Discovering CPF contributions from a company that you have never worked for can be concerning. You may never have applied for a position with the company, performed any work for it or even recognised its name, yet its contributions appear in your CPF account as though an employment relationship existed.
In such a situation, the existence of a false employment record is only the starting point. A phantom employment arrangement may involve the employer that created the record, directors or managers who authorised it, intermediaries who facilitated the arrangement and the individual whose particulars were used. Their respective legal positions may differ significantly depending on what each person did and knew.
Becoming Involved in a Phantom Employment Arrangement
An employer or intermediary may approach an individual and offer CPF contributions, cash or another benefit in exchange for the use of his or her personal particulars. CPF Board has warned members of the public against giving personal information to persons offering CPF contributions as a reward.
Other cases may be less straightforward. A person may voluntarily provide personal information for one purpose without understanding that it will subsequently be used to create a false employment record. A person may also know that CPF contributions are being made but not understand the purpose for which the supposed employment is being recorded.
Personal particulars may also be obtained without the individual’s knowledge or involvement. CPF Board has noted that seniors may be particularly vulnerable to such arrangements. Not every person described as a “phantom worker” is therefore in the same position; knowledge, consent and conduct are important when assessing responsibility.
Unfamiliar CPF Contributions and Individual Responsibility
A CPF record establishes that a contribution was made in the person’s name, but it does not by itself establish what that person knew or intended. The record may not show how the employer obtained the person’s particulars, what explanation was given or whether the individual understood that he or she was being represented as an employee.
A person whose particulars were used without permission is in a very different position from someone who knowingly agreed to be represented as an employee despite performing no work.
The existence of the CPF contribution may therefore prompt an investigation, but it does not by itself determine criminal responsibility.
Individual Liability and Knowing Participation
The legal risk is greater where an individual knowingly assists in the creation or operation of the false employment arrangement.
Under section 23(1) of the Employment of Foreign Manpower Act 1990 (“EFMA”), a person who abets an offence under the Act is liable to the punishment provided for the underlying offence. MOM has specifically warned that individuals who collude with companies by providing their particulars for fraudulent CPF contributions to inflate foreign worker quotas may be prosecuted for abetment of false declaration. Such offences may attract a fine of up to S$20,000, imprisonment for up to two years, or both.
An offer of “free CPF” should therefore not be regarded as harmless. Even where no work is required, the individual’s particulars may be used to create an apparent employment relationship that is later relied upon for work pass or foreign worker quota purposes. However, receiving CPF contributions does not necessarily prove that the individual understood the wider scheme.
Providing Personal Particulars Without Full Knowledge
CPF Board has warned that a person who provides CPF or Singpass details without knowing how the information will eventually be used may still be investigated. However, an investigation does not mean that an offence has necessarily been established.
Relevant questions may include why the information was provided, what the individual was told, whether any payment or benefit was offered and what the individual understood about the supposed employment. Messages, emails and other communications may therefore become important evidence of why the particulars were requested and what explanation was given.
Responsibility of Employers and Company Officers
Responsibility may extend beyond the individual whose name appears as the employee. A company acts through its directors, managers and other officers. An investigation may therefore consider who authorised the false employment records, who approved the CPF contributions, who prepared or approved work pass applications and who knew what the arrangement was intended to achieve.
Under section 20 of the EFMA, an officer of a company may in certain circumstances be proceeded against where an offence by the company was committed with that person’s consent or connivance, or was attributable to neglect on his or her part.
Accordingly, directors and managers should not assume that responsibility necessarily rests only with the employee responsible for payroll or an external service provider. The relevant inquiry may include what the officer knew, authorised or failed to supervise.
Role of Employment Agents and Intermediaries
Not every phantom employment arrangement is organised directly between an employer and the person whose particulars are used.
Intermediaries may be involved in recruiting individuals, obtaining personal particulars, connecting them with employers, arranging documents or coordinating payments. Depending on the conduct involved, responsibility may therefore extend beyond the employer and the phantom worker.
