# The Fair Consideration Framework and the MyCareersFuture advertising rule

URL: https://skillsforce.com.sg/insights/fair-consideration-framework-mycareersfuture-advertising
Title: The Fair Consideration Framework and the MyCareersFuture advertising rule | Skillsforce
Description: The 14-day MyCareersFuture advertising duty applies before a work pass application, not to every hire. The exact trigger, the five exemptions and the penalties.
Updated 21 August 2026. First published 21 August 2026. Author: Skillsforce (People-operations team)
Category: fair-hiring-local

Almost every Singapore employer has heard that a job must be advertised on MyCareersFuture for 14 days. Far fewer have been told the one thing that decides whether the duty applies to them at all. The rule is real, MOM enforces it, and it is narrower than the version that circulates online. Here is the exact trigger, the five current exemptions, the penalties for getting it wrong, and the broader fair-hiring standard that sits underneath it and does apply to every advertisement you publish.

## When does the MyCareersFuture 14-day advertising rule actually apply?

Only before an employer submits an Employment Pass or S Pass application. MOM requires the role advertised on MyCareersFuture for at least 14 consecutive days, with fair consideration of every applicant, before submission. It is not a duty on every hire. Five exemptions apply, including employers with fewer than 10 employees and salaries of S$22,500 and above.

## Key points

- The MyCareersFuture advertising duty is triggered by a work pass application, not by every hire. A company recruiting a Singaporean or Permanent Resident owes no advertising duty under the Fair Consideration Framework.
- The advertisement must stay open for at least 14 consecutive days before the application is submitted, and a change to the job title, the salary or the number of vacancies starts a fresh 14-day window.
- Five exemptions currently apply: companies with fewer than 10 employees; a fixed monthly salary of S$22,500 and above, in force since 1 September 2023; a role of not more than one month; a local transferee; and a candidate applying as an overseas intra-corporate transferee.
- Exemption from advertising is not exemption from fair consideration. MOM states that companies below the 10-employee threshold are still expected to consider Singaporeans fairly for jobs.
- A breach carries two separate consequences: administrative debarment of at least 12 months and up to 24 months, applying to new applications and renewals alike, and criminal prosecution for a false declaration carrying up to 2 years' imprisonment, a fine of up to S$20,000, or both.
- TAFEP's Tripartite Guidelines on Fair Employment Practices bind every employer and every job advertisement, whether or not a work pass is involved, and MOM enforces breaches through the same route that feeds the FCF Watchlist.

Almost every Singapore employer has heard that a job has to be advertised on MyCareersFuture for 14 days. Far fewer have been told when that duty actually starts, and the gap between the two is where the trouble sits. The rule is real and MOM enforces it, but it is narrower than the version that circulates: it attaches to one specific step in a hiring process, not to every vacancy a company opens. The wider set of obligations an employer owes local candidates is set out in [our guide to hiring Singaporeans and PRs](/insights/hiring-singaporeans-and-prs-employer-guide). This article covers the single duty inside it that employers most often misread.

## What the Fair Consideration Framework is

The Fair Consideration Framework, usually shortened to FCF, is the Ministry of Manpower's mechanism for making sure the local workforce is considered fairly for job opportunities. MOM's own formulation is that employers must not discriminate on non job-related characteristics, such as age, sex, nationality or race. MOM administers the framework and MOM enforces it. The advertising itself happens on MyCareersFuture, the national jobs portal that opened in April 2018 in place of the earlier Jobs Bank.

It helps to be clear about what kind of instrument this is. The FCF is administrative policy attached to MOM's control of work passes, not a statute with its own offence for unfair hiring. Its consequences are administrative, and they land squarely on an employer's ability to bring in foreign staff. That changes once the Workplace Fairness Act commences, because section 26 of that Act writes the fair-consideration duty into legislation for the first time. [What the Workplace Fairness Act changes](/insights/workplace-fairness-act-singapore-employers) is a separate question, and a separate article, because that Act is not yet in force.

## The trigger, stated exactly

Here is the part that gets mangled. The advertising duty applies before an employer submits an Employment Pass or S Pass application to MOM. That is the trigger, and it is the only trigger.

