Workplace Fairness Act and first public employment tribunal judgment — what it means for you and your business.
People you employ. Contractors and platform workers do not count.
Employment Pass, S Pass or similar.
A page in the staff handbook counts, so long as it is written down.
s27(1) — The Act asks for a written process. An open-door policy is not enough, because there is nothing to point to.
Not just that you will. The steps you take.
s27(1)(a)–(b) — You must inquire and review “in a stated manner”. Handling complaints “fairly and promptly” does not state a manner.
For example, in writing, within a set number of days.
s27(1)(c) — You must inform the person of the outcome “in a stated manner”.
A number of years, written down.
s27(1)(d) — Records of every inquiry and review must be kept “for a stated period”. “As required by law” states no period.
And what they told you.
s27(1)(e) — You must not disclose the person's identity or the information, unless it is reasonably necessary.
Having the process and telling people about it are two separate requirements.
s27(2) — A separate obligation from having the process at all.
Including someone they only suspect is about to.
s28 — The Act catches retaliation where the employer knows or suspects a person intends to complain, not only after they have.
Age, nationality, sex, marital status, pregnancy, caregiving, race, religion, language ability, disability, mental health.
ss5–7, 17–19 — The Act reaches hiring, decisions during employment, and dismissal. A job advertisement can breach it on its own.
And does the person you hire do that job, at the salary you advertised?
s26 — This part applies even if you employ fewer than 25 people.
TAFEP publishes the Fair and Progressive Employment Index. It takes about twenty minutes and covers more ground than this does. fairprogressive.sg →
This check is quicker and narrower. It begins with one part of the wider compliance load: which Workplace Fairness Act steps you have not completed yet.
The Workplace Fairness Act has not started yet. This has. The Employment Claims Tribunals have heard employment claims since April 2017 and wrongful dismissal claims since April 2019, but until 15 May 2026 none of their first-instance decisions had been published to the public. JGP v JGQ is the first, and it moved the line on what an employer must do before dismissing someone.
Dismissal claims lodged with TADM more than doubled between 2022 and 2025. The share that mediation could not settle, and which went on to the Tribunals, is at its highest on record.
MOM Employment Standards Report annexes, 2022 to 2025. The rate per 1,000 employees reached 0.57 in 2025, the highest since the regime began on 1 April 2019 and 54% above the 2019 rate of 0.37.
Retrenchment and dismissal disputes move together. Redundancies have stayed high since 2023.
MOM Labour Market Survey. In 2025 employers paid about $2.71 million on dismissal claims and about $22 million on salary claims. MOM linked the rise to reorganisation, restructuring and closures, not to falling standards.
JGP v JGQ [2026] SGECT 1. The employee won $17,332. Eight things moved.
| Before | After | |
|---|---|---|
| Due inquiry | Read as a rule for summary dismissal only. | The duty attaches to the ground, not the mode. You must hold an inquiry even when you give notice or pay salary in lieu. |
| What an inquiry is | One High Court case, turning on a contract clause. | Three parts: clear notice of the allegations; a real chance to answer; open-minded consideration of the answer. |
| Burden of proof | On the employer, but the width was untested. | Two stages. Prove the reason is true, then prove it is sufficient to justify dismissal rather than a smaller penalty. |
| State of mind | No guidance. | Allege dishonesty and you must prove it. A pattern of conduct is not enough — you must show the person knew and continued. |
| A lesser wrong | No guidance. | If the stated ground fails, a lesser wrong can replace it — but only within the same gravamen, and only if you put it to the employee first. |
| Parity | No Singapore authority. | Treat like cases alike, or record a principled reason for the difference. It is a cross-check on proportionality. |
| Your own code | Unclear. | An internal disciplinary code does not raise the statutory threshold. Breaching it is evidence, not proof. |
| Money | No worked example. | Loss of income and harm are separate heads. Salary in lieu of notice, already paid, does not reduce the award. |
Nine further decisions followed between July and August 2026, and they run the same way: the Tribunals look at what the employer actually did, not only at what the contract permitted. One employer lost the full $30,000 limit for dismissing during probation with no periodic reviews and expectations never communicated. Another lost $20,000 in full because it could not produce records, and the tribunal drew an adverse inference.
How much weight this carries. The Tribunals are a court of first instance. The decision is persuasive and it does not bind the General Division of the High Court. Reports indicate the employer applied for permission to appeal the related decisions; we have not confirmed that from a primary source. Appellate authority on wrongful dismissal already exists and is unaffected — for example Tan Tung Wee Eddie v Singapore Health Services Pte Ltd [2025] SGHC(A) 12. What was missing until May 2026 was reasoning from the Tribunals themselves, released to the public.
