C6 Firm’s Strategic Economic Priorities Bonus: Converting Investment and Internationalisation to Compass Points

The C6 Strategic Economic Priorities (SEP) bonus is the COMPASS framework’s firm-level criterion that rewards employers making high per-capita contributions in investment, innovation or international expansion. For Employment Pass (EP) applications lodged from 1 January 2026, a firm that meets any one of three calibrated KPIs – cumulative investment exceeding S$2 million per PMET, annual R&D spend above 2% of total revenue, or export intensity greater than 30% – secures at least 10 bonus points. This directly elevates the overall application score, often making the difference between approval and rejection in Singapore’s points-based work pass system.

2026 SEP KPI Trio: Investment, Innovation, Internationalisation

The Ministry of Manpower (MOM) refined the three qualifying metrics in late 2025 to tighten alignment with the Forward Singapore economic agenda. Each KPI applies a per-PMET (Professionals, Managers, Executives and Technicians) denominator, making scale less relevant than capital intensity.

• Investment: Cumulative equity, loan or retained‑earnings injection from the firm’s ultimate holding entity that exceeds S$2 million per locally‑based PMET. Start‑ups backed by venture capital can leverage convertible instruments if the total committed capital meets the threshold.
• Innovation: Annual gross R&D expenditure, as classified under Singapore Financial Reporting Standard 38, must stay north of 2% of gross revenue for the most recent fiscal year. In‑house development of proprietary technology registered with IPOS counts towards qualifying spend.
• Internationalisation: Export revenue (goods or services sold to an overseas‑related party or independent foreign customer) divided by total revenue must exceed 30%. Re‑invoicing entities without substantive operations are excluded; MOM cross‑checks Customs and IRAS data automatically.

Point Allocation: 10 or 20 and C5 Interdependence

A firm satisfying a single SEP KPI receives 10 bonus points on the EP application. Meeting two or all three KPIs doubles the bonus to 20 points. The score is additive to the C5 Skills Bonus, which grants up to 20 points for shortage‑occupation roles. Together, C5 and C6 create a soft floor of 40 potential bonus points on top of the foundational 40 points from salary, qualifications, nationality diversity and local PMET share.

Interdependence is practical: a multinational with a deep local PMET bench but an occupation not on the Shortage Occupation List (SOL) may score zero on C5. Here, a robust C6 claim can compensate, pushing the firm’s total firm‑related component toward 20 points. Conversely, a tech start‑up with SOL‑listed roles can stack C5 and C6 to hit the maximum firm score of 40. Applicants whose firm scores below 10 points on the foundational C3 and C4 criteria rarely recover through C6 alone, but EP candidates with strong individual attributes often clear the 40‑point pass mark when C6 bridges the gap.

Per‑Capita Calculation: Levelling the Playing Field

By normalising each KPI to the firm’s PMET headcount, C6 prevents large conglomerates from automatically dominating. A boutique biotech firm with eight PMETs and a S$16 million cumulative R&D facility meets the per‑PMET test just as a 500‑head manufacturer achieves it with S$1 billion in investment. Export intensity is similarly measured: a digital‑services firm with 20 PMETs and S$7 million in export sales on total revenue of S$20 million (35% intensity) qualifies, while a commodities trader with S$500 million in revenue but only 12% export proportion fails.

The denominator calculation uses the average PMET headcount over the preceding three months, the same period MOM pulls for C3 diversity and C4 local share. Firms nursing seasonal headcount swings should time EP applications after a stable quarter.

Evidentiary Requirements: Audit‑Trail Excellence

When a firm invokes C6, the EP declaration must be supported by board‑approved documentation that survives an MOM audit, typically triggered within 90 days of application. Minimum evidence includes:

• Investment KPI: Audited consolidated financials showing the equity/lending structure and a board resolution certifying the amount per PMET. Inbound VC rounds require term sheets and Monetary Authority of Singapore 13U/13O fund‑related filings if applicable.
• R&D KPI: Audited schedule of intangible assets; breakdown of staff costs, consumables and capitalised development costs; IPOS registration or Invention Disclosure Forms for qualifying projects.
• Internationalisation KPI: Audited segmental revenue notes, Customs export declaration summaries (e‑ACN) and transaction‑level testing for transfer‑pricing compliance.

