Laws and
labour protection

PROMOTING SYSTEMIC CHANGE

LAWS AND LABOUR PROTECTION

“They told me to follow the company agreement, not MOM’s law. They said that everyone does that.” – Migrant worker (name redacted) 

No matter how many individual workers we assist, more workers will find themselves in need of help, unless their systemic vulnerabilities are addressed. TWC2 thus advocates for improvements in migrant labour legislation and its enforcement.

We gather evidence about workers’ lived realities, call out errant employers and practices, identify key gaps and solutions, and drive public and parliamentary conversations about migrant worker policies.

Migrant workers are essential to Singapore’s economy.

Background on relevant laws

There are several pieces of legislation impacting migrant workers. One – EFMA – is specific to foreign nationals working in Singapore, while the others cover both local and foreign employees.

Singapore’s Employment Act (EA), which came into effect in 1968, lays out key employment rights for all employees except for domestic workers and seafarers. The Act affords critical protections around maximum hours of work, the right to weekly rest days, and salary payments.

The Employment of Foreign Manpower Act (EFMA), established in 1990, governs the employment conditions of migrant workers and regulates areas not covered by the Employment Act. These include employer responsibilities, Work Permit rules, and repatriation.

The Employment Claims Act sets out processes for dispute handling. The process is a two-stage one involving mandatory mediation, followed by adjudication by the Employment Claims Tribunal if mediation is unsuccessful. It applies to both local and foreign employees.

There is also the Work Injury Compensation Act, which ensures that employees receive due compensation after any work-related injury.

Other laws that have a bearing on migrant workers include:

TWC2’s recommendations are shaped by our conversations with migrant workers, and the cases we handle.

Advocating better laws

Over the years, TWC2 has consistently reviewed EA and EFMA, and submitted proposals to the government:

2026, 2018, 2014, 2013, 2012

We also present findings to international bodies such as the United Nations, and regularly submit shadow reports:

2025, 2021, 2020, 2015

Recommendations over the years

Too often, we see workers fall through gaps. Upon gathering evidence from the ground-up, we communicate our observations and recommended solutions to policy makers. Click on the following tabs for our key findings and recommendations, as well as progress made over the years:

Wage theft is by far the most common issue that low-wage migrant workers face. Many workers are disadvantaged in claiming their owed wages, because they were not issued official documentation around salary payments. 

TWC2 has pushed to make the following mandatory in the Employment Act: (1) the issuance of itemised payslips and (2) the payment of salaries through bank transfer. 

Progress has been made over the years, although the enforcement of these laws remains an issue.

  • 2026: TWC2 report on illegal overwork
  • 2024: TWC2 report on sticky cash
  • 2024: TWC2 report on payslips
  • 2023: TWC2 highlights widespread violation of payslip law
  • 2023: bank transfer rule extended to dorms with 7 occupants or more
  • 2021: TWC2 questions MOM’s official stats on high compliance of bank transfers
  • 2020: MOM makes bank transfer payments mandatory for dormitory residents
  • 2020: TWC2 media statement condemning MOM advisory to reduce MW salaries
  • 2020: TWC2 media statement on MW vulnerabilities during Covid-19
  • 2018: TWC2 supports parliamentary comment on disallowing salary reductions
  • 2018: TWC2 submits proposals on EA improvements
  • 2018: TWC2 policy brief on bank transfers
  • 2018: TWC2 survey on payslips
  • 2017: TWC2 x SMU report on labour protections required
  • 2017: TWC2 highlights power imbalance between workers and employers
  • 2017: TWC2 survey reveals majority of WPHs have no bank account
  • 2016: TWC2 finds 80% of male wphs prefer bank payments
  • 2016: TWC2 survey on payslips
  • 2015: TWC2 recommendations on inadequacy of MOM’s approach
  • 2015: MOM legislates mandatory payslips
  • 2015: TWC2 press letter on Singapore’s inaction on bank transfers
  • 2014: TWC2 statement that more is needed beyond payslips
  • 2014: TWC2 forum letter on salary non-payments
  • 2014: TWC2 survey highlights widespread problem of illegal deductions
  • 2014: TWC2 survey on salary payments
  • 2013: TWC2 press letter calls for transparency in company practices
  • 2013: TWC2 advocates in press
  • 2013: TWC2 press statement on the changes not adopted in EA amendment
  • 2011: TWC2 highlights gaps in MOM’s worker guide book
  • 2011: TWC2 press letter calling for stronger penalties
  • 2011: TWC2 begins advocacy on twin issues of payslips + bank payments 

