By Singapore’s Ministry of Manpower (MOM) is investigating around 45 companies involved in operations at Changi Airport for suspected offences under the Employment of Foreign Manpower Act 1990 (EFMA), including false declarations and illegal deployment of foreign workers. The ministry confirmed the investigation in a statement on Monday, 2 November 2026, following a recent inspection at the airport.
The inspection found Employment Pass (EP) holders deployed to perform baggage handling services, with preliminary investigations suggesting that the salaries and occupations declared to MOM for these EP holders were false. Other work pass holders were also found performing baggage handling work that differed from their declared occupations. Around 270 workers employed by SATS’ contractors and sub-contractors have so far been identified as potentially non-compliant with work pass regulations, according to MOM.
What the EFMA requires of employers
The Employment of Foreign Manpower Act 1990 is the primary legislation governing the hiring and deployment of foreign workers in Singapore. It places direct obligations on employers to ensure that every foreign employee holds a valid work pass and is deployed only in the occupation and with the employer declared to MOM.
The distinction between pass types matters because each category carries different salary thresholds, levy obligations and dependency ratio ceilings. An Employment Pass is tied to a specific employer and a specific declared role. Moving an EP holder into a different function, such as baggage handling, without updating MOM is not a minor administrative slip. It is an illegal deployment under the EFMA.
MOM’s statement that it “takes a serious view of work pass offences” reflects enforcement practice in Singapore. The ministry routinely conducts inspections across sectors, and airport operations have been a focus area because of the layered subcontracting arrangements common in ground handling and logistics.
Why subcontracting creates compliance risk
The involvement of SATS’ contractors and sub-contractors points to a structural issue familiar to HR and payroll teams in Singapore: compliance risk concentrates where labour supply chains are longest. A principal contractor may engage a vendor, which in turn engages sub-contractors, each layer adding distance between the entity that holds the work pass and the site where the worker actually performs duties.
MOM has directed SATS to strengthen its oversight of contracted companies, including verifying that foreign workers are deployed in accordance with their work passes and rectifying compliance deficiencies. The ministry has also issued an advisory to other companies involved in SATS’ operations.
For HR leaders, the practical lesson is that contractual indemnities from vendors do not eliminate regulatory exposure. MOM can investigate any employer in the chain, and the reputational and operational consequences of an enforcement action can extend well beyond the specific contractor found to be non-compliant.
Penalties and enforcement exposure
The EFMA sets out specific penalties for the offences under investigation. Making a false declaration in a work pass application carries a fine of up to $20,000, imprisonment of up to two years, or both. Employers who illegally deploy a foreign employee may face a financial penalty of up to $10,000 per worker, and may also be barred from hiring work pass holders.
The scale of the current investigation, involving around 270 workers, means the aggregate financial exposure for the companies concerned could be substantial if breaches are established. MOM has said it will take enforcement action where breaches of the EFMA are confirmed.
| Offence | Maximum penalty |
|---|---|
| False declaration in work pass application | Fine up to $20,000, imprisonment up to two years, or both |
| Illegal deployment of foreign employee | Financial penalty up to $10,000 |
| Breach of EFMA by employer | May be barred from hiring work pass holders |
MOM has temporarily allowed the affected employees to continue working while investigations continue, a measure that avoids immediate disruption to airport operations but does not signal any relaxation of the underlying compliance requirements.
What HR and payroll teams should review now
The Changi Airport case highlights three areas where HR and payroll functions in Singapore should conduct immediate internal checks.
First, verify that every foreign employee’s actual job duties match the occupation declared on their work pass. This is not a one-time exercise at onboarding. Role changes, secondments and site reassignments can all create mismatches that go unnoticed until an inspection occurs.
Second, audit contractor and vendor arrangements. Companies that rely on sub-contractors for operational functions should require evidence of work pass validity and declared occupations for every foreign worker deployed on their sites, not just a contractual promise of compliance.
Third, review salary declarations. EP eligibility depends on meeting minimum salary thresholds, which CNA reported as generally at least S$5,600 per month for EP candidates, with higher requirements for older applicants and those in financial services. Declaring a salary that is not actually paid, or paying a lower amount while declaring a higher one to meet the threshold, is a false declaration under the EFMA.
MOM encourages members of the public to report suspected work pass infringements through its Report an Infringement eService, with all information kept strictly confidential. Employers should assume that non-compliance can be detected through inspections, worker reports or internal audits, as SATS has said its own routine internal audit identified the irregularities that led to the current investigation.
The investigation remains ongoing, and MOM has said it will continue to conduct checks to ensure compliance with work pass requirements. For HR and payroll leaders, the immediate priority is to confirm that current practices would withstand the same scrutiny.
Sources: CNA, Ministry of Manpower, The Star
Photo: FEMA - 37138 - Federal airport workers in California by Adam Dubrowa, Public domain
