The first 90 days of HR and payroll in Singapore

Incorporation content stops at the UEN. Employment content starts at the first payslip. The first 90 days between those two points, Corppass, a CPF Submission Number, a work pass if the hire needs one, Work Injury Compensation insurance, is where a foreign company setting up in Singapore actually loses time, usually because a step got attempted before the step it depends on had cleared.

This is not an incorporation guide (ACRA’s own how-to guides cover that ground better than a third party can), and it is not a work-pass guide either. It is the readiness map in between: what has to be true, in what order, before you can legally hire and pay someone here.

The dependency chain

The chain runs in one direction. A Singapore-registered entity with a UEN unlocks Corppass, since only a Registered Officer with an active Singpass can set Corppass up for a new entity. Corppass then unlocks two separate branches: a CPF Submission Number (CSN), and then a distinct CPF EZPay e-service, for payroll; and myTax Portal access, for the Auto-Inclusion Scheme once headcount reaches five employees, and GST once turnover crosses S$1 million. Work Injury Compensation insurance and any work pass application run on their own trigger, a specific hire, rather than sitting inside this registration chain at all. There is no standalone “MOM employer registration” step to complete; MOM’s touchpoints are transactional, a pass application if a hire needs one, the compulsory insurance once qualifying staff are on the books.

Getting the order wrong is not fatal, but it is expensive in time. Apply for the CSN before Corppass access is assigned, and the application has nowhere to go; assign the CPF Services e-service but forget the separate CPF EZPay one, and you hold a CSN you cannot use. Neither mistake announces itself. CPF Board publishes no processing time for the CSN application, so there is no published figure for what a false start costs you, only the certainty that nobody notices the missing link until the next step in the chain fails.

Two of those triggers are also easy to misjudge. IRAS ties GST registration to revenue, not headcount, so a well-funded two-person subsidiary of a foreign parent can cross S$1 million in turnover before it has hired anyone at all; registration then has to happen within 30 days of forming that expectation, or by 30 January the year after the threshold was actually crossed. AIS, by contrast, genuinely is a later-stage problem for a brand-new small team: it only becomes compulsory once you have had five or more employees at any point in a calendar year, so a founding team of two or three is not yet in scope. Company registration versus HR readiness walks the UEN-to-Corppass-to-CSN sequence in full; setting up payroll for your first employee covers the CSN and CPF EZPay mechanics end to end, including the two-Corppass-e-Service trap that catches most first-time filers.

What you must decide before you can hire at all

Before registration can start, a foreign company has to pick a vehicle, and the four options are not interchangeable. A subsidiary is a distinct Singapore entity, can be 100% foreign-owned, trades and pays corporate tax, and its liability is limited to its own assets. A branch office is not a separate legal entity: the parent carries full liability, but a branch can trade and hire under the same obligations as a local company, plus extra statutory disclosure. A representative office is neither: it cannot generate income, sign contracts or trade at all, exists only for market research and liaison ahead of a possible permanent set-up, and is administered by Enterprise Singapore rather than ACRA. Re-domiciliation, relocating an existing foreign entity’s legal domicile to Singapore, is the fourth, rarer route.

The representative office is the one most guides oversell as the safe, flexible first move, and the real constraints are harder than that framing suggests. Its staff strength is capped at fewer than five people, its parent generally needs at least three years of trading history and around US$250,000 in annual turnover to qualify (figures reported consistently across corporate-services advisers, not published on a single ACRA page), and it can operate for a maximum of three years with no renewal beyond that ceiling: convert to a branch or subsidiary, or close. It also is not built for an ordinary employer relationship. Because it cannot trade or invoice, its own small staff are typically seconded from the parent rather than hired through a normal Singapore payroll and CPF relationship. Representative office, entity, or Manpower Outsourcing compares all three routes head to head, including where Skillsforce’s own Manpower Outsourcing service actually fits.

Whichever entity is chosen, ACRA’s requirements are specific. A private limited company needs at least one shareholder (a company can be 100% foreign-owned with no local shareholder at all), at least one director who is “ordinarily resident” in Singapore under Section 145 of the Companies Act, a company secretary appointed within six months who cannot also be the sole director, a registered office open to the public for at least three hours a day, and a minimum paid-up capital of S$1. “Ordinarily resident” admits a citizen, a permanent resident, an EntrePass holder, or an Employment Pass holder who has been granted a Letter of Consent by MOM to direct a company other than their own sponsoring employer. A lean founding team with nobody meeting that test usually needs a nominee director, or a principal on a work pass with that consent, before the paperwork can even close. A non-resident applicant cannot self-file either way; ACRA requires the application to go through a registered filing agent.

Name reservation itself is quick and cheap: a S$15 Bizfile application, approved fast and then held for 120 days while everything else catches up. Incorporation is “usually processed and approved within 15 minutes of the payment of application fee,” in ACRA’s own words, but only for applications that need no referral to another government agency; anything that does get referred, a regulated sector, for instance, takes 14 to 60 days instead. That 15-minute figure describes ACRA’s own system processing a complete, paid, referral-free application. It is not how long it takes a foreign parent with no Singapore-resident director yet, using a filing agent, to actually be ready to file one. Setting up in Singapore is Skillsforce’s own service for this stage; hiring staff before incorporation covers what genuinely can happen while the entity is still being registered, name reservation, EntrePass timing, and briefing a recruitment partner to start sourcing.

Who can sponsor a work pass in Singapore?

