Can EP or S Pass Holders Volunteer or Take Side Work in Singapore?

What does the law say about who a pass holder can work for?

A work pass ties the holder to one employer and one type of work. Section 12(1) of the Employment of Foreign Manpower Act 1990 (EFMA) provides that a work pass is valid only in respect of the employer and the foreign employee specified in it, and only for the trade, sector, occupation or type of employment specified in the pass (or submitted in the application), or any other one the Controller of Work Passes has approved.

For any other organisation, the pass holder therefore has no valid work pass. MOM states the policy plainly in its FAQ on multiple jobs: all work pass holders must only work for their designated employer, and must not take on additional jobs or engage in activities to earn additional income in Singapore. For S Pass holders, MOM’s S Pass FAQ says the holder can only work for one employer at a time.

Each pass also carries conditions set out in the Schedules to the Employment of Foreign Manpower (Work Passes) Regulations 2012, with separate Schedules for the S Pass and the Employment Pass.

Does it matter if the work is unpaid?

Less than most people expect. Section 2 of the EFMA defines “employ” as engaging or using the services of a person for any work, whether under a contract of service or otherwise, and “with or without salary”. Unpaid work can therefore still be employment for work pass purposes.

The question is what the activity really is. A useful way to test it:

• Who benefits? If a business gains labour, content, sales or a service it would otherwise pay for, the arrangement looks like work, even if no money changes hands.
• Is there any reward? Fees, honoraria, commissions, free products, travel or “exposure” given in return for a service all point towards work.
• Is it a role? Regular hours, a job title or supervision by the organiser suggest employment.
• Is the cause charitable? Helping at a charity drive, unpaid, is very different from helping a commercial event.

MOM’s published position on volunteering appears on its secondary directorship page: Employment Pass holders do not need a Letter of Consent to take part in volunteer activities if no payment is involved and the activities are for a charitable purpose. Both conditions must be met. An unpaid stint for a commercial business is not covered by that statement.

Can I speak at a conference or coach a team outside work?

Only if the activity is part of your job for your own employer, or it falls within a route MOM has approved.

Two hypotheticals illustrate the line:

• A marketing executive on an Employment Pass is invited to speak at a paid industry conference for a fee. The fee is paid by the organiser, not the employer, and the talk is the executive’s own engagement. On MOM’s stated policy, this is an activity to earn additional income and is not permitted on the pass. If the employer sends the executive as its representative, without a personal fee, the position is different, because the executive is then working for the employer named on the pass.
• An engineer on an S Pass is asked to coach a neighbourhood club’s football team. If the club pays a coaching fee, that is a second job. If it is unpaid, the answer turns on whether the activity is genuinely charitable volunteering. MOM’s published volunteering statement refers to Employment Pass holders, so an S Pass holder in this position should obtain MOM’s view in writing first.

MOM does operate Work Pass Exempt activities for speakers, trainers, performers and sports personnel, but the published conditions are framed around foreigners entering Singapore on a Short-Term Visit Pass, who must notify MOM before starting and are limited to 90 days in a calendar year. MOM’s pages do not say that these exemptions extend to someone already holding an Employment Pass or S Pass for another employer, so do not assume they do.

What about performers and events?

A performer who holds an Employment Pass or S Pass for one employer cannot perform for a different organiser on that pass, whether paid or unpaid, unless MOM has approved it. The pass is valid only for the named employer under section 12(1) of the EFMA.

Organisers should also note recent changes to the routes for engaging performers:

Route	Current position on MOM’s website
Work Permit for Performing Artiste	The scheme has ceased. MOM announced that it would stop accepting new applications from 1 June 2026; existing holders may stay until their passes expire or are cancelled.
Work Pass Exempt (performances)	Covers actors, singers, dancers and musicians at events supported by the Government or a statutory board, or at public performance venues, with exclusions for bars, nightclubs, hotels, private clubs and similar venues holding a Category 1 Public Entertainment Licence. Framed around short-term visitors.
Miscellaneous Work Pass	Not a route for performers. It covers speakers at seminars relating to religion, race, community or political causes, religious workers and certain journalists, for up to 60 days, with a Singapore sponsor (MOM eligibility page).
Regular work pass or service provider	MOM points businesses to engaging entertainment service providers, or hiring eligible performers on a regular work pass.