The Tribunals have heard employment claims since April 2017 and wrongful dismissal claims since April 2019. Until this decision, none of their first-instance grounds had been published to the public. It changes what an employer must do before dismissing someone for misconduct.
An employee earning $4,333 a month made 62 medical benefit claims totalling $9,989.64 over six months, for vitamins, supplements and skincare from one clinic. A three-person committee first proposed a warning and a bonus cut. The Global Head of HR asked them to look again; they then proposed dismissal. She was dismissed for intentional misconduct involving dishonesty.
Due inquiry: satisfied. She had the allegations, a chance to answer, and her answer was considered.
Dishonesty: not proved. The pattern was equally consistent with honest mistake. Invoices carried no item detail, colleagues did the same, and no document told her the claims were not allowed.
A lesser wrong: proved. She was negligent, relying on practice rather than the written policy.
Dismissal: not proportionate. The practice was widespread, she was junior with a clean record, and comparable staff got warnings or bonus cuts with no explanation for the difference.
Result: dismissal without just cause or excuse. $17,332 awarded — loss of income at the three-month cap ($12,999) plus harm ($4,333, being a two-month base less one month for her own negligence). The discretionary bonus claim failed.
How much weight this carries. The Tribunals are a court of first instance. The decision is persuasive and does not bind the General Division of the High Court. Reports indicate the employer sought permission to appeal the related decisions; that is not confirmed from a primary source. The tribunal read a sufficiency test into section 27(2)(b) of the Employment Claims Act 2016, which is wider than the words of the provision and has not been tested on appeal. Appellate authority on wrongful dismissal already exists and is unaffected.
Sources. JGP v JGQ [2026] SGECT 1 and the further 2026 decisions, elitigation.sg · Employment Act 1968 s14 · Employment Claims Act 2016 ss27, 35 · Employment Claims Regulations 2017, Second Schedule · Long Kim Wing v LTX-Credence [2017] SGHC 151 · Phosagro Asia v Piattchanine [2016] SGCA 61 · Dong Wei v Shell Eastern Trading [2022] SGHC(A) 8 · MOM Employment Standards Report annexes 2022–2025 · MOM Labour Market Survey.
Beyond Horizons by Bethel Chambers LLC · beyondhorizons.sg · This note is a summary for information. It is not legal advice for any particular matter and does not consider your circumstances. The law is stated as at 17 August 2026.
Two of these arrive together. A dismissal now has to survive a due inquiry, proof of every stated reason, and a parity check — today. From the end of 2027 the Workplace Fairness Act adds a separate claim on top of that, on grounds including pregnancy, caregiving responsibilities and mental health condition.
Which raises a practical question about who does this work for you.
Workplace fairness is the one with a date on it. Below are the others already sitting on a Singapore business, each with its own regulator, its own deadline and its own way of finding out you did not do it.
Breach notification has been mandatory since 1 February 2021. You must notify the PDPC where a breach is likely to cause significant harm, or affects 500 or more individuals — no later than three calendar days after you finish assessing it.
31 December 2026. The PDPC has said private organisations must stop using NRIC numbers for authentication.
Singapore does not require you to keep data here. It requires that whoever receives it abroad offers protection comparable to the PDPA, or that you fall inside a recognised exception. That is a contractual and diligence obligation on every overseas processor, cloud region and group company you send data to.
Under section 26 of the Workplace Fairness Act you must publish a job advertisement before applying for a work pass, consider every response in good faith and fairly, and ensure the pass holder does the advertised job at the advertised salary.
This one binds you even under 25 employees. Section 4(1)(a) exempts small employers from the Act “except for section 26”.
The IMDA and PDPC Model AI Governance Framework is voluntary. The PDPA's accountability obligation is not. If an AI system touches a decision about a person, you need internal governance, risk controls and review mechanisms proportionate to the use — and you need them written down.
The tribunals have already moved on dismissal, as Segment 2 sets out. The Workplace Fairness Act follows at the end of 2027 with a separate claim on eleven protected characteristics. Flexible work request guidelines and expanded parental leave sit underneath both.
Licence conditions and renewals, statutory filings and returns, consumer protection and product obligations, and the sector rules that come with a MAS, MOH, NEA or IMDA licence. These differ by business, which is exactly why they are the ones that get missed.
None of these is hard on its own. Each is a document, a process, and someone who remembers it exists before the regulator asks. The difficulty is that they arrive on six different calendars, from six different bodies, and none of them cares that you were busy with the others.
