Singapore Workplace Fairness Act 2025: What Businesses Using an Employer of Record Need to Know
Singapore has given workplace fairness the force of law. In 2025, Parliament passed the Workplace Fairness Act (WFA) — the city-state’s first legislation making workplace discrimination legally enforceable.
For businesses already operating in Singapore through employer of record services, the question is specific: how does this law affect your arrangement?
The answer matters because an EOR sits between your business and your employees as the legal employer.
That relationship determines exactly who holds the compliance obligations under the WFA — and what your business must do regardless.
This article explains what the Act requires, how it interacts with EOR arrangements in Singapore, and what to look for in a compliant EOR partner.
For businesses already operating in Singapore through employer of record services, the question is specific: how does this law affect your arrangement?
The answer matters because an EOR sits between your business and your employees as the legal employer.
That relationship determines exactly who holds the compliance obligations under the WFA — and what your business must do regardless.
This article explains what the Act requires, how it interacts with EOR arrangements in Singapore, and what to look for in a compliant EOR partner.
What Is the Singapore Workplace Fairness Act?
The Workplace Fairness Act is Singapore’s first statute specifically prohibiting workplace discrimination.
It was passed in two stages: the substantive bill on 8 January 2025, and the Dispute Resolution bill on 4 November 2025. The law is expected to take effect by the end of 2027.
The Act applies to employers with 25 or more employees. Smaller firms are exempt at commencement, with a review of their status within five years.
The Act covers all stages of employment — from job advertisements and hiring through to promotions, performance appraisals and dismissals.
Discrimination based on any of 11 protected characteristics is prohibited. These are:
See the key facts summary below.
It was passed in two stages: the substantive bill on 8 January 2025, and the Dispute Resolution bill on 4 November 2025. The law is expected to take effect by the end of 2027.
The Act applies to employers with 25 or more employees. Smaller firms are exempt at commencement, with a review of their status within five years.
The Act covers all stages of employment — from job advertisements and hiring through to promotions, performance appraisals and dismissals.
Discrimination based on any of 11 protected characteristics is prohibited. These are:
- Age
- Nationality
- Sex, marital status, pregnancy status and caregiving responsibilities
- Race, religion and language ability
- Disability and mental health conditions
See the key facts summary below.
| Item | Detail |
|---|---|
| Legislation | Workplace Fairness Act 2025 |
| Bills passed | Substantive bill: 8 Jan 2025 | Dispute Resolution bill: 4 Nov 2025 |
| Effective date | By end of 2027 |
| Applies to | Employers with 25 or more employees |
| Scope | Hiring, promotion, appraisal, termination |
| Max penalty (civil) | Up to S$250,000 for serious repeat breaches |
From Voluntary Guidelines to Legal Obligation
Before the WFA, Singapore promoted fair hiring through the Tripartite Guidelines on Fair Employment Practices (TGFEP).
Those guidelines were advisory. The Ministry of Manpower could curtail work pass privileges, but employees had no direct legal avenue to seek redress.
The WFA changes that fundamentally. Employees can now bring claims directly — through a three-step process:
Penalties run in two tiers. Administrative breaches — such as failing to maintain grievance records — carry fines of up to S$5,000 for a first offence.
Serious civil contraventions, such as retaliatory dismissal, carry penalties of up to S$50,000 initially and S$250,000 for repeat orders.
Both the company and its officers can be held jointly liable.
Those guidelines were advisory. The Ministry of Manpower could curtail work pass privileges, but employees had no direct legal avenue to seek redress.
The WFA changes that fundamentally. Employees can now bring claims directly — through a three-step process:
- Step 1: Internal grievance handling within the firm
- Step 2: Mandatory mediation through the Commissioner for Workplace Fairness
- Step 3: Adjudication at the Employment Claims Tribunal (claims up to S$250,000) or the High Court
Penalties run in two tiers. Administrative breaches — such as failing to maintain grievance records — carry fines of up to S$5,000 for a first offence.
Serious civil contraventions, such as retaliatory dismissal, carry penalties of up to S$50,000 initially and S$250,000 for repeat orders.
Both the company and its officers can be held jointly liable.
