COMPASS Scoring for a Family Office CIO

A Singapore single family office that wants to bring in a non-family Chief Investment Officer has no access to the ONE Pass, the Global Investor Programme or a Personalised Employment Pass, none of those routes were built for a salaried employee who is not the principal. COMPASS scoring for a family office CIO is, in nearly every such case, the real gatekeeping mechanism: an ordinary Employment Pass application assessed under the Ministry of Manpower’s points-based Complementarity Assessment Framework, exactly as for any other professional hire in Singapore.

That distinction matters because most existing commentary on family office hiring in Singapore focuses on the principal’s own immigration route, or on family members brought in as investment professionals to satisfy the headcount conditions of a 13O or 13U tax incentive scheme. An external CIO or portfolio manager, hired purely for their investment expertise and unrelated to the family, sits in a different lane entirely. Their pass depends on ordinary COMPASS mechanics, including salary benchmarking against local professionals, managers, executives and technicians (PMETs) in a highly specialised, high-salary financial services role.

This article goes deeper into that one scenario. We assume the reader already understands the broader family office hiring landscape, covered in our companion piece on family office hiring, Employment Pass and MAS licensing routes, and focuses narrowly on how COMPASS points stack up for an external CIO or senior portfolio manager hire, illustrated with a worked example.

Why the External CIO Sits Outside ONE Pass and PEP

ONE Pass and the Personalised Employment Pass (PEP) are both built around a single high-earning individual assessed on their own track record; neither is designed for an employer-employee relationship. A family office that formally employs a CIO or portfolio manager sponsors that person’s work pass in the same way any Singapore company sponsors a foreign employee, so the Employment Pass framework, with its Stage 1 qualifying salary test and Stage 2 COMPASS scoring, applies in full. This differs from whether a family member sits on the investment team to satisfy the economic conditions of a Section 13O or 13U scheme, covered separately in our piece on family members as investment professionals for 13O and 13U purposes. It is also distinct from whether a fund manager or director is genuinely an employee of the vehicle for regulatory purposes, addressed in our analysis of the four tests for VCC directors, fund managers and employees, a useful cross-check for family offices with a fund vehicle alongside the SFO.

MOM’s COMPASS Framework at a Glance (As at 28 April 2026)

The Complementarity Assessment Framework, known as MOM’s COMPASS framework, has applied to all new and renewal Employment Pass applications since 1 September 2023. As at 28 April 2026, the framework remains a two-stage test, and every threshold below reflects MOM’s published position on that date.

The Two-Stage Test and the 40-Point Pass Mark

Stage 1 requires the candidate to meet the EP qualifying salary, benchmarked to the top third of local PMET salaries by age. Candidates who fail Stage 1 cannot proceed to Stage 2, regardless of how well they would otherwise score. Stage 2 is COMPASS itself: the application must earn at least 40 points across four foundational criteria, salary, qualifications, diversity and support for local employment, plus two optional bonus criteria, the skills bonus and the strategic economic priorities bonus.

EP Qualifying Salary versus the C1 Salary Benchmark

The EP qualifying salary (Stage 1) is a minimum bar; the C1 salary criterion under COMPASS (Stage 2) is a separate percentile-based scoring exercise. As at 28 April 2026, the EP qualifying salary for the financial services sector, where a family office’s investment team is ordinarily classified, is SGD 6,200 at age 23 or below, rising with age to SGD 11,800 at age 45 and above. These figures rise to SGD 6,600 and SGD 12,700 respectively for new applications from 1 January 2027, and for renewals expiring from 1 January 2028. A CIO or senior portfolio manager will typically clear this floor with room to spare. Separately, any candidate with a fixed monthly salary of at least SGD 22,500 is exempt from COMPASS altogether, needing only to clear Stage 1. Many senior external CIOs will fall above this line; a portfolio manager or deputy CIO on a more moderate package usually will not, which is why COMPASS scoring for a family office CIO or portfolio manager hire still needs to be worked through carefully rather than assumed away.

The Four Foundational Criteria for a CIO or Portfolio Manager Hire

Each foundational criterion under MOM’s COMPASS framework scores 0, 10 or 20 points, assessed independently before bonus points are added.

C1 Salary: Why a Highly-Paid CIO Usually Scores Well

C1 compares the candidate’s fixed monthly salary against local PMET salary benchmarks in the same sector, by age. A salary at the 90th percentile or above earns 20 points, 65th to below the 90th earns 10 points, and anything below the 65th percentile earns zero. A genuinely senior CIO running an eight or nine-figure portfolio will usually command a salary comfortably in the upper bands for financial services professionals of a similar age, so this criterion tends to be a source of strength, provided the family office benchmarks the offered package properly rather than lowballing it to control cost.

C2 Qualifications

C2 awards 20 points for degree-equivalent qualifications from top-tier institutions (broadly, the top 100 QS-ranked universities, Singapore’s Autonomous Universities, or institutions endorsed by the relevant sector agency), 10 points for other degree-equivalent qualifications including well-recognised professional qualifications endorsed by a sector agency, and zero for qualifications that do not meet the degree-equivalent bar. A CIO or senior portfolio manager with a relevant postgraduate degree, or a recognised professional finance qualification, will usually clear the 10-point band, and the 20-point band if their first degree is from a top-tier institution.

