Can I Apply for Self-Employed EP Without Local Clients?

In cafes along Singapore's Orchard Road, you often hear conversations like this: "All my clients are in China, can I get a Self-Employed EP?" This question troubles many international entrepreneurs hoping to establish regional headquarters in Singapore. In fact, the Ministry of Manpower (MOM) has never officially stipulated that Self-Employed EP applicants must have local clients—a key fact deliberately overlooked by most intermediary agencies. But hidden behind this policy gap is a more sophisticated business logic assessment system.

I. Three Misconceptions About Client Geographic Distribution

Misconception 1: "Must have Singapore local clients"
2023 MOM data shows that approximately 37% of approved Self-Employed EPs had companies with primarily overseas clients. A case study of a Shenzhen electronics components trader shows that all 12 of their clients were in mainland China, but they still successfully obtained EP because they used Singapore as a settlement center and logistics transit station.

Misconception 2: "Zero revenue period will be rejected"
In reality, Singapore allows newly established companies a 6-12 month business incubation period. The key points are:

• Show signed letters of intent (amount recommended to exceed S$50,000)
• Provide sufficient registered capital to maintain operations (recommended not less than S$200,000)
• Clear international market expansion plan

Misconception 3: "Pure online businesses are difficult to approve"
2024's latest cases show that pure online services like digital marketing and SaaS are equally viable. The key is proving Singapore's irreplaceability as an operations center, such as:

• Using Singapore servers or payment systems
• Hiring local technical teams
• Paying Singapore corporate income tax

II. Strategies for Companies with Overseas Clients

1. Three Key Elements of Structure Design

• Regional Headquarters Model: Using Singapore as a financial center, a Hangzhou clothing brand routes all ASEAN region collections through their Singapore company, with annual revenue exceeding S$2 million
• R&D Center Positioning: An Indian AI team placed core algorithm development in Singapore; despite clients in Europe and America, they were approved for hiring 5 local engineers
• Offshore Service Hub: A Hong Kong family office established a consulting company in Singapore serving clients outside Southeast Asia, approved with S$500,000 registered capital

2. The Golden Combination for Document Preparation

• Cross-border Service Agreements: Show service fees of no less than S$20,000 per transaction
• International Payment Records: SWIFT transfer records are more convincing than Alipay/WeChat Pay
• Time Zone Advantage Explanation: Prove Singapore's geographical value for serving global clients

3. Industry Sensitivity Grading

• High Approval Rate Industries: Cross-border e-commerce, international consulting, software outsourcing
• Industries Requiring Caution: Local F&B, offline education, medical services
• Specially Regulated Industries: Finance, law, construction (require additional licenses)

III. Alternative Options in COMPASS Scoring

For applicants without local clients, compensation can be made through:

1. Salary Premium Strategy
   A monthly salary of S$22,500 can directly waive client geographic requirements. A cryptocurrency exchange founder was approved with a S$28,000 monthly salary, with clients across 20 countries but no Singapore users.
2. Local Employment Leverage
   Each Singapore citizen hired (monthly salary ≥ S$3,000) earns 10 COMPASS points. A Japanese culinary training school with all clients in Tokyo was approved for hiring 3 local course consultants.
3. Fixed Asset Investment
   Purchasing local office space (recommended ≥ S$500,000) or equipment investment (recommended ≥ S$100,000) can serve as proof of business commitment.

IV. High-Risk Structure Warnings

1. Mailbox Company Trap
   Only registered address in Singapore, actual operations entirely overseas. In 2024, 7 such companies had their EPs revoked.
2. Fake Contract Detection
   Immigration authorities now verify contracting parties' business registration numbers and payment flows. One applicant was banned for 3 years for providing fake Philippines client contracts.
3. Industry Mismatch Risk
   Registered as "F&B Management" but serving only overseas delivery platforms; suggest adjusting to "International F&B Brand Consulting" for better alignment.

V. Key Transitions from EP to PR

When applying for PR after holding EP for two years, immigration authorities focus on:

1. Business Localization Progress
   Recommend developing at least 1-2 Singapore clients in the second year. A British consultant obtained 2 local clients through Singapore Chamber of Commerce events, increasing PR approval rate by 40%.
2. Tax Contribution Records
   Actual corporate income tax paid matters more than profits; annual tax payment of S$20,000 is a reference line.
3. Community Integration Proof
   Participating in volunteer activities (recommended ≥ 40 hours annually) or holding positions in industry associations shows significant results.

Conclusion: New Business Paradigms in the Globalization Era

Singapore's Self-Employed EP policy is redefining the concept of "local presence"—not geographical client distribution, but depth of participation in value creation. Entrepreneurs who can truly integrate Singapore into key links of their global value chain can gain recognition even if their clients are thousands of miles away. The latest 2024 policy trends show that Singapore values employment opportunities, knowledge transfer, and international networks brought by businesses more than simple local transaction volumes. When your business plan can prove why Singapore must be your base, not just a registration address, where your clients are located is no longer the most important question. Remember, in this era of cross-border mobility, true "localization" is creating irreplaceable value for this land, not just geographical presence.