Employment Pass · 4 min read
A new holding company, and an EP approved after MOM asked hard questions
Our client set up her own investment holding company in Singapore and applied for an Employment Pass to run it. Because the company was brand new and had no business activity yet, the Ministry of Manpower (MOM) asked a long list of questions before approving. This case shows what MOM asked, and how we answered.
Details anonymised to protect client confidentiality. Facts, sequence and outcome are real. Every case is different and decisions rest with the authorities.
The situation
Our client is a Chinese national. She was already working in Singapore as a director of another company. She wanted to start her own investment holding company, own it fully, and run it as managing director. For that she needed a new Employment Pass under her own company.
The difficulty was timing. Her company was only two weeks old when the application went in. It had no office yet, no staff, no customers, and no corporate bank account, because the bank needed her as the authorised signatory, and she could not take that role until her pass was approved. A few weeks after filing, MOM wrote back and asked for the company’s bank statements and client contracts, a tenancy agreement for an office, a list of employees, and an explanation of her salary.
What we did
We did not pretend the company was something it was not. For each request, we explained the honest position: the contracts, office, staff and bank account were all waiting on her pass. To show the company could survive its setup stage, we provided proof of her personal funds.
For the salary question, we showed MOM real job advertisements on MyCareersFuture for similar director roles, proving her proposed salary was in line with the market. We also pointed out one simple fact: she earned more in her old job than she planned to pay herself in her new company. She was accepting a pay cut to build her own business. That made the salary believable.
The outcome
MOM approved the Employment Pass about ten weeks after filing. The pass was issued, she became her company’s director and bank signatory, and she now runs the business she owns. Every answer we gave was factual, and every fact had a document behind it.
| When | What happened |
|---|---|
| July 2025 | Company incorporated; EP filed as managing director within two weeks |
| August 2025 | MOM asks for contracts, tenancy, employee list and salary justification; we file a full response |
| October 2025 | Employment Pass approved |
| December 2025 | Pass issued; founder becomes director and authorised bank signatory |
What this case shows
- Answer MOM honestly; do not dress up an early-stage company
- Proof of personal funds can show that a new company is sustainable
- Justify the salary with real market job listings, not opinions
- A believable reason, like taking a pay cut to own your business, is persuasive
Map your own case before you file.
Tell us your situation and we will tell you, honestly, what a credible path looks like.