Do PEP Holders Need an LOC to Be Directors in Singapore?

Appointing directors in Singapore isn’t always straightforward—especially when it involves PEP holders. If your business is thinking about appointing a Personalised Employment Pass (PEP) holder as a director, it’s important to understand whether a Letter of Consent (LOC) is needed and how MOM policies apply. This is where experienced corporate secretary services can help you stay compliant.

In this guide, we explain when PEP holders can be directors in Singapore, when an LOC is required, and how to stay aligned with MOM and ACRA regulations.

1. What Is a Personalised Employment Pass (PEP)?

The Personalised Employment Pass (PEP) is issued by Singapore’s Ministry of Manpower (MOM) to high-earning, skilled professionals. Unlike other work passes, the PEP isn’t tied to one employer and allows holders to switch jobs without reapplying.

But despite its flexibility, taking on a directorship—especially in a company other than the main employer—comes with its own set of rules.

2. No LOC Needed: Directorship in Main Employer Company

If the company appointing the PEP holder is also their official employer (as registered with MOM), they can typically be appointed without needing a Letter of Consent.

✅ LOC not required when:

• The appointment is within the main employer’s company
• The role is part of the PEP holder’s primary employment duties

This is known as a primary directorship, and it’s permitted without additional approval.

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3. LOC Required: Directorship in a Different Company

If a PEP holder is invited to be a director in another company—whether it’s a subsidiary, an unrelated entity, or even a startup—they’ll need to apply for a Letter of Consent first.

✅ LOC required when:

• The role is outside their main employment
• The appointment is in a separate company
• The directorship is advisory, part-time, or non-executive in nature

This is called a secondary directorship, and MOM approval is a must.

4. Summary Table: When Is an LOC Needed?

5. Why This Matters for Singapore Businesses

For small businesses in Singapore, understanding the director requirements for PEP holders is vital. Making the wrong move—like appointing a director without the proper LOC—can delay ACRA filings or trigger MOM compliance issues.

That’s why many SMEs turn to corporate secretary services. These professionals help with:

• Verifying PEP employment status and eligibility
• Checking MOM regulations for LOC requirements
• Submitting necessary forms and applications
• Updating company records with ACRA

Summary

In Singapore, PEP holders can be appointed as directors without an LOC only if it’s within their main employer’s company. Any other directorship requires MOM approval via a Letter of Consent. Getting it right avoids unnecessary compliance issues and delays.

If you’re unsure about your director appointments, engaging a trusted corporate secretary service can help ensure smooth filings and proper guidance.

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