The True Cost of a Bad Hire: Singapore Market Analysis 2025
10 Mar 2025
12
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Singapore's most consequential piece of HR legislation is being rewritten — and most employers are not watching. In August 2025, the tripartite partners formed a Tripartite Workgroup (TWG) to review the Employment Act 1968, Singapore's principal labour law. That workgroup told the country it expects to submit its recommendations to the Government by the second half of 2026. We are now in that window.
No draft text has been published. No amendment bill has been tabled. But the direction of travel is on the public record, and the gap between "recommendations submitted" and "obligations in force" is exactly the window in which well-run companies get their house in order. This article sets out what has actually been announced, what remains speculation, and the seven practical moves Singapore employers should make in the next two quarters.
The Employment Act is Singapore's main labour law. It sets the basic terms and conditions of work for employees under a contract of service — covering local and foreign employees, full-time, part-time, temporary and contract staff, and those paid hourly, daily, monthly or by piece rate. Seafarers, domestic workers and public officers sit outside it and are governed by other legislation.
On 4 August 2025, MOM announced that the tripartite partners had formed a Tripartite Workgroup to review the Act. Members agreed on the scope and focus areas of the workgroup's work at that first meeting. According to MOM, the TWG will "study and develop recommendations to update the EA to account for the changing labour force profile, evolving forms of work, and challenging economic landscape," including "ensuring adequate protections for different groups of workers, and streamlining the EA to reduce regulatory and compliance costs for businesses."
Three stated objectives guide the work:
That third objective is the one employers should read twice. It signals that competitiveness is an explicit design constraint, not an afterthought — which is a meaningful reassurance for firms bracing for a purely protective rewrite.
The composition of a tripartite workgroup is usually a reliable guide to what will and will not be on the table.
The TWG is co-chaired by Mr Ng Chee Khern, Permanent Secretary at MOM; Ms Cham Hui Fong, Deputy Secretary-General of NTUC; and Mr Kuah Boon Wee, Vice President of SNEF. Its 17-member roster spans MOM's Workplace Policy and Strategy, Labour Relations and Workplaces, and Legal Services divisions; senior NTUC leaders including Assistant Secretary-General Patrick Tay; SNEF industrial relations panel members with day-to-day HR responsibility at large Singapore employers; and — importantly — representation from the Singapore Business Federation and the Association of Small & Medium Enterprises.
The SBF and ASME seats matter. SME compliance capacity has been a recurring theme in Singapore employment policy, and their presence signals the workgroup is alive to the fact that a well-intentioned obligation which a 5,000-person multinational absorbs easily can be genuinely burdensome for a 20-person firm without a dedicated HR function.
In their public statements at the workgroup's formation, the co-chairs set out distinct priorities. Mr Ng described the Act as "the cornerstone of Singapore's labour legislation, establishing trust between employers and workers." Ms Cham said NTUC would "champion lower-wage workers and workmen as well as PMEs whose employment and work may be affected by socio-political, economic and technological factors." Mr Kuah noted that "workplace norms and worker expectations are changing amidst a challenging economic landscape and stagnating workforce growth."
Read together, those three statements sketch the likely negotiation: PME protections and lower-wage worker protections pushed by the labour side, flexibility and cost containment pushed by the employer side, and MOM holding the line on labour market competitiveness.
Before you can assess what might change, you need an accurate picture of what currently applies. Many Singapore employers are working from a pre-2019 mental model. Here is the current position.
The 2019 amendments were the last major expansion of scope. From 1 April 2019, the Act was extended to cover all employees for core provisions — including managers and executives earning more than $4,500 a month, who had previously been excluded — and wrongful dismissal claims moved from the Minister for Manpower to the Employment Claims Tribunals. Seven years on, the labour market has changed again.
MOM named three drivers. Each has an evidence base an employer can point to.
Singapore's workforce is ageing and its growth is slowing — the "stagnating workforce growth" SNEF's Mr Kuah referred to. The policy response is already visible in adjacent legislation: under the Retirement and Re-employment Act, from 1 July 2026 the minimum retirement age is 64 years, and the re-employment age was raised from 68 to 69 on the same date — a change MOM describes as helping older workers who wish to continue working as long as they are willing and able to. An Employment Act framed around shorter working lives needs revisiting for a workforce where many now work into their late sixties.
Both increases are steps along a longer path. The Tripartite Workgroup on Older Workers recommended in its 2019 report that the retirement and re-employment ages rise “to 65 and 70 respectively in small steps by 2030.” That is a tripartite recommendation rather than a legislated schedule — the Government has moved in line with it so far, but each step has been enacted separately, so employers should plan against what is actually in force rather than against the 2030 end-point.
Term contracts, project-based engagements, platform work and hybrid arrangements have all grown. Singapore has already legislated separately for platform workers, and the Act itself now sits alongside a growing body of tripartite advisories — on term contract employees, on flexible work arrangement requests — that shape practice without carrying the force of statute. One plausible thread of the review is where the boundary between guideline and law should sit.
The labour market has been resilient but uneven. MOM's advance release for the second quarter of 2026 recorded total employment growth of 10,700 — the 19th consecutive quarter of growth — with the overall unemployment rate at 2.0% in June 2026 and the resident rate at 2.9%. At the same time, retrenchments rose from 3,830 in 1Q 2026 to 4,500 in 2Q 2026, taking the incidence of retrenchment from 1.6 to 1.9 per 1,000 employees, concentrated in outward-oriented sectors and driven primarily by business restructuring. MOM noted those levels remain well below those typically seen in a downturn.
Forward-looking indicators improved through June. The share of firms expecting to hire over the following three months rose from 40.6% in May 2026 to 43.9% in June, the share expecting to raise wages rose from 23.7% to 29.3%, and the share expecting to retrench fell from 3.2% to 2.7%.
For employers, this is a workforce that is simultaneously hard to grow and being actively restructured — precisely the conditions in which employment law gets scrutinised.
Discipline matters here. A great deal of commentary about the Employment Act review circulating in HR forums is inference rather than announcement.
What is on the public record: the workgroup's existence, composition, three guiding objectives, stated focus areas, commitment to consult employers and employees, and the 2H 2026 timeline for submitting recommendations to Government.
What is not on the public record: any specific proposed change to leave entitlements, overtime thresholds, Part 4 salary caps, notice periods, or transfer-of-undertaking provisions. Several law firms have published views on what a review of this kind could touch. Those are informed professional predictions, not policy.
There is also a sequencing point worth internalising. Recommendations submitted in 2H 2026 do not become obligations in 2H 2026. Government must accept them, MOM must draft an amendment bill, Parliament must pass it, and commencement dates must be set — often with transitional periods. The 2018–2019 cycle is instructive: the amendment bill's media release was issued in November 2018 and the changes took effect on 1 April 2019, giving employers a defined runway.
The Employment Act review is not the only thing landing. Employers planning HR work for the next 18 months should hold these together.
Notice the common thread. The Workplace Fairness Act makes the quality of your written record the decisive factor in defending an employment decision. The Employment Act review may change what the record has to show. Both point to the same preparation work.
Establish, employee by employee, who is covered by the core Act, who falls under Part 4, and who is a workman versus a non-workman versus a manager or executive. MOM publishes a Part 4 self-assessment tool. Firms that get this wrong tend to get it wrong systemically — an entire job family misclassified — which turns a small error into a large exposure.
Key employment terms and itemised payslips are already statutory obligations, and they are the documents most likely to be affected by any amendment. Move to a templated, version-controlled KETs format now, so that if a change lands, you are updating one master template rather than 200 individually drafted letters.
For anyone covered by Part 4, hours of work, rest days and overtime records need to be accurate and retrievable. If your records currently live in a spreadsheet maintained by one person, that is a single point of failure — and the first thing a dispute will expose.
Under the WFA dispute resolution framework, an individual who experiences workplace discrimination should first raise the matter internally through the firm's grievance handling process, with mediation before adjudication. That means a functioning internal channel is not optional infrastructure — it is the first line of defence. TAFEP runs clinics and briefings on grievance handling and fair recruitment for exactly this purpose.
With the retirement age at 64 and re-employment age at 69 since 1 July 2026, review your retirement policy wording and re-employment assessment criteria. MOM's guidance is specific on timing: begin discussions not less than 6 months before an employee turns 64, offer eligible employees a re-employment contract at least 3 months before their retirement date, and inform those who do not qualify at least 3 months ahead. Note also that transitional retirement ages of 62 and 63 still apply to earlier birth cohorts, so a single blanket policy will not be correct for your whole workforce. Employers of Singaporean workers aged 60 and above earning below $4,000 a month may be eligible for wage offsets of up to 7% under the Senior Employment Credit.
The TWG has said it will consult and engage stakeholders, including employers and employees. If your firm is a member of SNEF, SBF or ASME, those are your channels. Employers who want the "reduce regulatory and compliance costs" half of the mandate taken seriously need to supply concrete examples of where compliance is disproportionately costly.
Someone in your organisation should own this file, monitor MOM's newsroom, and diarise a review for each quarter through 2027. Regulatory surprises are almost always ownership failures rather than information failures — the announcement was public; nobody was watching.
SMEs. The presence of ASME and SBF on the workgroup is a genuine signal that proportionality is in scope. Practically, though, SMEs carry the most risk from a coverage audit because job titles and actual duties drift apart fastest in small firms. Start with classification, not policy documents.
Multinationals with regional HR. The risk here is the opposite: global policy templates that assume a different legal baseline. Singapore's sick leave structure — 14 days outpatient and up to 60 days hospitalisation, inclusive — does not map cleanly onto most global standards. Confirm your Singapore-specific addenda are current.
High-growth and startup employers. Rapid hiring plus informal documentation is the classic exposure profile. The Workplace Fairness Bill requires firms to have grievance handling processes, and MOM has noted that 6 in 10 firms already have formal procedures to manage workplace discrimination. If yours is in the other four, close that gap now rather than in 2027.
Employers with large Part 4 populations — manufacturing, construction, logistics, F&B, cleaning and security. You have the most to gain or lose from any change to hours-of-work rules or salary thresholds. This is the group that should be most active in consultation.
The Employment Act review is the most significant piece of Singapore employment policy currently in motion, and it is moving quietly. Recommendations are expected to reach Government during the second half of 2026; from there, drafting, debate and commencement will follow on a timeline the Government has not yet set.
That gap is a gift. It gives employers time to do the unglamorous work — classification, contracts, key employment terms, working-time records, grievance processes — that will make any eventual change a matter of updating templates rather than rebuilding an HR function under deadline. The firms that will find 2027 comfortable are the ones treating the second half of 2026 as preparation time.
If you would like a structured review of your employment documentation against the current Act, and a plan for absorbing whatever the review recommends, our team works with Singapore employers on exactly this.
This article draws on primary sources published by the Ministry of Manpower, including the press release on the first meeting of the Tripartite Workgroup on the Employment Act Review (4 August 2025), the Labour Market Advance Release for the second quarter of 2026 (31 July 2026), MOM's Employment Act coverage, annual leave, sick leave, retirement, re-employment and amendment guidance pages, and the Workplace Fairness (Dispute Resolution) Bill factsheet (14 October 2025), together with TAFEP's Workplace Fairness resource page. Information is current as at 22 August 2026. Where a specific change to the Employment Act has not been announced, this article says so rather than speculating. Employers should verify the position at the time of reading, as timelines and thresholds may change. This article is general information and not legal advice.