Since September 2023, COMPASS (Complementarity Assessment Framework) has applied mandatory scoring to all Employment Pass (EP) applications. The Diversity criterion carries 20 points, and 40 points is the pass threshold. If any one nationality makes up more than 25% of your employer’s local PMET workforce, you lose those 20 points outright. The current Diversity threshold is 25%: if same-nationality local PMET reaches 25% or above, you score 0. For applicants from highly concentrated nationalities such as mainland China, India and Malaysia, this means the structural risk to an EP application is rising. You must calculate your company’s nationality share precisely before applying, or you may fail to clear the COMPASS threshold at all.
How the Nationality-Share Test Works
Under COMPASS, the Diversity criterion measures the share of your employer’s local PMET workforce that holds the same nationality as you. Diversity is scored in three bands: below 5% same-nationality local PMET scores 20 points, 5% to below 25% scores 10 points, and 25% or above scores 0. Ministry of Manpower (MOM) Regulation No. 3 (2023), published in the Government Gazette on 28 August 2023, states expressly: “If the proportion of local PMET of the same nationality as the applicant is ≤ 25%, the Diversity score is 20 points.” MOM calculates by exact ratio: among 20 local PMET, 5 of the same nationality is 25%, falling within the “25% or above” band for 0 points; 4 is 20%, within the “5% to below 25%” band for 10 points.
Denominator: Local PMET Only
MOM defines “local” as Singapore citizens and permanent residents (PR) in PMET roles. Foreign PMET on an EP, S Pass or Work Permit are excluded from the denominator. This means a company with 100 local PMET and 50 foreign PMET counts only those 100 local PMET. If your company relies heavily on foreign staff, the denominator shrinks and your same-nationality share may be higher.
Numerator: By Passport, Not Race
Nationality is determined by citizenship, not race. An ethnic-Chinese Singapore citizen does not share your nationality (Chinese national). An ethnic-Chinese Malaysian citizen holding Malaysian PR also does not share your nationality (Chinese national). Only local PMET holding the same passport as you count in the numerator. This is often misunderstood — many applicants assume a “Chinese-heavy” company is safe, when the opposite may be true.
Company Level, Not Group Level
The test applies to a single ACRA-registered entity (UEN). Different subsidiaries under a group each have their own UEN and their own local PMET share. If you work for a large MNC’s Singapore subsidiary, only that subsidiary’s local PMET data count. If hired through a third-party manpower agency, the agency’s data are used, not the client company’s.
How to Calculate Your Company’s Nationality Share
MOM does not publish company-level nationality data. You must request it from HR or the colleague handling EP applications. If the company refuses, you can infer from MyCareersFuture.sg and the annual report, but precision is limited. The full steps follow.
Step 1: Confirm the Denominator
Obtain the total number of local PMET currently employed by your registered entity. Local PMET include Singapore citizens and PR in PMET-level roles. Exclude foreign employees (EP, S Pass, Work Permit, other work passes). Exclude local non-PMET staff (such as administrative assistants, technicians and other roles below PMET level).
Step 2: Confirm the Numerator
Count the local PMET of the same nationality as you. Note: count only local PMET holding the same passport as you at the time of application. A Chinese-national applicant counts only Chinese-national local PMET, not ethnic-Chinese Singapore citizens or ethnic-Chinese Malaysian PR holders.
Step 3: Calculate the Ratio
Numerator ÷ denominator × 100 = percentage. Example: 4 Chinese nationals among 20 local PMET is 20%, pass. 6 Chinese nationals is 30%, fail. MOM calculates by exact ratio — 5 of the same nationality among 20 local PMET is exactly 25%, within the “25% or above” band, scoring 0.
Step 4: Assess the Impact on Your Application
If the ratio exceeds 25%, Diversity scores 0. You must recover those 20 points from the other five COMPASS criteria (salary, qualifications, support for local employment, skills, strategic economic priorities). The baseline requirement is a total score of ≥ 40. Losing 20 points means you need full marks on at least three criteria to clear the threshold. For applicants without an edge in salary or qualifications, this is nearly impossible.
Potential Impact of 2026 Policy Tightening
COMPASS Diversity thresholds are set by official MOM announcements. MOM press release of 18 February 2025 states verbatim: “MOM will adjust the Nationality-Share threshold to ensure the Diversity criterion remains effective as Singapore’s labour market evolves.” Any threshold change is subject to formal MOM announcement. If this adjustment takes effect, applicants sitting exactly at 25% will drop straight to 0. Those planning to apply for an EP in 2026 or later must assess this risk in advance.
Structural Disadvantage from Industry Concentration
Some industries show clear nationality concentration. Local PMET nationality distributions differ by industry; applicants may ask their employer for the company’s own data. If your nationality is over-represented in your industry, your Diversity score is structurally disadvantaged. This is not a matter of personal ability but a systemic barrier set by company workforce structure.
Renewals Are Affected Too
The Diversity test applies to every new application and every renewal. If your company’s local PMET composition changes between renewals, your score may shift accordingly. Monitor the company’s hiring pattern annually. If your company keeps hiring local PMET from a single nationality, your renewal risk will rise year on year.
Strategic Responses for Applicants
Facing the Nationality-Share test, you have three paths.
Path 1: Coordinate Application Timing
Nationality share is calculated at each application using the company’s workforce data at that time. If your company hires local PMET of other nationalities before you apply, your same-nationality share may fall below 25%. This is a legitimate strategy: coordinate with HR and submit after a diversity hiring round. Note that MOM does not accept “anticipated hiring” as a basis for early application; only hiring already completed at the point of application counts.
Path 2: Change Employer
If your current company cannot meet the Diversity threshold, consider moving to a company with a more balanced local PMET nationality mix. Target firms should have a large base of Singapore-citizen PMET, as this dilutes the share of any single foreign nationality. In technology and financial services, prioritise firms led by local management teams over MNC subsidiaries dominated by foreign executives.
Path 3: Obtain Data Early
Send a formal written request to HR using this template: “I am applying for an Employment Pass under UEN [insert UEN]. Please provide the total number of local PMET (Singapore citizens and PR) employed by the company as at [date], and among them the number of local PMET of Chinese / Indian / Malaysian nationality.” Companies may decide whether to provide internal staff data, but most will cooperate to advance the application. If the company refuses, external public information is for reference only and precision is limited.
Indirect Impact on PR Applications
The Diversity criterion does not apply directly to PR applications. Immigration & Checkpoints Authority (ICA) uses separate criteria to assess PR eligibility. But an EP application that fails on low Diversity may delay your PR path — you need a valid EP to maintain residence in Singapore before you can apply for PR. If EP renewal fails, your PR application may be hindered by a break in residence continuity.
Three Actionable Takeaways
- Obtain your company’s local PMET nationality data immediately: request it from HR at least 3 months before submitting your EP application; do not wait until the application window closes.
- If your same-nationality share is close to 25%, prioritise a job move or coordinated hiring timing: the 2026 threshold may drop to 20%; act now or you may be out next year.
- Monitor the company’s hiring pattern and assess renewal risk once a year: the Diversity test is not a one-off check; renewals are also affected. If the company keeps hiring from a single nationality, prepare a contingency plan 6 months before renewal.