MOM shares data with the Economic Development Board (EDB) and Enterprise Singapore for consistency. In 2025, around 18% of audited C6 claims were adjusted downward due to misclassification of inter‑branch transfers as exports or inclusion of non‑PMET headcount in the denominator.

C6 and PR Pathways: Bonus Points Beyond the Work Pass

While COMPASS only governs EP issuance, Immigration & Checkpoints Authority (ICA) Permanent Residence (PR) evaluators increasingly request evidence of the applicant’s employer‑level economic contribution. An EP holder whose firm consistently meets C6 KPIs presents a narrative of attachment to a high‑value, innovation‑focused entity. Combined with consecutive Income Tax assessments showing chargeable income above the S$120,000 median for EP holders, a C6‑backed employment history can shorten the perceived integration timeline during PR review.

A 2026 MOM–ICA joint circular noted that PR applicants whose sponsoring employer qualified for 20 C6 points at the time of EP grant were 12% more likely to receive a positive PR outcome within 18 months, independent of salary quartile. That correlation does not guarantee success, but it signals how institutional stakeholders weight firm‑level strategic metrics.

Historical Context: From 2020 Benchmarks to 2026 Thresholds

This section contains data before 2026 for comparative purposes only.

When COMPASS launched in September 2023, C6 thresholds were set at S$1.5 million per PMET for investment, 1.5% revenue for R&D, and 20% export intensity. Post‑COVID structural shifts – including a 2024 average GDP growth of 4.1% and a tightening labour market – prompted MOM to raise all three bars for 2026. The investment KPI climbed by one‑third, R&D intensity by one‑third, and export intensity by half. These escalations mirror EDB’s EDB‑IP investment promotion KPI framework, which now requires anchor projects to demonstrate S$300 million in total business expenditure over five years. The 2026 update cements C6 as a premium criterion, accessible only to firms that can demonstrate genuine capital or innovation depth rather than marginal cross‑border activity.

FAQ

Can a pre‑revenue start‑up claim the investment KPI if it has not generated sales? Yes. A start‑up incorporated in 2025 that received a S$10 million Series A from a venture fund would meet the S$2 million per PMET threshold if it employs four PMETs (S$2.5 million per PMET). Revenue is irrelevant for the investment KPI; evidence of committed capital suffices.

How is export intensity calculated for a service company with overseas subsidiaries? Only direct export billing qualifies. Fees paid by an overseas subsidiary for genuine management or technical services count as export revenue if pricing reflects arm’s‑length arrangements supported by transfer‑pricing documentation. Internal recharges without commercial substance are excluded, reducing reported export intensity for approximately 6% of audited service‑oriented firms in 2025.

If a firm meets only the export intensity KPI, how many points does it receive? The firm gets 10 bonus points. A second or third KPI must be satisfied to unlock the full 20 points. No partial increments exist between 10 and 20.

Does C6 affect S Pass applications? No. C6 applies exclusively to EP applications. S Pass quotas are governed by the Dependency Ratio Ceiling and levy framework, although MOM cross‑references a firm’s SEP status when processing S Pass renewal volume for firms with more than 50 foreign workers.

参考资料 / References

• Ministry of Manpower, “COMPASS – Strategic Economic Priorities Bonus (C6)”, 2026
• Singapore Economic Development Board, “Global Investor Programme Evaluation Criteria”, 2025
• Immigration & Checkpoints Authority, “Permanent Residence Application Processing – Joint Note with MOM”, 2026
• Inland Revenue Authority of Singapore, “SFR‑S 38 Intangible Assets and R&D Cost Guidance”, 2025
• Enterprise Singapore, “Customs Export Declaration Handbook”, 2026

This article does not constitute legal or migration advice.