Case Study 7: Securing an EP for a Key Director After Two Appeals

Client Background

We were approached by a newly incorporated company in early 2025 seeking to hire an Indonesian national as a Director. The individual was considered key to the business, and the company was keen for him to commence operations in Singapore as soon as possible.

The Problem or Challenge

As the company was newly established, it had limited operational history and early-stage funding. As a result, the initial Employment Pass (EP) application was subject to heightened scrutiny by the Ministry of Manpower (MOM).

This was compounded by additional vetting procedures that may apply to applicants of certain nationalities.

The first EP application was rejected. While disappointing, this outcome was not unexpected given the early-stage nature of the business and the incomplete supporting documentation available at the time.

Rejections involving new companies are common where MOM has concerns around business substance, salary positioning, or the company’s ability to support the proposed role.

As outlined in our guide on how to apply for an Employment Pass in Singapore, applications involving newly incorporated companies and foreign directors are often subject to closer scrutiny.

 Our Approach

We advised the company early on about the potential roadblocks and timeline. AftWe advised the company early on about the potential risks, documentation gaps, and realistic timelines involved. Following the initial rejection, we continued working closely with both the employer and the applicant to strengthen the application.

A first EP appeal was filed with a clarified job scope and improved hiring justification. However, this appeal was unsuccessful.

In practice, the success of an Employment Pass appeal often depends on whether the revised submission meaningfully addresses MOM’s original concerns, rather than simply repeating earlier arguments.

For the second EP appeal, we restructured the submission entirely, focusing on:

• A clearer and more detailed business model
• Updated financial projections and supporting documents
• Stronger emphasis on the applicant’s role as essential to the company’s operations

Throughout the process, we provided detailed guidance to ensure the appeal aligned with MOM’s assessment criteria and expectations.This included addressing broader factors such as business credibility, role justification, and how the application would likely be viewed under Singapore’s COMPASS framework.

The Outcome

The second Employment Pass appeal was approved. The EP was issued the following month, allowing the company to proceed with its business activities with the key individual in place. Both the employer and the applicant expressed appreciation for the continued support and strategic direction provided.

What This Case Shows

Hiring a foreign director through a newly formed company in Singapore is possible, but it requires careful planning, realistic expectations, and a willingness to address MOM’s concerns with clarity and substance.

Even where an initial application and appeal are unsuccessful, a well-prepared subsequent appeal can succeed when supported by a solid business framework and credible documentation.

For another real-life scenario involving a new company director, read our case study on Employment Pass Eligibility Check for Business Owner Approved in Under Two Weeks.

Want to Appeal a rejected EP Application?

If your Employment Pass application has been rejected, or if you are a new company planning to hire a foreign director, we can help you assess your options and prepare a clear and well-supported application or appeal through our Singapore work pass services. Book a 20-minute consultation to understand your options and next steps.