In July 2026, MOM announced the arrest of 14 individuals in an investigation into suspected employment-related offences. Those arrested included four company directors, nine foreign workers and a key appointment holder from an employment agency. MOM was also investigating suspected fraudulent CPF contributions made to 139 locals who were not employed by the companies concerned.
Evidence and Investigation
MOM may investigate the surrounding circumstances to determine whether genuine employment existed and who was involved in creating or facilitating the arrangement. Relevant evidence may include employment documents, salary and CPF records, work pass applications, communications between the parties, payment arrangements and statements provided during investigations.
The practical questions may include whether the individual ever performed work for the company, who first approached him or her, whether any payment or benefit was offered, what explanation was given for the CPF contributions, whether false employment documents were created and whether the individual introduced or recruited other persons into the arrangement.
These facts may help distinguish between an organiser of the scheme, an intermediary who actively facilitated it, a person who knowingly participated and a person whose particulars were used without his or her consent.
False Work Pass Declarations and Potential Penalties
Singapore courts have recognised the importance of protecting the integrity of the work pass system.
In Chiew Kok Chai v Public Prosecutor at [62], the High Court held that imprisonment should generally be the norm for false declaration offences under section 22(1)(d) of the EFMA involving work pass applications, reflecting the need for deterrence.
This does not mean that every person connected to a phantom employment arrangement will necessarily be prosecuted or receive a custodial sentence. Liability and sentencing depend on the offence, the person’s role and the evidence. The case nevertheless shows why false employment records may have consequences extending beyond the CPF contribution itself.
Steps to Take Upon Discovering Unfamiliar CPF Contributions
CPF members should review their transaction histories and pay attention to contributions from employers that they do not recognise.
Where there may be an innocent explanation, such as contributions continuing after a genuine employment relationship has ended, CPF Board recommends seeking clarification from the employer. If you are certain that you have never worked for the company concerned, CPF Board provides a channel for reporting invalid CPF contributions. Suspected use of locals as phantom workers may also be reported to MOM through its “Report an infringement” eService.
It is also advisable to preserve relevant records, including CPF statements, employment documents, messages, emails and any communications concerning the supposed employment. Where personal particulars were previously provided to another person, records of what was said and why the information was requested may become important if questions later arise about the individual’s knowledge or involvement.
Individuals should also avoid giving out Singpass credentials, CPF information or other personal particulars simply because they are offered CPF contributions or another benefit in return. What may appear to be a minor arrangement can result in the individual becoming involved in a wider employment investigation.
Determining Responsibility in Phantom Employment Arrangements
A phantom job may exist only on paper, but liability cannot be determined from the paper record alone. The law distinguishes between the person who creates the false employment, those who facilitate it, those who knowingly participate and those whose particulars may have been misused.
Accordingly, an unfamiliar CPF contribution should not automatically be treated as proof that the recipient has committed an offence. The circumstances surrounding the supposed employment, and in particular what each person knew and did, remain important.
Whether you are an individual who has discovered CPF contributions from an unfamiliar company, someone who has been approached to participate in such an arrangement, or an employer concerned about a possible investigation, understanding your legal position early can help you take the appropriate next steps. If you require advice concerning suspected phantom employment, an MOM investigation, false employment records or related offences under the Employment of Foreign Manpower Act, please feel free to reach out to our firm for assistance.
The information provided in this article is for general informational purposes only and does not constitute legal advice. It should not be relied upon as a substitute for legal advice in relation to any particular circumstances. You should seek specific legal advice where necessary.
Sources
- CPF Board, Phantom workers and the risk of unknown CPF contributions
- CPF Board, Reporting invalid CPF contributions from employers you never worked for before
- MOM Parliamentary Answer, 27 Feb 2026
- MOM Parliamentary Answer, 3 Mar 2026
- MOM press release, 1 Apr 2026
- MOM press release, 23 Jul 2026
- Employment of Foreign Manpower Act 1990, s 20, s 22(1)(d) and s 23
- Chiew Kok Chai v Public Prosecutor [2019] SGHC 169 at [62]