It does not apply to every hire. A company recruiting a Singaporean or a Permanent Resident into a role owes no MyCareersFuture advertising duty under the FCF at all. It does not apply to every search either. An employer can brief a role, advertise where it likes, interview widely and hire locally without the framework's 14-day clock ever starting. The clock starts because the employer intends to sponsor a pass, and it has to have finished running before the application goes in.

The mechanics are short and unforgiving. The advertisement must stay open for at least 14 consecutive days, so that job seekers can view and apply for the vacancy. If a detail changes while it is running, whether the job title, the salary or the number of vacancies, the employer must keep it open for at least another 14 consecutive days before the application can be submitted. MOM also states that an employer should not make a job offer to a candidate during the mandatory advertising duration.

The word "consider" is doing real work in the framework's name. MOM's stated position is that an employer must genuinely review the applicants rather than go through the motion of advertising a role that has already been decided. An advertisement placed around a candidate who was chosen weeks earlier satisfies the calendar and fails the framework.

## The five exemptions

MOM's live guidance lists five exemptions from the advertising requirement.

- Companies with fewer than 10 employees. MOM's stated reason is that small companies may have limited resources to handle the administrative process, or are ramping up their operations.
- A vacancy with a fixed monthly salary of S$22,500 and above. This threshold took effect on 1 September 2023, and MOM's reasoning is that positions at that level are senior management and specialist roles that already involve rigorous selection, so requiring an advertisement would not be practical.
- A short-term role, meaning a vacancy of not more than one month.
- A role filled by a local transferee. MOM's guidance on this exemption ties it to companies undergoing a merger and acquisition, amalgamation or corporate restructuring, or to companies whose common shareholders own at least 50% of each.
- A role filled by a candidate applying as an overseas intra-corporate transferee.

Two of those repay a second look. The fewer-than-10 test is a headcount test on the company itself, and it is not the same measure as the local workforce counts used elsewhere in Singapore's employment rules, which [we cover separately](/insights/local-qualifying-salary-local-workforce-count). And the last two are genuinely different exemptions rather than one written twice: a local transferee moves between related Singapore entities, while an overseas intra-corporate transferee applies from within the same group abroad.

One line matters more than the five above put together: an exemption from advertising is not an exemption from fair consideration. MOM says plainly that small companies falling under the fewer-than-10 exemption are still expected to consider Singaporeans fairly for jobs. Working out which of these applies to a particular role, at the point a search is briefed rather than at the point a candidate has been chosen, is part of what we do when we run one.

## The Watchlist, debarment and the false-declaration offence

MOM checks compliance at the point of application. An employer has to declare the matching MyCareersFuture advertisement identifier before MOM will accept a pass application, which is what makes the duty enforceable rather than aspirational.

Beyond that, MOM operates a scrutiny mechanism widely known as the FCF Watchlist. Employers are placed under heightened scrutiny on workforce-profile grounds, for example an exceptionally high share of foreign professionals, managers, executives and technicians compared with their industry peers, or a high concentration of them from a single nationality, and on the basis of repeated complaints of discriminatory hiring practices. The most recent MOM press release carrying cumulative figures is dated 5 August 2020. At that point, roughly 1,200 employers had been scrutinised under the framework since 2016, about 190 had been placed on the Watchlist, and more than 100 of those had since exited it. Those are 2020 numbers, and we have not found a later MOM release updating them, so read them as the shape of the mechanism rather than the current count.

Two consequences follow a breach, and they are worth keeping apart, because most summaries flatten them into one.

Debarment is administrative. It runs for a minimum of 12 months, rising to 24 months in more serious cases, and it applies to both new work pass applications and renewals. An employer under debarment cannot bring in or retain foreign staff through the normal route, whatever the commercial cost of that happens to be at the time.

A false declaration is criminal. Declaring that all candidates were fairly considered when they were not can lead to prosecution, and conviction carries imprisonment of up to 2 years, a fine of up to S$20,000, or both.

## The layer underneath: TAFEP and the Tripartite Guidelines

The FCF sits on top of something broader, and this is where employers who assumed the 14-day rule was the whole story get caught. The Tripartite Guidelines on Fair Employment Practices are issued by TAFEP, the Tripartite Alliance for Fair and Progressive Employment Practices, set up in 2006 by MOM, the National Trades Union Congress and the Singapore National Employers Federation. Every employer in Singapore is expected to follow them, not only those sponsoring passes.