Low-wage migrant workers are largely not allowed to transfer to a different company without their employer’s permission. The lack of job mobility makes workers vulnerable to abuse or unfair treatment, because their default option for leaving a bad job is resigning, followed by repatriation. However, with loans taken to pay recruitment debt still to be serviced and families to feed, resigning and repatriation is like jumping from the frying pan into the fire. 

Fortunately, there are limited exceptions to the default rule, and Work Permit holders are allowed transfers without their current employer’s consent under specific circumstances, through the following means:

  • No-consent window period: 40-21 days before the end of a Work Permit, a worker is allowed to transfer to a different company without his existing employer’s consent.
  • Change of Employer (COE) letter: A document issued by MOM to a Work Permit holder at the end of a valid salary claim, allowing him/her 14 days to search for a new job in Singapore.
  • Temporary Job Scheme (TJS): If a worker is required to stay on in Singapore to aid in the investigation of the employer, the ministry will let the workers take on six-month jobs.

These exceptions are too limited, with too many workers still feeling trapped by the lack of freedom to walk away from a bad job or abusive employer. TWC2 advocates for Work Permit holders to be allowed to transfer companies freely, and be given 30-60 days to look for a new job after their permit is cancelled.

  • 2025: TWC2 report on COE
  • 2025: TWC2 highlights limited success of COE and tracks gov data
  • 2024: TWC2 report on no-consent window period
  • 2021: TWC2 critiques SCMX retention scheme
  • 2021: TWC2 press letter on importance of job mobility after Covid-19 
  • 2021: TWC2 highlights problems with adjusted rules
  • 2021: MOM adjusts rules on no-consent window period
  • 2021: TWC2 highlights low success rate of window period
  • 2018: TWC2 qualitative study on COE success rates
  • 2017: blanket rule on COE confirmed in parliament, but success rate of transfers are low
  • 2016: TWC2 notices MOM issuing COEs without us asking
  • 2015: MOM introduces no-consent window period
  • 2014: TWC2 paper on importance of job mobility
  • 2014: TWC2 starts asking MOM to grant COEs against employer’s wishes
  • 2013: Parliament picks up on this term
  • 2013: TWC2 formalises stand on job mobility
  • 2011: TWC2 identifies issue of ‘churn’ resulting from inflexible repatriation

When migrant workers raise salary disputes or get injured, employers often terminate their Work Permit or S pass.

These workers are issued a Special Pass by MOM, which allows them to stay in Singapore until their claims are resolved. However, they are not allowed to work, and, without an income for months, are left in a particularly vulnerable position.

Before 2012, employers were generally understood to be responsible for their upkeep, but the scope of such responsibilities were unclear and inconsistently enforced. Many were left without proper housing, food, or financial support while pursuing claims.

Despite clearer legislation over the years, lapses in enforcement and gaps in essential support have persisted. TWC2 continues to advocate for better legislation and enforcement around employer obligations for upkeep, including the provision of accommodation, food, and medical care for Special Pass holders (SPHs). 

  • 2026: TWC2 presents evidence of inappropriate accommodations for SPHs
  • 2024: TWC2 highlights lack of appropriate food provisions for SPHs
  • 2019: TWC2 highlights progress and gaps
  • 2017: EFMA amended
  • 2016: TWC2 paper on gaps faced by SPHs
  • 2013: TWC2 identifies gaps within EFMA regulation in our Employment Act recommendations
  • 2013: TWC2 publishes position paper on accommodation for SPHs
  • 2013: TWC2 publishes report on accommodation for SPHs
  • 2013: TWC2 highlights unfair treatment of SPHs
  • 2013: TWC2 formalises stand on SPHs
  • 2012: EFMA revised
  • 2012: TWC2 documents vulnerability of SPHs
  • 2011: TWC2 submits proposals for EFMA revisions
  • 2010: TWC2 report on precarity of special pass holders
  • 2008: TCRP set up to help SPHs

Helping a worker assemble documents for his salary claim as he fights it at the Employment Claims Tribunal.

The need for better enforcement

Despite better protections offered by EA and EFMA over the years, many migrant workers continue to face exploitation and abuse. The most common infractions that TWC2 sees are:

  • Illegal and excessive work hours
  • Non-issuance of salary documents (timecards and payslips)
  • Salary payments by cash instead of bank transfer
  • Salary under/nonpayment

At a talk we gave in July 2026, when we described the above kinds of issues that commonly surface, an audience member commented that it was strange to see how all these were only dealt with as civil infringements when underlying every case was a criminal infraction. So why aren’t these treated as such? he asked.

Indeed, that is a good point. TWC2 thus calls for existing laws to be enforced more strongly. By documenting the cases that we see on the ground, we blow the whistle on errant employers, and spread public awareness on the realities that migrant workers face. 

Read our latest articles to find out more about these issues, and click on the following tabs for the key changes that we urge MOM to adopt: 

Need title

MOM currently takes a range of actions ranging from letters of caution, education, and penalties to help employers comply with the law. However, TWC2 believes there is too great a tendency towards leniency and an unwarranted skewing towards education, with insufficient use of penalties.

TWC2 recommends that when employers have been found to break the law, they should be penalised to prevent future infractions and not be let off. Such penalties should also be significant, swift, and transparent in order to be effective deterrents. This is especially after employers have been given sufficient time to adjust to laws previously passed in 2015 and 2020.

Furthermore, in specific cases where a worker, having filed a salary claim, is disadvantaged in his claim because the employer obstinately refuses to furnish documentation, the full force of the law should be brought to bear.

Read our 2025 forum letter.

From TWC2’s casework, we see that most workers’ problems stem from their employers violating laws and regulations. Moreover, most violations are not committed only against one worker; they usually take the form of a company-wide practice (e.g. under-payment of overtime work) that affects all workers. Thus, if one worker lodges a valid complaint, there is good reason to believe that similar abuses are inflicted on all other employees too, even if they are too afraid to speak up.

Logically, therefore, the most efficient way for MOM to check for breaches of law is to follow through from one complaint and conduct an inspection of the human resource or payroll practices of the entire company. Such a targeted approach is more likely to uncover violations than random checks on random companies.

There has to be an operating protocol within MOM in which, any time TADM (the salary claims unit) hears of such violations from one worker, TADM immediately relays the information to the enforcement branch — which should promptly launch an investigation into the whole company.

Read more.

MOM currently conducts around 5,000 Workright inspections annually. These inspections should be conducted more frequently, and in a more transparent manner. Details about the methods and findings of these inspections should be made available, and include: 

  • how many companies were surveyed/assessed
  • methods of inspection
  • percentage compliance
  • whether the information has been verified by asking workers independently if companies’ assertions that payslips were issued for their retention were in fact true.

Read more.

There are over 300,000 domestic workers in Singapore, and they are not protected by the Employment Act.

Domestic workers

TWC2’s work began with improving the conditions of migrant domestic workers in Singapore. Together with other NGOs, we advocated for rest days for domestic workers. In 2012, MOM announced weekly rest days for workers from 2013. Further progress was made in 2023, when MOM mandated that at least 1 rest day a month cannot be compensated away.

While most of our clients are now non-domestic workers, we continue to provide employment advice to domestic workers, and assist with cases when they arise.

Other needed protections

Workers being ferried on the backs of lorries repeatedly comes up in the public discourse. So does the question of dormitories. Indeed the daily discomfort, safety risks and indignities that stem from lorry transport and crowded dormitories are issues that weak legislation permits, and they need to be addressed.

Yet, TWC2 is always conscious of the need to be responsive to migrant workers’ priorities rather than impose our ideas of what is important onto them. In this respect, it is humbling to note that when we meet workers, they hardly ever bring up these issues unprompted. Instead, the most pressing issues for them relate to unpaid salaries, contract violations, premature termination and difficulty in getting treatment for injuries.

There is reason for this. The men and women are here to work, earn and provide for their families. Anything that stands in the way of a decent job and promised income is critical for them. They will endure great hardship – the indignity of lorries, the lack of privacy in dorms – to work and earn, but hardship is not critical the way having a job and regular salary payments are.

This is not to say that these questions of transport and accommodation can be left aside. Our common humanity does not allow such callousness.

There is one more issue that irks migrant workers on a daily basis: catered food. The quality is poor, and delivery schedules often mean food is left waiting for too long before they can be consumed. This, strangely, does not garner public concern as much as lorries and dorms, but it probably frustrates workers more than these two issues.

For more information about how we have spoken up on these, click the tabs below:

“Even one death in such lorry accidents is one too many.” – TWC2 Executive Director Ethan Guo in The Straits Times, 11 January 2025

TWC2 advocates for an end to the unsafe practice of ferrying migrant workers in the back of lorries. 

While we continue to shape national conversations on this problem, we do not invest a huge amount into researching or campaigning on this issue. This is because our work is led by the clients that we serve. The immediate concerns of the bulk of these workers involve wage theft, recruitment fees, and workplace injuries. Few, if any, come to us for help with unsafe transportation. 

Read more about our work on the lorry issue below:

Dormitories are not just a housing issue, but reflect a structural condition in which migrant workers’ health, dignity, and social inclusion are undermined and neglected. TWC2 has consistently advocated for improved living conditions for migrant workers, as part of a more enlightened approach towards their social needs and wellbeing. 

During COVID-19, we also ran the Small Essential Needs programme. It alleviated some of the hardship workers faced, while allowing us to highlight the systemic gaps revealed by the pandemic. 

  • 2026: TWC2 press comment on new worker dormitories
  • 2024: TWC2 analyses parliamentary replies on dormitories
  • 2024: TWC2 press comment on the Dormitory Transition Scheme
  • 2023: TWC2 voices concerns of Changi Coastal residents
  • 2023: TWC2 report on insufficient laundry provisions in dorms
  • 2023: TWC2 highlights gaps between policy and reality
  • 2021: TWC2 critiques dorm reforms
  • 2021: MOM announces new standards for dormitories
  • 2020: TWC2 presents evidence for freedom from dorms
  • 2020: TWC2 statement calling for freedom from dorms
  • 2020: TWC2 letter critiquing offshore dormitory proposal
  • 2020: TWC2 op-ed calling for dormitory reform
  • 2020: TWC2 media statement on Covid-19 situation
  • 2020: TWC2 proposes improvements to dormitory model
  • 2016: TWC2 calls for better living conditions during zika and dengue outbreaks
  • 2015: TWC2 ST letter contextualises dorm issues against other vulnerabilities

Food is a basic need, but for many migrant workers, access to adequate and nutritious meals is not guaranteed. Because kitchen facilities are not mandatory in dormitories, many workers depend on their employers or caterers for daily meals. We have seen cases where workers are given insufficient portions, poor-quality food, or meals that do not meet their cultural or dietary needs. When workers are injured or unable to work, and have no income, these vulnerabilities are exacerbated.

TWC2 has long highlighted how food insecurity affects workers’ health, recovery, and dignity. Poor nutrition can cause chronic diseases, slow healing, or add to the stress of already precarious situations. We continue to document gaps in food provision, support workers facing food insecurity, and push for a system that guarantees access to sufficient, nutritious, and culturally appropriate food. Read more below, and refer also to our advocacy on healthcare .

  • 2023: TWC2 quantitative study on catered food
  • 2023: TWC2 calls out poor handling of dormitory catered food 
  • 2016: TWC2 snapshot of different food arrangements for migrant workers
  • 2015: TWC2 statement on poor food quality for migrant workers

Prime Lodge, 2023. It is not compulsory for dormitories to include cooking facilities, leaving many workers reliant on catered food with poor nutrition.