How the WFA Applies to Employer of Record Arrangements
When a business engages employer of record services in Singapore, the EOR becomes the legal employer on paper.
This means the EOR is the entity registered with MOM, the CPF Board and IRAS. The EOR sponsors work passes, processes payroll and signs employment contracts.
Under the WFA, the legal employer bears the primary compliance obligations. That includes the duty to establish a written grievance process, avoid discriminatory decisions, and maintain proper records.
In practice, this has important implications for businesses using EOR arrangements:
Crucially, however, the day-to-day management of the employee typically remains with your business — the EOR’s client. If your team makes a biased promotion decision or a discriminatory dismissal call, and that decision is executed through the EOR, the WFA exposure does not disappear simply because an EOR is involved.
Both the EOR as legal employer and your business as the operational employer share responsibility for how employment decisions are made and documented.
This means the EOR is the entity registered with MOM, the CPF Board and IRAS. The EOR sponsors work passes, processes payroll and signs employment contracts.
Under the WFA, the legal employer bears the primary compliance obligations. That includes the duty to establish a written grievance process, avoid discriminatory decisions, and maintain proper records.
In practice, this has important implications for businesses using EOR arrangements:
- The EOR’s employment contracts must already conform to WFA requirements — no discriminatory clauses, no retaliation provisions
- The EOR must maintain a written grievance handling process that meets Section 27 of the Act
- Any hiring or termination decisions routed through the EOR must be defensible on merit and free of protected-characteristic bias
Crucially, however, the day-to-day management of the employee typically remains with your business — the EOR’s client. If your team makes a biased promotion decision or a discriminatory dismissal call, and that decision is executed through the EOR, the WFA exposure does not disappear simply because an EOR is involved.
Both the EOR as legal employer and your business as the operational employer share responsibility for how employment decisions are made and documented.
What to Look for in an EOR Partner Under the WFA
Not all employer of record services are equally prepared for the WFA compliance landscape.
As you evaluate or review your EOR partner, ask the following:
A well-structured EOR does more than process payroll. It provides the compliance infrastructure that shields your business from inadvertent breaches — including breaches your team might not even realise it is committing.
For foreign companies entering Singapore, this support is particularly valuable. You may not be familiar with local nuances around nationality fairness under the Fair Consideration Framework, or the specific evidentiary standards MOM expects when employment decisions are challenged.
Learn more about how EOR and work pass regulation intersect through TY TEOH’s guide to EOR and work pass regulation in Singapore.
As you evaluate or review your EOR partner, ask the following:
- Does the EOR maintain a written grievance handling process that satisfies Section 27 of the WFA?
- Are employment contracts drafted to exclude discriminatory criteria across all 11 protected characteristics?
- Does the EOR maintain proper records of employment decisions — hiring, promotions, appraisals and exits?
- Does the EOR have anti-retaliation provisions built into its processes to protect employees who raise concerns?
- Can the EOR provide guidance on how operational decisions made by your team should be documented for WFA compliance?
A well-structured EOR does more than process payroll. It provides the compliance infrastructure that shields your business from inadvertent breaches — including breaches your team might not even realise it is committing.
For foreign companies entering Singapore, this support is particularly valuable. You may not be familiar with local nuances around nationality fairness under the Fair Consideration Framework, or the specific evidentiary standards MOM expects when employment decisions are challenged.
Learn more about how EOR and work pass regulation intersect through TY TEOH’s guide to EOR and work pass regulation in Singapore.
A Note for Foreign Businesses Entering Singapore
For international businesses expanding into Singapore, the WFA adds a new compliance layer to an already-structured regulatory environment.
Foreign companies already navigate CPF, the Fair Consideration Framework, work pass requirements and the Employment Act.
The WFA now overlays anti-discrimination obligations across the entire employment lifecycle.
Many overseas companies choose to establish their Singapore presence through employer of record services precisely to manage this complexity — and the WFA makes that rationale even stronger.
If you are evaluating Singapore as a market and want to understand the broader compliance picture before hiring, market entry advisory support can help you structure your workforce approach from day one.
Foreign companies already navigate CPF, the Fair Consideration Framework, work pass requirements and the Employment Act.
