Do You Need to Post Job Advertisements Before Singapore EP Application? (Fair Consideration Framework FCF)

The Ministry of Manpower (MOM) in Singapore requires employers to fairly consider all candidates during the Employment Pass EP application process, with particular priority given to Singapore citizens and Permanent Residents (PR). This policy is implemented through the Fair Consideration Framework (FCF), ensuring that local job seekers enjoy equal competitive opportunities in the employment market. This article will provide detailed information on the accuracy and duration requirements for job advertisement posting in EP applications, as well as other key aspects of the Fair Consideration Framework.

1. What is the Fair Consideration Framework (FCF)?

The Fair Consideration Framework (FCF) is a policy introduced by the Singapore government to ensure that employers fairly evaluate the qualifications of local job seekers when hiring foreign employees. Employers must post job advertisements through the MyCareersFuture platform and provide local job seekers with at least 14 days to apply, ensuring they can participate in fair competition. Unless specific exemption conditions are met, all EP applications must comply with this framework.

2. Job Posting Requirements

When complying with the Fair Consideration Framework, employers need to pay special attention to the accuracy and duration of job advertisements to ensure compliance with MOM requirements. Failure to meet these requirements may result in EP application rejection or delays.

1. Advertisement Accuracy RequirementsJob advertisements posted on the MyCareersFuture platform must accurately reflect the actual job responsibilities, qualification requirements, and salary levels of the position. The accuracy of advertisements directly relates to whether all candidates have been fairly considered, avoiding misleading or excluding qualified job seekers. Here are key points to pay special attention to when posting advertisements:
   • Job Description: The job description in the advertisement must be clear and accurate, covering all major responsibilities and requirements of the position, avoiding overly broad or vague language. For example, specific job tasks and expected skills should be clearly listed, rather than simply writing "Senior Manager" or "IT Professional".
   • Qualification Requirements: Qualification requirements listed in job advertisements must be reasonable and relevant to the position, and cannot include unnecessary restrictions. For example, conditions should not be set based on irrelevant factors such as race, age, gender, or nationality. All qualification requirements should be directly related to the job content, such as specific educational requirements, work experience, or technical skills.
   • Salary Range: Job advertisements must clearly list the salary range, which should be in line with market levels and match the recruited position. Salary levels should not be set too high or too low to avoid excluding certain qualified job seekers.
   • Non-discriminatory Language: The wording in advertisements must be neutral and must not contain any discriminatory content. For example, advertisements should not include language such as "males only" or "under 40 years old only", ensuring that all qualified candidates can participate in competition.
2. Job Advertisement Duration RequirementsAccording to FCF regulations, employers must post job advertisements on the MyCareersFuture platform for at least 14 days before applying for EP. This duration requirement ensures that local job seekers have sufficient time to view the position and submit applications. Insufficient advertisement duration may result in EP application rejection or requirements to repost the advertisement.
   • Continuous posting for 14 days: Advertisements must be posted continuously for 14 days and cannot be paused or deleted midway. If the advertisement duration does not reach 14 days, or if the advertisement is withdrawn during this period, MOM may determine that the employer has not complied with the fair recruitment process, resulting in invalid applications.
   • Maintaining Advertisement Visibility: After posting the advertisement, employers need to ensure that the job information remains visible throughout the entire 14-day period and can normally receive job seekers' applications. Any technical issues or situations where the position is not visible may result in the job advertisement being deemed invalid.

3. Job Advertisement Exemption Situations

Although FCF has clear advertisement posting requirements for most EP applications, employers can obtain exemptions in certain situations and do not need to comply with the 14-day advertisement posting regulations. The following are the main exemption situations:

1. Small Enterprises
   Small enterprises with fewer than 10 employees can be exempted from advertisement posting requirements. Such companies can directly apply for EP without posting job advertisements on MyCareersFuture.
2. High-Salary Positions
   For positions with monthly salaries reaching or exceeding SGD 22,500, employers do not need to post job advertisements. Such high-salary positions typically target senior management personnel or technical talents, and therefore are not subject to advertisement posting restrictions.
3. Short-term Positions
   If the employment period for the position does not exceed one month, employers can be exempted from advertisement posting requirements and directly apply for EP.
4. Internal Transfers or Multinational Company Employee Transfers
   If foreign employees are transferred to Singapore through internal transfers or global employment contracts, advertisement posting requirements can also be exempted. Such exemptions typically apply to employee transfers in multinational companies.

4. How to Ensure Job Advertisement Compliance?

1. Advertisement Accuracy Review
   Before posting job advertisements, employers should carefully review the advertisement content to ensure that job descriptions, qualification requirements, salary levels, and wording are accurate. Avoid any language that may cause discrimination and ensure that advertisement content complies with FCF's non-discrimination requirements.
2. Ensure Advertisement is Posted Continuously for 14 Days
   After posting the advertisement, ensure it remains visible for 14 consecutive days and can normally accept applications. Ensure there are no technical failures and avoid situations where the advertisement is taken down midway or information becomes invisible.
3. Maintain Recruitment Records
   Employers should maintain complete recruitment records, including resumes, interview evaluations, and the basis for recruitment decisions. These documents may be required during MOM reviews to prove the compliance and transparency of the recruitment process.

5. Summary

In the process of applying for EP in Singapore, employers must strictly comply with the requirements of the Fair Consideration Framework (FCF), especially regarding the accuracy and duration of job advertisements. Accurate job descriptions, reasonable qualification requirements, and sufficient advertisement posting duration can ensure that local job seekers have fair opportunities to participate in competition, avoiding delays in EP applications due to non-compliant advertisements.

Even when exemptions exist, employers still need to ensure the transparency and legality of the recruitment process. If you have any questions about EP applications or job advertisement posting, please feel free to contact our team. We will provide professional guidance and personalized solutions to ensure your EP application proceeds smoothly.