, after one or two months of non-payment, they feel free to file a claim, the amount will most probably be below the security bond value of $5,000 and the problem will be much easier to solve.
We must also bear in mind the plight of S-Pass workers. Their employers do not have to put up security bonds, unlike the requirement for employers of Work Permit holders. There isn’t any $5,000 bond that MOM can forfeit if salary is not paid. A simple solution would be for MOM to impose a similar security bond on employers of S-Pass workers.
Foreigners working without valid work passes
Member of Parliament Elysa Chen (PAP) asked the Minister for Manpower (a) how many cases of foreigners found working without valid employment passes were reported annually over the last five years; and (b) what proportion resulted in (i) prosecutions (ii) fines or (iii) repatriations.
MOM replied:
From 2020 to 2024, an annual average of 450 foreigners were found to be working illegally without valid work passes. On average, 13 foreigners were prosecuted, 4 were fined and the rest were issued with warnings, as most of the cases involved short duration of illegal employment. These foreigners were also repatriated and debarred from working in Singapore.
TWC2’s comment
We first note that although the question used the term “employment passes”, the minister’s reply was about “work passes”. An Employment Pass is a specific category of work passes issued by MOM. Nonetheless, it was reasonable to intuit that the member of parliament intended to ask about work passes, or lack thereof.
However, we’re not totally clear what the figure of 450 per year actually represents. On the face of it, it connotes a situation where a foreigner deliberately engages in paid work despite not having a work pass. However, there are two more subtle scenarios and we are not sure if the minister’s figure includes them:
The first additional scenario is one where the worker is continuing to perform his usual job without knowing that the employer has quietly cancelled his work pass. Employers can cancel work passes online and TWC2 has come across cases where this was done behind the worker’s back. With no clue that anything was amiss, the worker may continue to work for weeks till he discovers by accident that his work pass has been cancelled.
The second scenario is a variation of the above – one where the employer has fallen behind in his payments of the monthly foreign worker levy. MOM suspends the work passes of the employees involved, but if the employer does not inform his crew, then workers may be none the wiser and are likely to continue working.
Does the 450-per-year figure include these scenarios? If so, the statement that since only short periods of illegal employment were involved, “These foreigners were also repatriated and debarred from working in Singapore” sounds quite unjust. It would be good if a clear assurance is given by the ministry that penalties are not imposed on workers if employers do not inform them about the cancellation or suspension of their work passes.
Moonlighting domestic workers and the Household Services Scheme (HSS)
Member of Parliament Yeo Wan Ling (PAP) asked the Minister for Manpower (a) in each of the past five years, how many migrant domestic workers and unofficial employers have been fined for illegal moonlighting; and (b) what is the take-up rate of the Household Services Scheme since its permanent formalisation in 2021.
MOM replied that:
Between 2020 and 2024, an average of 12 Migrant Domestic Workers (MDWs) and 15 employers were fined each year for moonlighting related offences.
The Household Services Scheme (HSS) allows companies to hire migrant workers to provide part-time domestic services such as home cleaning, grocery shopping, car-washing and pet-sitting. Since formalising the HSS as a permanent scheme in 2021, the number of HSS companies increased from around 80 to 240 today. Based on surveys, the number of households served by HSS companies have also increased steadily.
MOM supports companies offering HSS services through quota and source country concessions for migrant workers and the companies determine the prices of their services based on market demand and types of services provided. HSS companies benefit from additional work permit quota above the prevailing Dependency Ratio Ceiling (DRC) for the services sector. As there has been a steady growth of HSS companies over the past years, there is sufficient choice for consumers and no impetus currently to consider government interventions on the prices of such services.
We recognise the manpower benefits of foreign workers working for multiple households for greater efficiencies. Hence, we support schemes such as HSS, as well as the Shared Stay-in Senior Care Services Sandbox, which allows workers to be deployed across households with additional foreign worker quota and source relaxations. Under such schemes, workers only have one employer, for clear accountability over the worker’s welfare. This better safeguards the interests of both workers and employers. For example, if MDWs are allowed to concurrently work for HSS companies and sustain an injury, it would be hard to determine the proportion of liability to be borne between multiple employers.
Furthermore, once we allow migrant workers to work for multiple employers, it will be difficult to prevent them from moonlighting illegally, which will undermine the integrity of the work pass framework and affect business prospects of law-abiding companies, as well as our local workers’ employment outcomes.
TWC2’s comment
At TWC2, we do not see enough domestic worker cases to be able to assess if the figures for “moonlighting” reflect the real situation on the ground. For clarity, we believe the term “moonlighting” used here means a situation where the migrant domestic worker works outside her approved place of employment on her own accord (i.e. not directed to do so by her official employer).
The rationale behind the minister’s reply about HSS, especially about the need to have clear employer accountability, is uncontestable. Also, we wouldn’t expect the minister to know the “take-up” rate, since this would be commercially sensitive information.
Nonetheless, the figure for the number of companies provided by the minister may raise concerns. That there are now 240 companies, mushrooming from only 80 a couple of years ago may suggest that many are mosquito-sized enterprises with unsteady cash flow, a consequence of brutal competition among them. This can result in job precarity for the employees involved.
Other questions relating to domestic work
For completeness’ sake, here are links to MOM’s site containing other questions pertaining to migrant domestic workers, from the September 2025 sitting: