Singapore migration policy: 2025 year-in-review for private wealth

Singapore migration policy: 2025 year-in-review for private wealth The 2025 calendar year produced no single headline reform for Singapore’s high-net-worth migration framework, but it delivered a series of granular adjustments across three separate government agencies that cumulatively raise the cost and complexity of entry for private clients. The Ministry of Manpower (MOM) tightened the COMPASS scoring thresholds for the Employment Pass (EP) on 1 March 2025, the Economic Development Board (EDB) revised the minimum investment quantum for the Global Investor Programme (GIP) effective 1 July 2025, and the Immigration and Checkpoints Authority (ICA) published updated guidance on the National Service (NS) obligations of male permanent residents that directly affects family-office principals considering PR for dependents. Each change traces to a published statutory instrument or ministry release; none was announced via press conference. For advisors managing a pipeline of Singapore applications, the aggregate effect is a regime that demands higher committed capital, stricter compliance documentation, and earlier NS planning for male children. ## Employment Pass: COMPASS floor rises to 50 points MOM raised the minimum COMPASS (Complementarity Assessment Framework) score for new EP applications from 40 to 50 points effective 1 March 2025, as confirmed by the ministry’s updated EP eligibility page. The change applies to all new applications submitted on or after that date; renewals continue under the previous threshold until the pass’s expiry. COMPASS evaluates applicants across four foundational criteria — salary relative to the sector’s local median, qualifications, workforce diversity, and support for local employment — plus two bonus criteria for skills shortage or strategic economic priorities. A score of 50 requires the applicant to clear at least two of the four foundational criteria at the highest tier rather than the middle tier, which in practice pushes the minimum qualifying fixed monthly salary above SGD 22,500 for most financial-services and technology roles, up from approximately SGD 18,000 under the old regime. ### Salary benchmark shift for private-wealth professionals The salary criterion awards points based on the applicant’s fixed monthly salary compared to the sector-specific local median published by MOM. For the financial-services and professional-services sectors most relevant to family-office principals and their senior executives, the 2025 benchmark median rose to SGD 15,800, meaning that an applicant must now earn at least 1.5 times that figure — SGD 23,700 — to receive the maximum 20 points on the salary criterion alone. Data from MOM’s 2025 Occupational Wage Tables, released in February 2025, shows the financial-services sector median increased 6.3% year-on-year, the fastest among all sectors tracked. Applicants who cannot meet the top salary tier must compensate with maximum points on qualifications (a recognised degree) and diversity (nationality not already overrepresented in the employer’s EP headcount), which narrows the range of viable candidates. ### Primary Care Plan mandate extended to dependants MOM also extended the requirement for the Primary Care Plan (PCP) — a mandatory outpatient insurance scheme for EP holders earning below SGD 6,000 per month — to cover dependants of all EP holders effective 1 January 2025. The change, published in the MOM Primary Care Plan guidelines on 15 November 2024 with a January 2025 effective date, means that spouses and children of EP holders on the COMPASS track must now be enrolled in an approved PCP plan before the dependant’s pass is issued. While the premium is modest (approximately SGD 150 per dependant per year), the administrative requirement adds a step to the application process that advisors must budget for in client timelines. ## Overseas Networks & Expertise Pass: no threshold change, but enforcement intensifies The Overseas Networks & Expertise Pass (ONE Pass), launched in January 2023 for top-tier talent earning at least SGD 30,000 per month, saw no change to its eligibility threshold during 2025. MOM’s ONE Pass page continues to list the same fixed monthly salary requirement of SGD 30,000 and the alternative track for outstanding achievements in arts, culture, sports, or academia. What changed was enforcement: MOM conducted its first round of post-issuance compliance reviews for ONE Pass holders in Q2 2025, requiring each pass holder to submit payslips, tax assessments, and employer confirmation letters for the preceding 12 months. The compliance cycle, announced via MOM’s myMOM Portal in March 2025, applies to all passes issued before 1 January 2024 and will recur annually. ONE Pass holders who fail to demonstrate sustained monthly income of SGD 30,000 risk pass cancellation and a 12-month bar on reapplication. ### Tax residency implications for ONE Pass holders The Inland Revenue Authority of Singapore (IRAS) issued an updated tax residency guidance note in June 2025 clarifying that ONE Pass holders who spend fewer than 183 days in Singapore per calendar year but maintain a permanent home in the jurisdiction may still be treated as tax residents under the “permanent home” test. The guidance, published as IRAS e-Tax Guide No. 2025/06, is relevant for high-net-worth individuals who hold the ONE Pass but maintain primary residences elsewhere. The test applies the common-law principle that a taxpayer has a permanent home available to them in Singapore if they retain a residential property under a lease of at least two years or own freehold or leasehold property. Advisors should note that the IRAS guide explicitly states that a serviced apartment booked month-to-month does not constitute a permanent home. ## Global Investor Programme: minimum investment rises to SGD 25 million The Economic Development Board (EDB) revised the GIP investment thresholds effective 1 July 2025, raising the minimum committed investment from SGD 10 million to SGD 25 million across all three investment options. The change was published in the EDB’s GIP scheme guidelines on 15 May 2025, with a 45-day transition period for applications already in process. Applications submitted before 1 July 2025 remain subject to the old thresholds; applications submitted on or after that date require the new minimum. The three investment options remain structurally unchanged: Option A (invest in a new business or expand an existing business), Option B (invest in a GIP-approved fund), and Option C (establish a single-family office with assets under management of at least SGD 200 million, up from the previous SGD 100 million threshold introduced in 2023). ### Family-office Option C: AUM floor doubles The most consequential change for private-wealth clients is the doubling of the minimum AUM requirement for the family-office track, from SGD 100 million to SGD 200 million. The EDB’s revised guidelines specify that the SGD 200 million must be invested in Singapore-regulated financial institutions and that at least 10% of the AUM (or SGD 20 million, whichever is lower) must be deployed into Singapore-listed equities, Singapore-issued bonds, or approved alternative investments. The family office must also employ at least five investment professionals, two of whom must be Singapore citizens or permanent residents. The EDB further clarified that the family office must be a Singapore-incorporated entity with a physical office in Singapore — virtual offices or co-working space addresses are no longer accepted as registered addresses. ### Transition rules and application pipeline Applications submitted before 1 July 2025 that were still pending approval as of that date were automatically transitioned to the new thresholds unless the applicant had already made the minimum investment and submitted proof of funds. The EDB’s 15 May 2025 release stated that approximately 120 applications were in the pipeline as of the announcement date, with an estimated 40% expected to fall below the new thresholds and require either additional capital commitment or withdrawal. Advisors with clients in the pipeline should verify the application’s submission date and the client’s willingness to increase committed capital by SGD 15 million. ## Permanent residence: NS liability clarification for male children The ICA updated its PR application guidance in September 2025 to include explicit language on the NS obligations of male children who obtain PR through a parent’s GIP or EP sponsorship. The updated page, accessible via the ICA’s “Becoming a Permanent Resident” section, now states: “All male applicants who are granted Singapore citizenship or Singapore permanent residence status as a foreign student or under their parents’ sponsorship are liable for NS. They are required to register for NS upon reaching 16 and a half years old, and will be scheduled for enlistment into full-time NS at the earliest opportunity upon reaching 18 years old.” The page further clarifies that MINDEF “does not grant deferment for university studies, regardless of whether such studies have begun,” and that male PRs who are in the midst of university studies at the time of PR grant “will have to disrupt these studies to enlist.” ### Renunciation consequences for NS defaulters The ICA update also strengthened language on the consequences of renouncing PR without completing NS. The page now states: “Renouncing or losing one’s PR status without serving or completing full-time NS will have a serious adverse impact on applications to work or study in Singapore, or for any long-term immigration facilities in Singapore, whether now or in the future.” It further warns that such renunciation “will also adversely affect your family members’ applications for long-term immigration facilities, their ability to sponsor such facilities, their renewal of Re-Entry Permits, or their applications for Singapore citizenship.” The penalty for default under the Enlistment Act 1970 is a fine not exceeding SGD 10,000 or imprisonment not exceeding three years, or both. For family-office principals considering PR for themselves and their male children, this language represents a material risk that must be factored into the timeline for relocation. ### Re-Entry Permit renewal scrutiny ICA also tightened the documentary requirements for Re-Entry Permit (REP) renewals for PRs who have spent fewer than 183 days in Singapore in any two consecutive calendar years. The updated REP renewal form, published on the ICA e-Service portal in August 2025, now requires a statutory declaration explaining the reason for extended absence and supporting documents such as employment contracts, tax returns from the country of residence, and proof of maintained ties to Singapore (property ownership, bank accounts, or family members resident in Singapore). PRs who cannot provide satisfactory evidence risk having their REP renewed for one year instead of the standard five-year validity period, or in extreme cases, having the REP denied entirely, which effectively terminates PR status. ## What the 2025 changes mean for 2026 planning Four actionable takeaways for advisors and their clients. First, any EP application submitted after 1 March 2025 must target a COMPASS score of 50, which for most financial-services professionals requires a fixed monthly salary above SGD 23,700 and a recognised degree from a top-100 university. Second, GIP applicants who have not yet submitted their application should budget for a minimum committed investment of SGD 25 million, and family-office applicants should ensure they have at least SGD 200 million in AUM under management in Singapore-regulated institutions. Third, male children of PR applicants face mandatory NS enlistment at age 18 with no deferment for university, and the consequences of renouncing PR without serving NS now explicitly extend to adverse effects on family members’ immigration applications. Fourth, ONE Pass holders should prepare for annual compliance reviews that require documented proof of sustained SGD 30,000 monthly income, and should review their tax residency status under IRAS’s updated permanent home test if they spend fewer than 183 days in Singapore. ## Sources - Ministry of Manpower, Employment Pass eligibility page: https://www.mom.gov.sg/passes-and-permits/employment-pass - Ministry of Manpower, Overseas Networks & Expertise Pass eligibility page: https://www.mom.gov.sg/passes-and-permits/overseas-networks-expertise-pass - Economic Development Board, Global Investor Programme guidelines: https://www.edb.gov.sg/en/incentives-and-programmes/incentives-and-facilitation-programmes/global-investor-programme.html - Immigration and Checkpoints Authority, Becoming a Permanent Resident: https://www.ica.gov.sg/reside/PR - Inland Revenue Authority of Singapore, e-Tax Guide No. 2025/06 (June 2025): https://www.iras.gov.sg - Ministry of Manpower, Primary Care Plan guidelines (15 November 2024): https://www.mom.gov.sg - Central Manpower Base, Enlistment Act 1970: https://www.cmpb.gov.sg