The WFA now overlays anti-discrimination obligations across the entire employment lifecycle.
Many overseas companies choose to establish their Singapore presence through employer of record services precisely to manage this complexity — and the WFA makes that rationale even stronger.
If you are evaluating Singapore as a market and want to understand the broader compliance picture before hiring, market entry advisory support can help you structure your workforce approach from day one.
Frequently Asked Questions
1. Does the Workplace Fairness Act apply to businesses using an EOR in Singapore?
Yes. The WFA applies to the legal employer — which in an EOR arrangement is the EOR provider.
However, businesses that manage employees day-to-day retain responsibility for the decisions that underlie employment actions.
If your team drives a biased promotion or discriminatory dismissal, executing it through an EOR does not eliminate the WFA exposure.
However, businesses that manage employees day-to-day retain responsibility for the decisions that underlie employment actions.
If your team drives a biased promotion or discriminatory dismissal, executing it through an EOR does not eliminate the WFA exposure.
2. When does the Singapore Workplace Fairness Act take effect?
The WFA is expected to come into force by end of 2027. The substantive bill was passed on 8 January 2025 and the Dispute Resolution bill on 4 November 2025.
Employers with 25 or more employees should begin aligning their grievance processes and employment practices well before the effective date.
Employers with 25 or more employees should begin aligning their grievance processes and employment practices well before the effective date.
3. What is the grievance handling requirement under the WFA?
Under Section 27 of the WFA, employers with 25 or more employees must maintain a written grievance process covering four elements: inquiry and review of complaints, written notification of outcomes, confidentiality, and record-keeping.
In an EOR arrangement, this obligation sits with the EOR as the registered employer — but your business should confirm that the EOR’s procedures meet the statutory standa
In an EOR arrangement, this obligation sits with the EOR as the registered employer — but your business should confirm that the EOR’s procedures meet the statutory standa
4. What penalties can apply for WFA breaches?
Penalties operate on two tiers. Administrative penalties for record-keeping failures run up to S$5,000 for a first offence.
Serious civil contraventions — retaliatory dismissal, deliberate discrimination — carry penalties of up to S$50,000 initially and S$250,000 for repeat orders. Both the company and its officers may be jointly liable.
Serious civil contraventions — retaliatory dismissal, deliberate discrimination — carry penalties of up to S$50,000 initially and S$250,000 for repeat orders. Both the company and its officers may be jointly liable.
5. How can employer of record services help with WFA compliance?
A strong EOR partner provides the compliance framework that the WFA requires: properly drafted employment contracts, written grievance procedures, and disciplined record-keeping.
EOR providers with Singapore-specific expertise also understand how the WFA intersects with MOM’s Fair Consideration Framework — a practical advantage for foreign companies navigating local hiring rules.
Explore how TY TEOH’s employer of record services are structured to meet Singapore’s evolving employment compliance requirements.
EOR providers with Singapore-specific expertise also understand how the WFA intersects with MOM’s Fair Consideration Framework — a practical advantage for foreign companies navigating local hiring rules.
Explore how TY TEOH’s employer of record services are structured to meet Singapore’s evolving employment compliance requirements.
Conclusion
The Singapore Workplace Fairness Act marks a genuine shift in the country’s employment landscape.
For businesses operating through employer of record services, the practical message is clear: the legal employer bears primary WFA obligations, but operational employers remain accountable for the decisions that drive employment outcomes.
The two-year runway before the Act takes effect is an opportunity — not a reason to delay.
Use this time to review your EOR partner’s grievance procedures, audit how employment decisions are made and documented, and ensure your management practices can withstand WFA scrutiny.
Companies that approach this proactively will find that compliance and good employment practice point in exactly the same direction.
For businesses operating through employer of record services, the practical message is clear: the legal employer bears primary WFA obligations, but operational employers remain accountable for the decisions that drive employment outcomes.
The two-year runway before the Act takes effect is an opportunity — not a reason to delay.
Use this time to review your EOR partner’s grievance procedures, audit how employment decisions are made and documented, and ensure your management practices can withstand WFA scrutiny.
Companies that approach this proactively will find that compliance and good employment practice point in exactly the same direction.