So the question is not which law to worry about. It is who holds all of them.
Match the legal support model to the work you need done.
Workplace fairness is one law. Licence conditions, employment obligations, data protection and anything crossing a border are the rest of it, and they do not arrive on a convenient schedule. There are three ways to cover that work: employ someone, take a placement from an agency, or retain a law practice.
Six questions, about a minute. You will see how the three options differ as you work through them.
Question 1 of 6
We would rather you checked this than took our word for it. Put in the salary you would actually pay.
Defaults are the September 2026 mid-point for senior legal counsel in Singapore, and the middle of our band.
| Salary, 12 months | S$156,000 |
| Annual wage supplement, one month | S$13,000 |
| Employer CPF at 17%, ordinary wages | S$16,320 |
| Employer CPF at 17%, additional wages | S$1,020 |
| Recruitment fee, 20% of first-year salary | S$31,200 |
| Year one, employed | S$217,540 |
| Each following year | S$186,340 |
| Retainer, 12 months | S$72,000 |
| Five-year difference | S$602,900 |
Where each input comes from. Employer CPF is 17% for employees aged 55 and below, on an Ordinary Wage ceiling of S$8,000 a month from 1 January 2026, annual ceiling S$102,000. The annual wage supplement is one month. The recruitment fee is 20% of first-year salary; agencies quote 20–25% and we use the lower figure. We compare with the cost of employing a lawyer. We do not compare our fees with those of any other law practice.
Three ways to buy legal advice. Hover or tap any mark for the reason and the source.
| Bethel Chambers LLC | Employed in-house counsel | Lawyer placed by an agency | |
|---|---|---|---|
| Compulsory professional indemnity insurance behind the advice | As a law corporation the minimum is S$2 million for each and every claim, inclusive of costs. Cover must be proved before a practising certificate is issued. | Not compulsory. Your company carries the risk of your employee's error under its own policies. | The agency states it does not offer legal advice, so no professional indemnity cover attaches to the advice. |
| A practising certificate, renewed every year | Held and renewed annually. Renewal is conditional on both insurance and continuing education. | Not required to advise your own employer, and many in-house counsel do not hold one. | Depends entirely on the individual placed. Ask. |
| Mandatory continuing legal education | 16 CPD points each year, of which at least 3 must be in ethics and professional standards. Our cost, not yours. | SILE states that lawyers without a Singapore practising certificate, such as in-house counsel, are not required to meet the CPD points requirement. Training becomes your budget and your decision. | Same position, and not your budget to control. |
| Privilege rests on a clear statutory basis | Section 128 of the Evidence Act 1893: communications with an advocate or solicitor in the course and for the purpose of professional employment as such. No employment relationship required. | Section 128A, real and settled since the 2012 amendment. Section 3(7)(a) defines legal counsel as a person who is an employee of an entity employed to provide legal advice. Your employee meets that test. | We cannot find the provision. Section 128 needs an advocate or solicitor acting for a client. Section 128A needs a legal counsel in your entity, and a placed contractor is generally not your employee. Section 128A(4) extends only to related corporations under section 6 of the Companies Act, and an agency is not one. |
| Privilege survives the commercial conversation | Section 128 has no equivalent carve-out. What you say to your solicitor is said to a solicitor. | Sections 128A(2)(c) and (d) exclude any communication not made for the purpose of seeking legal advice, and documents acquired otherwise. In-house counsel sitting in a commercial meeting is the classic exposure. | The same exclusions would bite, if section 128A reaches the arrangement at all. |
| Privileged in a European Commission competition investigation | Independent external lawyers are the category the Court of Justice protects. | Akzo Nobel: an in-house lawyer's position as an employee does not allow them to ignore the employer's commercial strategies, so professional independence is not made out. Directly relevant if you sell into the EU. | No better, and probably worse. |
| A complaints and disciplinary route for you if something goes wrong | You are a client. The Law Society of Singapore's complaints and disciplinary process is open to you. | The matter is internal. Your remedy against your own employee is an employment matter. | A commercial contract with a staffing supplier. |
| A professional duty to check for conflicts before acting | Rules 20 to 22 of the Professional Conduct Rules 2015: conflicts between two or more clients, between a current and a former client, and between the client and the practice itself. The check runs before we take the work, and it can stop us taking it. | One employer, one client. This particular risk does not really arise for an employee. | An employment agency is not a law practice, so it is not subject to those rules. Nothing in the arrangement requires anyone to check who else the placed lawyer is working for — including a competitor, or the other side of a live dispute. |
| Cover continues through leave and illness | A named lead counsel and a named deputy, both holding your matters. | Up to 14 days annual leave and 14 days paid outpatient sick leave a year, and up to 60 days hospitalisation leave. One person is one point of failure. | Depends on the agency's bench and on your contract. |
| No CPF, no annual wage supplement, no recruitment fee | A professional fee, fixed monthly in the engagement letter. | Employer CPF at 17%, a thirteenth month, and 20 to 25% of first-year salary to an agency. | No employment on-costs, though the agency margin sits inside the rate. |
| Ends on notice, with no severance and no second search | The engagement letter governs. No employment claim, no re-recruitment. | A hire that does not fit costs the notice period, a second recruitment fee, and the months before the decision is taken. | Placement contracts are built to end. |
What a retainer actually covers. Business as usual, plus the things that only look urgent because nobody was watching for them.