What happens if the rules are broken?

Both the pass holder and the organiser face criminal exposure, and the pass holder can lose the right to work in Singapore. The EFMA provisions are:

• The pass holder working for someone else. Section 5(2) provides that a foreign employee must not be in the employment of an employer without a valid work pass. The penalty under section 5(7) is a fine of up to $20,000, imprisonment of up to 2 years, or both.
• The pass holder breaching a pass condition. Under section 22(1)(a), a foreign employee who contravenes a condition (other than a regulatory condition) of the work pass commits an offence, punishable under section 22(1)(h) by a fine of up to $10,000, imprisonment of up to 12 months, or both.
• Side business. A foreigner who engages in a trade or business for gain on their own account without a valid work pass risks an offence under section 10(1), with a fine of up to $20,000, imprisonment of up to 2 years, or both on a first conviction (section 10(2)(a)).
• The pass itself. Section 7(5) allows the Controller to revoke a work pass and to debar a person from applying for or being issued a work pass for a fixed period.
• The organiser. Section 5(1) prohibits employing a foreign employee who does not have a valid work pass. Under section 5(6), a first conviction carries a fine of $5,000 to $30,000, imprisonment of up to 12 months, or both, with mandatory imprisonment for individuals on a repeat conviction. Officers of a company may be personally liable under section 20, and anyone who abets an offence is guilty of it under section 23. For more on this exposure, see our guide to illegal employment under section 5 of the EFMA.
• The pass holder’s own employer. Section 5(3) prohibits employing a foreign employee otherwise than in accordance with the conditions of the work pass, with a fine of up to $10,000 under section 5(8). An employer that lends staff to another business can be caught.

If your pass has been cancelled, our article on your rights when a work pass is cancelled explains what follows, and our guide to Employment Pass rejections and appeals covers later applications.

What should I do before saying yes?

Check first, get it in writing, and do not start until the position is clear.

• Ask your employer. If the activity can properly be done as part of your job, your employer can send you as its representative. Your employer’s consent alone does not authorise work for another organisation.
• Check whether a formal route exists. For Employment Pass holders, MOM issues a Letter of Consent for secondary directorships in related companies. For other engagements, the organiser may need to apply for the correct pass for the activity.
• Ask MOM in writing. Where the position is unclear, set out the facts and obtain MOM’s answer in writing before the activity begins.
• Keep a record. Note that the activity is unpaid, its charitable purpose, and that no reward in kind is given.
• Organisers: check passes. Before engaging a foreigner, confirm who the pass is issued for and whether your engagement falls within it.

If MOM has already contacted you about an engagement, read our guide to MOM investigations and your rights before giving a statement.

---

Frequently asked questions

Can an Employment Pass holder volunteer in Singapore?

Yes, within limits. MOM states that Employment Pass holders do not need a Letter of Consent for volunteer activities where no payment is involved and the activity is for a charitable purpose. Unpaid help to a commercial business is not covered.

Can an S Pass holder take a part-time job with a second employer?

No. MOM states that an S Pass holder can only work for one employer at a time. The S Pass is valid only for the employer named on it.

If I am not paid, is it still work?

It can be. The EFMA defines “employ” to include engaging a person for work with or without salary. What matters is the substance of the arrangement, not only whether money is paid.

Can my employer give me permission to work for another company?

Not on its own. The pass is valid only for the employer named on it, so work for another organisation needs MOM’s approval or the correct pass. Your employer’s consent is relevant, but it is not a substitute for MOM approval.

Can an Employment Pass holder own shares in another company?

Yes. MOM states that an Employment Pass holder may own shares in a Singapore-registered company. Owning shares is different from working in or running that business, which raises the issues discussed above.

This article is for general information only and is not legal advice. The law stated is as at October 2026.