Once the entity exists, a work pass is a separate gate, and it has one governing rule: only the direct, Singapore-registered employer can sponsor one. MOM states this in a dedicated FAQ, not as an inference: “Work passes are for foreigners to work for Singapore-based companies.” For a company with no local presence, MOM names exactly two routes back into the system, a representative office or local ACRA registration, plus a Short-Term Visit Pass, capped at 90 days a year, for genuinely short visits that never amount to being based here. The practical planning consequence is concrete: MOM processes an Employment Pass application within 10 business days once the sponsoring company is registered in Singapore, and not before. That alone is a reason to close the entity before starting to negotiate a start date with a candidate who needs a pass.

A third party that sponsors a pass for someone actually working for an overseas company with no Singapore registration is, in MOM’s own words, committing an offence. This is also why Skillsforce’s own Manpower Outsourcing service is scoped the way it is: where a client already has a Singapore entity, Skillsforce can sign the employment contracts, pay CPF and issue payslips under that entity’s registration, while the client directs the day-to-day work. Where a client has no Singapore entity yet, the support is recruiting, screening and shortlisting ahead of incorporation, not employment; the entity has to exist first, for exactly the reason MOM’s FAQ states. See Manpower Outsourcing for how those two scenarios work, and HR for a foreign company with no Singapore presence for the fuller picture of what MOM’s rule means for a company still weighing its options.

For the hire itself, an Employment Pass has to clear a qualifying salary, and MOM assesses each application against its wider eligibility criteria on top of that. Immigration practitioners commonly report that a newly incorporated company faces closer scrutiny than an established employer, since a company with no operating history yet has little to show against the employer-side criteria; this is reported practice, not a separate MOM rule. Roles also generally need 14 days’ advertising on MyCareersFuture first, though companies with fewer than 10 employees are exempt from advertising, which covers most first hires.

Day one as an employer

Once someone is hired, the paperwork clock starts immediately. Key Employment Terms, in writing, are due within 14 days of the first day of work, for anyone on a contract of 14 days or more. An itemised payslip goes with every payment from the first one onward, or within three working days if it cannot go with the payment itself. CPF applies only to Singapore Citizens and Permanent Residents earning more than S$50 a month; Employment Pass, S Pass and Work Permit holders receive none. The Skills Development Levy is different: it applies to every employee working in Singapore, foreign hires included, at 0.25% of monthly wages. Both are due on the last day of the calendar month the wages relate to; the 14th of the following month is an enforcement threshold, not the actual due date, a distinction the payroll compliance calendar covers in full alongside every other recurring deadline.

Work Injury Compensation insurance is the one obligation with a genuine lead time and no headcount threshold at all: it applies from the very first qualifying employee, doing manual work at any salary or non-manual work at S$2,600 or less a month, and MOM’s own instruction is to finalise the policy at least 21 days before it needs to start. Leaving it to the first week is not an option; the cover has to exist before the offer’s start date arrives. Leave entitlements follow the Employment Act once someone passes three months of service: 7 days of annual leave in the first year, rising by a day a year to 14; sick leave phasing in from 5 outpatient and 15 hospitalisation days at 3 months to 14 and 60 at 6 months; and 11 public holidays, separate from annual leave entirely. Maternity leave is a different statute altogether, 16 weeks under the Child Development Co-Savings Act rather than the Employment Act, gated on the child’s citizenship rather than the parent’s. Paternity leave is 4 weeks for any birth from 1 April 2025 onward, doubled from the 2 weeks many still-circulating guides quote. First employee HR policies checklist turns all of this into the week-before-day-one list.

The full ninety-day sequence

A foreign company’s first ninety days in Singapore run in one fixed order: entity registration, Corppass and CPF set-up, any work pass the first hire needs, then the day-one HR obligations. Laid out as a sequence, it looks like this.

Phase	What happens	What it blocks
1. Choose and register the entity	Decide subsidiary, branch or representative office; if nobody on the founding team is Singapore-resident, engage a filing agent and arrange a resident director; reserve the name and incorporate	Everything below. Nothing can start without a UEN
2. Set up Corppass	A Registered Officer with Singpass registers the entity, then grants access to whoever will handle payroll and tax filings	The CPF Submission Number and myTax Portal access
3. Apply for the CPF Submission Number	Apply as soon as a first hire is planned; separately assign the CPF EZPay e-service to whoever will actually submit	Paying CPF and SDL
4. Arrange the first hire’s work pass, if one is needed	Confirm the Singapore entity is the sponsor, budget 10 business days for a registered employer, and check whether the role needs 14 days on MyCareersFuture first	Legally starting the employee’s first day
5. Buy Work Injury Compensation insurance	Finalise cover at least 21 days before the start date if the hire does manual work, or non-manual work at S$2,600 or less a month	Lawful cover from day one; there is no headcount threshold
6. Issue Key Employment Terms and the first payslip	Written KETs within 14 days of the first day; an itemised payslip with every payment from the first one	A lapse escalates from MOM engagement to a penalty per repeat infringement
7. Run the first CPF and SDL submission	Due the last day of the calendar month the wages relate to	The 14th of the following month is an enforcement threshold, not a grace period
8. Watch the two triggers with no fixed date	AIS becomes compulsory at five or more employees in a calendar year; GST becomes compulsory once turnover crosses, or is expected to cross, S$1 million	Neither blocks the next step, but both are easy to miss since they are not day-one, headcount-based items

Every step in this sequence is publicly documented, and a careful operations lead can run it alone with nothing more than the links here and a diary. What actually derails a first ninety days is not any single registration; it is attempting two or three of them out of order while also trying to close a hire, usually in the exact week nobody has time to re-read an ACRA guide twice. Skillsforce runs HR set-up and payroll for foreign companies opening in Singapore, sequencing the whole chain so a first hire’s start date does not slip, or this page is the order to follow if you would rather run it yourself. A UEN with nobody able to pay them is not yet a Singapore operation.