The first of the five principles carries most of the weight: recruit and select employees on the basis of merit, such as skills, experience or ability to perform the job, and regardless of age, race, gender, religion, marital status and family responsibilities, or disability. That is the standard a job advertisement is judged against, and unlike the 14-day rule it does apply to every advertisement a company publishes. TAFEP's guidance on writing advertisements is blunt about the wording that fails it: age-coded phrasing such as "Below 30 only", gender-coded phrasing such as "Preferably female", and nationality or race-coded phrasing such as "Non-Singaporeans preferred". The test is whether the stated selection criteria relate to the qualifications, skills, knowledge and experience the job actually needs.

The guidelines are guidance rather than statute, but the enforcement route is not theoretical. TAFEP refers cases to MOM, and MOM's responses run from requiring attendance at corrective workshops and requiring the employer to rectify lapses in its HR processes, through placement on the FCF Watchlist, to curtailing the employer's ability to obtain work pass approvals at all. The guidelines and the framework are the same enforcement system seen from two ends.

## If someone else is doing your recruiting

Outsourcing a search does not outsource the obligation. Since 1 October 2020, MOM's licence conditions have required employment agencies to comply with the fair recruitment requirements in the Tripartite Guidelines when recruiting on behalf of a client. Agencies must brief their clients on those requirements, make reasonable efforts to attract Singaporeans for vacancies, and must not abet discriminatory hiring by a client, for example by withholding applications on the basis of age, race, nationality, gender or disability. An agency that fails can be issued demerit points, have its licence suspended or revoked, or face prosecution. An employer who asks an agency to quietly filter local candidates out is asking it to breach its own licence conditions, and both sides carry the consequence. If you have not looked, [checking an agency's EA licence](/insights/how-to-check-recruitment-agency-ea-licence-singapore) takes about five minutes.

We run [Recruitment & Executive Search](/services/recruitment) under EA Licence 99C3289. In practice that means the local market is searched first as a matter of course, any advertising window is planned into [the hiring timeline](/insights/recruitment-shortlist-timeline-singapore) rather than bolted on when an application is already overdue, and the record of who applied and how they were assessed exists before anyone asks to see it. None of that is beyond an employer who would rather run it in-house. The duration is 14 consecutive days, the trigger is the pass application, and the five exemptions above are the entire list. Knowing which one applies to the role in front of you is the part worth settling before the search starts, not after the offer has been made.

## Frequently asked questions

### Does the MyCareersFuture 14-day advertising rule apply to every job I post?

No. The Fair Consideration Framework's advertising duty is triggered only when an employer intends to submit one of the work pass applications the framework covers, and it must be satisfied before that application goes in, for at least 14 consecutive days. A company hiring a Singaporean or Permanent Resident owes no MyCareersFuture advertising duty under the framework. The separate expectation of merit-based, non-discriminatory selection under TAFEP's Tripartite Guidelines on Fair Employment Practices applies to every advertisement, whatever the hire.

### How long must a job be advertised on MyCareersFuture before a work pass application?

At least 14 consecutive days, so that job seekers can view and apply for the vacancy. If the job title, the salary or the number of vacancies changes while the advertisement is running, MOM requires it to stay open for at least another 14 consecutive days before the application can be submitted. MOM also states that an employer should not make a job offer to a candidate during the mandatory advertising duration.

### Which roles are exempt from the FCF advertising requirement?

MOM lists five exemptions as at 21 August 2026. Companies with fewer than 10 employees. A vacancy with a fixed monthly salary of S$22,500 and above, a threshold in force since 1 September 2023. A short-term role, meaning not more than one month. A role filled by a local transferee, which MOM's own guidance ties to companies undergoing a merger and acquisition, amalgamation or corporate restructuring, or to companies whose common shareholders own at least 50% of each. And a role filled by a candidate applying as an overseas intra-corporate transferee. Exemption from advertising is not exemption from fair consideration.