Group reorganisations, holding structures and intra-group transfers. Most of the risk is in doing the steps in the right order, and in the records that show you did.
Preparing for and responding to MOM and MAS. This work starts long before a notice arrives, because an inspection tests the record you already hold, not the explanation you can give afterwards.
Complaints, terminations and grievances at the stage where they can still be settled, which is where most of them end. If a matter does go to proceedings, our in-house disputes team takes it through to the finish. Either way it turns on the documents, which is the argument for writing them properly the first time.
The rule that has not commenced yet. The Workplace Fairness Act in 2027, licensing changes, and what your regulator has signalled but not yet published. Cheaper to build for than to retrofit.
Model and service terms, rights over your data and whether it trains anything, indemnities for automated output, liability caps that survive a hallucination, audit and exit rights, and what happens when the vendor silently changes the model underneath you. These contracts are drafted by the vendor, for the vendor, and are usually presented as standard.
Whatever you decide above, one person is one point of failure. This is the year you actually get from a single employee.
Each square is one working day in a year. The maroon squares are the ones a single employee is entitled to be away.
The band depends on volume and scope. Both are fixed in the engagement letter before work begins.
We do not charge by the hour for retained work, and we do not bill for the first conversation.
We give no guarantee of outcome. We commit to a named lead counsel, a named deputy, and a response time stated in the engagement letter.
Beyond Horizons is the practice of Bethel Chambers LLC, a Singapore law corporation. Privilege: Evidence Act 1893, ss 128, 128A, 131 and the definition of "legal counsel" in s 3(7), read from Singapore Statutes Online on 5 September 2026; Akzo Nobel Chemicals Ltd v European Commission (Court of Justice, 2010) on in-house counsel in Commission competition investigations. Privilege depends on facts we have not seen and this page is general information, not advice on your position. Every figure on this page comes from a public source. Salary band: MyCareersFuture, sweep of live Singapore postings, September 2026. CPF rates and wage ceilings: Central Provident Fund Board, effective 1 January 2026. Leave entitlements: Employment Act as published by the Ministry of Manpower — 14 days annual leave at maximum entitlement, 14 days paid outpatient sick leave and up to 60 days paid hospitalisation leave after six months of service, against a 260-day working year. Professional indemnity insurance: the Law Society of Singapore's compulsory scheme. Continuing education: the SILE CPD Scheme. Recruitment fee: published agency rates of 20% to 25% of first-year salary.
We compare our fees with the cost of employing a lawyer. We do not compare our fees with those of any other law practice.
Succession, holding structures, family assets and governance. The work meant to outlast the person who started it.
Our cross-border practice. Anchored in Singapore, working where the counterparty, the asset or the regulator sits somewhere else.
The majority of the team working on your matters come from more than five years of top-tier cross-border practice at magic circle UK firms and white shoe US firms, and hold Singapore law credentials.
Cross-border training for the transaction, Singapore qualification for the regulator, and a retainer that prices on the outcome rather than the hour.
Beyond Horizons is the practice of Bethel Chambers LLC, a Singapore law corporation. Sources: Workplace Fairness Act 2025 and Evidence Act 1893, read from Singapore Statutes Online; CPF Board contribution rates effective 1 January 2026; Employment Act leave entitlements published by the Ministry of Manpower; the Law Society of Singapore's compulsory professional indemnity scheme; the SILE CPD Scheme; MyCareersFuture salary data, September 2026; Akzo Nobel Chemicals Ltd v European Commission (Court of Justice, 2010).
This page gives general information about legislation. It is not legal advice, and using it does not create a solicitor–client relationship. The Workplace Fairness Act is passed but not yet commenced; commencement is expected at the end of 2027 and the threshold of 25 may be changed by the Minister. Exceptions in Part 5 of that Act are not tested here.