C3 Diversity and C4 Support for Local Employment: the Firm-Level Wildcard

These two criteria are scored at the level of the employing organisation, not the candidate, which is precisely where a small single family office differs from a large financial institution. Organisations with fewer than 25 PMET employees receive a default 10 points on both C3 and C4, regardless of actual workforce composition. Because most single family offices run lean teams, well under 25 PMETs, this default frequently applies and is often the deciding factor in whether the application clears 40 points. Organisations with 25 or more PMETs are instead scored on actual percentile bands: for C3, a candidate whose nationality forms less than 5% of the firm’s PMETs earns 20 points, 5% to below 25% earns 10 points, and 25% or more earns zero; for C4, a local PMET share at or above the 50th percentile of the sector earns 20 points, 20th to below the 50th earns 10 points, and below the 20th earns zero.

COMPASS Criteria Breakdown for a CIO or Portfolio Manager Hire

Criterion	What it measures	Points available	Typical relevance to a CIO/PM hire
C1 Salary	Salary vs local PMET benchmarks by sector and age	0, 10 or 20	Usually strong, given high market pay for CIO/PM roles
C2 Qualifications	Degree-equivalence and institution tier	0, 10 or 20	Usually 10 or 20 for relevant postgraduate or finance qualifications
C3 Diversity	Nationality share of firm’s PMETs (or default if under 25 PMETs)	0, 10 or 20	Often defaults to 10 for a small SFO team
C4 Support for local employment	Local PMET share vs sector (or default if under 25 PMETs)	0, 10 or 20	Often defaults to 10 for a small SFO team
C5 Skills bonus	Role on the Shortage Occupation List	0, 10 or 20	Rarely applies; CIO/PM roles are not typically SOL-listed
C6 SEP bonus	Firm’s participation in eligible economic agency programmes	0 or 10	Case specific; unlikely unless separately endorsed

The Two Bonus Criteria: Skills Bonus and Strategic Economic Priorities

The skills bonus (C5) rewards jobs on MOM’s Shortage Occupation List, awarding 20 points where the candidate’s nationality forms less than a third of the firm’s PMETs, or 10 points where it forms a third or more. The Shortage Occupation List skews heavily towards specific technology occupations, and a CIO or portfolio manager role does not typically appear on it, so this bonus is usually not available for this hire and should not be relied upon in planning. The strategic economic priorities bonus (C6) awards 10 points where the employing organisation participates in an eligible programme run by an economic agency, or is endorsed by the labour movement for transformation efforts, at the discretion of the supporting agency. This firm-level bonus is unrelated to the candidate personally, and most single family offices will not hold such an endorsement, so it should be treated as a possible upside rather than a planning assumption.

COMPASS Scoring for a Family Office CIO: A Worked Points Example

The following is illustrative only, showing how the mechanics interact. It is not a guarantee of any outcome, since actual COMPASS assessment is case specific and depends on MOM’s records of the employer’s workforce profile at the time of application.

Consider a Singapore single family office with 18 PMET employees, hiring a portfolio manager (not the CIO) below the SGD 22,500 COMPASS exemption line, so the application must be scored in full.

Criterion	Illustrative fact pattern	Points
C1 Salary	Salary sits at the 75th percentile of local PMET salaries in financial services for the candidate’s age band	10
C2 Qualifications	Candidate holds a relevant master’s degree from a non-top-tier but degree-equivalent institution	10
C3 Diversity	Firm has fewer than 25 PMETs, so the default applies	10
C4 Support for local employment	Firm has fewer than 25 PMETs, so the default applies	10
C5 Skills bonus	Portfolio manager role is not on the Shortage Occupation List	0
C6 SEP bonus	Firm holds no eligible economic agency endorsement	0
Total		40 (Pass)

On these facts the application passes exactly at the 40-point line, with the small-firm defaults on C3 and C4 doing much of the work. A weaker salary result, for example a package below the 65th percentile scoring zero on C1, would need offsetting elsewhere, most realistically by a top-tier qualification worth 20 points on C2, since the diversity and local employment defaults are already fixed at 10 each for a firm this size. This mirrors the dynamic in our worked example on hiring a foreign actuary, licensing, pass strategy and salary benchmarks, another highly specialised hire where salary strength and qualification tier trade off against each other.

Practical Take-aways for Family Offices Hiring External Investment Talent

First, benchmark the offered salary against actual sector percentiles, not what the family is used to paying internally, since C1 is fully within the family office’s control. Second, do not assume years of experience alone will carry a COMPASS application; MOM’s framework runs on qualifications, salary and workforce data, not tenure, a point explored in why you should stop hiring based on years of experience. Third, check the firm’s actual PMET headcount before assuming the under-25 default applies. Fourth, MAS licensing and fund structuring sit alongside the Employment Pass question, including the entity questions in our single family office setup FAQ.

Conclusion

COMPASS scoring for a family office CIO or portfolio manager hire is a mechanical, points-based exercise once the underlying facts, salary percentile, qualification tier, and the firm’s PMET headcount, are properly established. Getting it right the first time avoids costly delays for a hire a family office cannot afford to leave unresolved. If you are structuring an Employment Pass application for a family office’s external investment hire, Little Big Employment Agency’s licensed EP application services can assess the COMPASS scoring position before you submit, and where the hire also touches fund vehicle or single family office structuring questions, Raffles Corporate Services can advise on the wider setup alongside it.

, The Editorial Team, Little Big Employment Agency