### What happens if an employer breaches the Fair Consideration Framework?

Two separate consequences, on two separate tracks. Debarment is administrative: a minimum of 12 months, rising to 24 months in more serious cases, and it applies to both new work pass applications and renewals. A false declaration that all candidates were fairly considered is criminal, can be prosecuted, and on conviction carries imprisonment of up to 2 years, a fine of up to S$20,000, or both.

### What is the FCF Watchlist?

MOM's heightened-scrutiny list for employers whose workforce profile or complaint history points to unfair hiring: for example an exceptionally high share of foreign professionals, managers, executives and technicians compared with industry peers, a high concentration of them from a single nationality, or repeated complaints of discriminatory hiring practices. In a MOM press release of 5 August 2020, the most recent one carrying cumulative figures, roughly 1,200 employers had been scrutinised under the framework since 2016 and about 190 had been placed on the Watchlist.

### Does using a recruitment agency transfer the fair-hiring obligation?

No. Since 1 October 2020, MOM's licence conditions have required employment agencies to comply with the fair recruitment requirements in the Tripartite Guidelines on Fair Employment Practices, to brief their clients on those requirements, to make reasonable efforts to attract Singaporeans for vacancies, and not to abet discriminatory hiring by a client, for example by withholding applications on the basis of age, race, nationality, gender or disability. An agency that fails can be issued demerit points, have its licence suspended or revoked, or face prosecution. The employer's own duty is unchanged.

## Sources

- [Ministry of Manpower: Fair Consideration Framework](https://www.mom.gov.sg/employment-practices/fair-consideration-framework) (Accessed 21 August 2026)
- [Ministry of Manpower: Consider all candidates fairly](https://www.mom.gov.sg/passes-and-permits/employment-pass/consider-all-candidates-fairly) (Accessed 21 August 2026)
- [Ministry of Manpower: consider all candidates fairly before a work pass application](https://www.mom.gov.sg/passes-and-permits/s-pass/consider-all-candidates-fairly) (Accessed 21 August 2026)
- [Ministry of Manpower FAQ: why jobs with a fixed monthly salary of $22,500 and above are exempted from advertising](https://www.mom.gov.sg/faq/fair-consideration-framework/why-are-jobs-with-fixed-monthly-salary-of-22500-and-above-exempted-from-advertising) (Accessed 21 August 2026)
- [Ministry of Manpower FAQ: why jobs in small companies with fewer than 10 employees are exempted from advertising](https://www.mom.gov.sg/faq/fair-consideration-framework/why-are-jobs-in-small-companies-with-fewer-than-10-employees-exempted-from-advertising) (Accessed 21 August 2026)
- [Ministry of Manpower FAQ: exemption from FCF advertising where the candidate is a local transferee](https://www.mom.gov.sg/faq/work-pass-general/can-my-company-be-exempted-from-fcf-advertising-requirements-is-candidate-is-a-local-transferee) (Accessed 21 August 2026)
- [Ministry of Manpower press release, 5 August 2020: employers placed on the Fair Consideration Framework Watchlist](https://www.mom.gov.sg/newsroom/press-releases/2020/0805-another-47-employers-placed-on-the-fair-consideration-framework-watchlist) (Accessed 21 August 2026)
- [TAFEP: Tripartite Guidelines on Fair Employment Practices](https://www.tal.sg/tafep/getting-started/fair/tripartite-guidelines) (Accessed 21 August 2026)
- [TAFEP: writing job advertisements](https://www.tal.sg/tafep/employment-practices/recruitment/writing-job-advertisements) (Accessed 21 August 2026)
- [Ministry of Manpower press release, 22 June 2020: new licence conditions for employment agencies to strengthen fair hiring](https://www.mom.gov.sg/newsroom/press-releases/2020/0622-new-licence-conditions-for-employment-agencies-to-strengthen-fair-hiring) (Accessed 21 August 2026)

## Related

- [Hiring Singaporeans and PRs: the employer guide](https://skillsforce.com.sg/insights/hiring-singaporeans-and-prs-employer-guide)
- [What the Workplace Fairness Act changes](https://skillsforce.com.sg/insights/workplace-fairness-act-singapore-employers)
- [How to check a recruitment agency's EA licence](https://skillsforce.com.sg/insights/how-to-check-recruitment-agency-ea-licence-singapore)
- [Recruitment & Executive Search](https://skillsforce.com.sg/services/recruitment)