C6 Building a C6 Credentialed Firm: Documenting Innovation and Growth for Compass Points
The C6 bonus under Singapore’s COMPASS framework awards up to 20 additional points to employers that demonstrate exceptional investment, innovation, or internationalisation. A firm can claim points from two of three approved categories. Ministry of Manpower data from its 2025 compliance cycle revealed that 18% of C6 claims were rejected outright—not because the firms lacked genuine activities, but because their documentation failed to meet evidentiary thresholds. Getting the paper trail right determines whether your firm’s innovation and growth actually translate into higher EP approval chances.
Understanding the C6 Bonus Categories
C6 points split across three pillars. The fixed asset investment pillar requires cumulative investment in Singapore of at least SGD 2 million over a rolling three‑year period, measured by additions to property, plant and equipment. The innovation pillar relies on approved R&D tax claims from IRAS—specifically, deductions or allowances under Section 14D of the Income Tax Act or the Enterprise Innovation Scheme. Internationalisation points demand that export revenue exceeds 50% of total revenue in the most recent financial year. Each pillar can deliver up to 10 points; combining two delivers the maximum 20. Only one claim per pillar is allowed, and the evidence must tie directly to the applying entity.
Audited Financials for the Investment KPI
MOM accepts only audited financial statements prepared by a public accountant registered with ACRA. The statements must isolate fixed assets located in Singapore and provide a clear reconciliation that tracks the SGD 2 million threshold across a three‑year window ending in the latest completed financial year. Leasehold improvements, machinery, and IT hardware qualify; inventory and intangible assets do not. If any assets are held under finance leases, include the lease schedules and a note confirming the capitalised value. Unaudited management accounts, draft financials, or director‑certified spreadsheets are automatically rejected. MOM’s 2026 operational guidelines also flag that a mismatch between the audited asset register and the ACRA filing will trigger an automatic verification hold, delaying the EP application by up to four weeks.
Approved R&D Tax Claims from IRAS
To secure innovation points, present the IRAS notice of assessment or the Enterprise Innovation Scheme acknowledgment letter for R&D expenditure claimed in the last three years. MOM cross‑checks the IRAS reference number electronically; claims still under review or subject to audit cannot be used. The qualifying R&D must have been conducted in Singapore and must relate to the firm’s trade. If the claim was made under a group cost‑sharing arrangement, supply the intercompany agreement and evidence that the Singapore entity bore the expenditure. MOM’s 2025 enforcement round invalidated 12% of innovation claims because the firm used expired or provisional IRAS estimates. Only final, approved assessments are admissible.
Invoices and Customs Data for Export Intensity
Internationalisation evidence rests on two complementary documents: sales invoices issued to overseas counterparties and the corresponding TradeNet export permits. The total export value on the permits must match the invoiced amount within a 5% tolerance, or MOM will request an auditor‑reconciled statement. For exports of services, contracts and bank‑inflow statements replace customs data. When intercompany sales exceed 20% of total exports, the firm must add transfer pricing documentation that justifies arm’s‑length pricing. The 50% export‑intensity test uses only the most recent audited financial year; a single one‑year spike without a supporting trend may invite a request for prior‑year comparatives.
Timeline for Submitting Evidence During EP Pre‑approval
Evidence is uploaded directly when the employer submits the EP application via EP Online. There is no post‑submission grace period. MOM’s system assigns 0 points to any C6 category that lacks a complete document bundle at the moment of lodgement. Firms should finalise a C6 evidence pack 4‑6 weeks before the candidate’s intended submission date. This allows time for auditor sign‑off on investment letters and IRAS re‑issuance of assessment notices if needed. For EP renewals where the same entity has claimed C6 previously, MOM still requires updated documents for the latest financial year; historical acceptance does not waive the refresh.
Common Pitfalls and Verification Triggers
MOM now runs automated cross‑references against ACRA, IRAS, and Singapore Customs databases. A common trigger is a discrepancy between GST‑declared export sales and the total revenue in audited financials—this suggests the export intensity may be overstated. Another is innovation points claimed by small entities that have never filed an R&D tax return; MOM will query whether the role of the EP candidate genuinely supports innovation. Firms should also ensure that the EP candidate’s job description aligns with the claimed growth pillar. A candidate in a purely administrative role is unlikely to be deemed instrumental to R&D, even if the firm holds valid IRAS assessments.
FAQ
What is the exact investment threshold for C6 points? The firm must show cumulative fixed asset investment in Singapore of at least SGD 2 million across the three most recent financial years. The figure is taken from the audited fixed asset register, excluding revaluations and assets held for resale.
Can pending R&D claims be used? No. Only final IRAS assessments issued for claims under Section 14D or the Enterprise Innovation Scheme are accepted. MOM verifies the status electronically, and provisional filings or claims under objection receive 0 points.
How recent must export evidence be? Export intensity is measured over the most recent completed financial year. If the EP application is filed in 2026, the firm must use audited data for FY2025, accompanied by TradeNet permits for the same period.
参考资料
Ministry of Manpower – COMPASS C6 Bonus Criteria 2026
Inland Revenue Authority of Singapore – Research and Development Tax Deduction Guidelines 2025
Singapore Customs – TradeNet Export Permit Requirements 2026
Enterprise Singapore – Enterprise Innovation Scheme (EIS) Application Guide 2025
This article does not constitute legal or migration advice.