Does payroll software actually file, or just calculate?

Every payroll vendor’s site says something like “CPF, IR8A and AIS, handled.” It is rarely a lie, but it is rarely the whole answer either. Some products genuinely submit to CPF Board and IRAS on your behalf, through a government API. Most compute the numbers correctly and hand you back a file, a bank upload, a CPF EZPay record, an IR8A return, that you or someone on your team still has to log in and submit. Both are honestly “payroll software”. Only one of them removes a step from your month.

This is worth settling before you sign, not after the first bonus run reveals which one you bought. It matters more than the feature comparison, because neither version moves the legal liability off your desk.

Who stays liable if the software gets it wrong?

Legal liability for CPF and IRAS filings does not change based on which software you buy, and that is the fact most buyers get backwards. Section 68 of the Income Tax Act puts the annual employment-income return on “every employer”, not a software vendor. Section 94 sets the general penalty for not filing at all: a fine of up to S$5,000, and up to six months’ imprisonment in default of payment. Section 95 covers a negligent incorrect return specifically, at a penalty equal to double the tax undercharged, and on its wording that reaches an employer’s own required return. It is the tier that fits an honest data error rather than deliberate evasion. The CPF Act’s definition of employer is written broadly enough to also catch “any manager, agent or person responsible for the payment of wages… on behalf of an employer,” so handing the computation to a vendor does not narrow who can be pursued. It widens the list of people who could be, without removing the company from it.

Neither CPF Board nor IRAS has published a sentence stating “you remain liable if you outsource.” That is not a regulator’s quote, it is the plain consequence of how the statutes above are written. We cover it in full, alongside the wider four-way choice between in-house, software, a bureau and full outsourcing, in payroll in-house, software or outsourced, and against a bureau specifically in payroll bureau vs software. Here, the short version is enough: whatever a vendor’s product does, the CPF Submission Number and the IRAS filing sit under your UEN, not theirs, and the deadlines on the payroll compliance calendar do not move because a vendor is involved.

What “file” can actually mean

“Files with CPF and IRAS” hides three different products, and a vendor’s marketing page rarely says which one you are looking at.

The first is computation only. The software calculates CPF, SDL and IR8A figures correctly, on the same Ordinary Wage and Additional Wage rules CPF Board applies, but stops there. You still key or upload the result yourself, much as submitting CPF through CPF EZPay directly would, just with less arithmetic to get wrong.

The second is file generation. The software produces a file in the format CPF EZPay or myTax Portal expects, a CPF contribution file, a bank GIRO file, an IR8A record, ready to upload. Someone on your team still logs in and submits it; the software has removed the building of the file, not the act of filing it.

The third is direct submission. The software is integrated with a government system, usually through the One-Stop Payroll initiative or IRAS’s own AIS direct-API channel, and the numbers reach CPF Board or IRAS without anyone downloading and re-uploading anything.

A concrete version of why this matters: a bonus month lands, the software computes the correct CPF figure down to the cent, generates a file, and stops. If nobody logs into CPF EZPay before the last day of the month, the number was right and the filing still did not happen. That gap is invisible in a sales demo, because a demo never simulates the week your usual payroll person is on leave.

All three tiers are honestly described as software that “handles” CPF and IR8A. Only the third actually files for you. Ask a vendor directly which of the three you are buying; the answer changes what your own team still has to do every month, and how much of that disappears if the person who currently does it is unavailable.

One-Stop Payroll: what it genuinely lets software submit

One-Stop Payroll is the answer to “is there a real government channel for this,” and it is worth understanding precisely, because most comparisons either ignore it or oversell it.

It is a joint effort by IRAS, the CPF Board, MOM and GovTech, whose microsite soft-launched in August 2024. OSP-ready payroll software can submit three things from a single platform, via API, rather than three separate logins: annual salary data to IRAS under the Auto-Inclusion Scheme, monthly CPF contribution information to CPF Board, and responses to MOM’s Occupational Employment Dataset and labour market surveys.

That is a genuinely useful reduction in logins for the three things it covers, and the annual AIS submission itself is worth reading our AIS enrolment article for if you have not filed one before. It is not a general payroll portal. Based on IRAS’s and OSP’s own descriptions, it does not extend to IR21 tax clearance for a departing foreign employee, the Skills Development Levy, itemised payslip issuance, or bank disbursement of salaries; none of those are named among what it submits. A vendor whose product is genuinely OSP-ready has covered a real, checkable piece of ground, not the whole compliance surface.

You reach One-Stop Payroll through your payroll software, not through a portal you log into directly, in the same way CPF EZPay and the AIS direct-API channel sit alongside it as recognised submission routes on IRAS’s own AIS pages. A vendor listing of OSP-ready products exists on the OSP website itself. Read it for what it is: a listing is evidence of integration, not an endorsement of quality.

What even capable software still leaves you to check

Buying genuinely OSP-ready, AIS-compliant software answers the arithmetic and, for CPF and AIS specifically, the submission question. It does not automatically answer the rest.

Our own check of Singapore HR and payroll software covered eight platforms against their own public documentation and found real, named gaps that varied product to product: one does not support the Appendix 8A or 8B forms for benefits-in-kind and stock options, which still have to go through myTax Portal by hand; another’s bank file works only for GIRO, not FAST; a third generates a bank file at all, but disbursement itself still means uploading that file to the bank’s own portal rather than the software paying anyone directly.

None of that makes the products bad. It makes “payroll software” a wider category than the marketing suggests, closer to a set of ingredients that varies by product than a single guaranteed feature set. Skills Development Levy shows the same pattern in miniature: CPF EZPay, and most software built on the same logic, auto-computes SDL for Singapore Citizens and Permanent Residents, but SDL for a foreign employee is commonly a manual entry, because SDL, unlike CPF, is payable for every employee working in Singapore, foreign staff included.

Nor does capable software close the Additional Wage ceiling gap on its own. CPF’s own guide is explicit about CPF EZPay’s auto-computation: “It does not impose a cap on CPF contributions that exceed the additional wage ceiling.” Software built on the same computation logic inherits the same blind spot unless a vendor has specifically built a check for it, which is exactly the kind of thing worth asking about rather than assuming.

The buyer’s checklist before you sign

Ask these before a contract, not after, and get the vendor to answer in specifics, not marketing language:

• Does it submit directly to CPF Board and IRAS through an API, generate a file you still upload, or only calculate the figures? Get the vendor to name which.
• Is it genuinely OSP-ready, or on IRAS’s own list of AIS-compliant software, rather than simply “compatible” as a marketing claim?
• Does it auto-compute Skills Development Levy for foreign employees, or only for Citizens and Permanent Residents?
• Does it cap CPF contributions at the Additional Wage ceiling, or, like CPF EZPay’s own auto-computation, leave that unchecked in a bonus month?
• Who holds the Corppass access the software needs to operate, the vendor or your own team, and can you see and control it directly?
• Does the bank file it produces match your actual bank’s format, GIRO or FAST, or does disbursement still mean a manual upload?
• Does it handle IR21 tax clearance for a departing foreign employee, or does that sit outside the product entirely? Our IR8A employer guide sets out what the annual form itself actually requires, separately from IR21.
• Does it support Appendix 8A and 8B for benefits-in-kind and stock options, or will those still need filing separately through myTax Portal?

That last group of questions matters beyond the immediate purchase. A vendor holding your Corppass access, rather than your own team, is a real operational dependency, not just a convenience; know which one you are agreeing to, and how you would move off the software if you ever needed to.

None of this makes software the wrong choice, or the whole answer. It answers the computation question well, and for CPF and AIS specifically, a genuinely OSP-ready product can answer the submission question too. What it cannot do is take the liability off your CPF Submission Number, or guess which of the questions above matter for your particular mix of local and foreign staff. Ask the vendor directly, get a direct answer, and check it against what you actually need filed. If the gaps turn out to matter more than the fee saved, payroll processing is the alternative worth pricing against them.