The Answer in 60 Seconds

WICA section 24 requires every employer to insure and maintain insurance under approved employee insurance policies with designated employer's insurers against liabilities under the Act for every employee, subject to prescribed exclusions and minimum amounts. WICA section 25 makes contravention of that duty an offence. The first-offence penalty is a fine not exceeding S$10,000 or imprisonment for up to 12 months or both. For a repeat offender, it is a fine not exceeding S$20,000 or imprisonment for up to 12 months or both.

Not knowing your employee numbers, required liability, policy approval status or insurer designation does not provide a defence unless the employer took all reasonable steps to ascertain those matters. Officer liability is not in section 25(3). It sits in WICA section 72, which applies its own three-limb test to officers and influential managers and operates whether or not the corporation is convicted.

The Sourced Detail

The offence is built around a continuous operating duty. Your company must know which employees require insurance, maintain an approved policy with a designated insurer and keep the policy information accurate. No one needs to be injured for the offence to be committed: the trigger is failing the insurance duty itself.

The duty under section 24

Section 24(1) of the Work Injury Compensation Act 2019 requires every employer to insure and maintain insurance under one or more approved employee insurance policies with one or more designated employer's insurers. The cover is against liabilities the employer incurs under the Act for every employee.

The words "insure and maintain" require continuity. The employer needs an approved policy in force, not an application, quotation or renewal discussion. The insurer also needs to hold the required designation. MOM maintains the current designated-insurer page, so verify status against that page rather than relying on an old list or count.

Section 24(2) states that the duty does not apply to prescribed excluded classes and is subject to a prescribed minimum amount. The Act leaves those details to the applicable prescription. The excluded classes are listed in the Second Schedule to the Work Injury Compensation (Insurance) Regulations 2020, which sets out 16. The first takes out employees doing non-manual work whose salary, not counting overtime, bonuses, the annual wage supplement, productivity incentive payments and allowances, exceeds S$2,600 a month. The other 15 take out all employees of certain employers, including the Government, a bank in Singapore (as defined in the Banking Act 1970), a finance company (within the meaning of the Finance Companies Act 1967), a hotel-keeper (as defined by the Hotels Act 1954) and "an employer engaged in retail trade", and employees "employed in the operation of" certain businesses, including "a hairdressing saloon", "a coffee shop" and "a theatre or cinema". Terms such as "retail trade" and "coffee shop" are not defined, so an employer unsure whether a class applies to it should ask MOM or its insurer. An employer whose employees fall in an excluded class must still pay compensation under WICA. MOM's WIC insurance requirements state the effect of the first class: insure every employee doing manual work, whatever the salary, and every employee doing non-manual work whose salary, not counting overtime, bonuses, the annual wage supplement, productivity incentive payments and allowances, is S$2,600 a month or less. The same page tells employers not to under-declare the number of employees and to keep each employee's occupation accurate with the insurer.

Use the WICA complete guide for the wider compensation and claims framework. This page focuses on the insurance offence.

The offence and both penalty tiers

Section 25(1) states that an employer who contravenes section 24(1) is guilty of an offence. The first tier carries a fine not exceeding S$10,000 or imprisonment for a term not exceeding 12 months or both. For a repeat offender, the maximum fine rises to S$20,000 while the imprisonment term remains up to 12 months.

The penalty sits in subsection (1), not subsection (2). Section 25(2) defines a repeat offender by reference to at least one earlier conviction under subsection (1), section 34P(1), or section 35(1)(b) of the repealed Act, whether that earlier conviction occurred before, on or after 1 September 2020.

The ignorance rule in section 25(3)

Section 25(3) addresses the practical failures that arise in an SME. It is not a director-liability provision. It removes specified ignorance arguments unless the employer took all reasonable steps to ascertain the relevant matters.

Ignorance does not provide a defence for the number of employees, the extent of liability requiring insurance, the policy's lack of approval or the insurer's lack of designation. The statutory exception requires the employer to have taken all reasonable steps to ascertain those matters.

This makes verification central. Reconcile employee records with the policy information. Check policy approval and insurer designation. Keep renewal, endorsement and payment records. When employee numbers, occupations or remuneration change, determine what the policy and compulsory terms require and complete the update.

A verbal assurance that insurance is "handled" leaves no written record of the steps taken. Keep the policy schedule, dates, employer identity, declared information and insurer status in a controlled record. Escalate mismatches before work continues without the required insurance.

Deducting insurance costs from employee earnings

Section 25(4) creates a separate offence where an employer deducts from an employee's earnings to defray or partly defray the required insurance cost. A first conviction carries a fine not exceeding S$5,000 or imprisonment for up to 6 months or both. A repeat conviction raises the maximum fine to S$10,000 and retains the maximum imprisonment term of 6 months.

Section 25(5) defines repeat offender for that deduction offence by specified earlier convictions. Keep the insurance premium as an employer cost. Do not pass it to employees through a payroll deduction.

Officer and manager exposure under section 72

Corporate-officer liability sits in section 72(2). It reaches an officer of the corporation and an individual involved in management who is in a position to influence the corporation's conduct in relation to the offence.

The person is guilty of the same offence as the corporation where one of three conditions applies. First, the person consented, connived or conspired with others to effect the offence. Second, the person was knowingly concerned in or party to the offence by act or omission. Third, the person knew or ought reasonably to have known that the offence, or one of the same type, would be or was being committed and failed to take all reasonable steps to prevent or stop it.

Section 72(6) defines officer to include a director, partner, chief executive, manager, secretary or similar officer, a person purporting to act in such a capacity, and specified members where members manage the corporation's affairs.

Section 72(3) lets the individual rely on a defence available to the corporation and places on that person the same burden of proof the corporation would carry. Section 72(5) states that the officer mechanism applies whether or not the corporation is convicted and does not affect the corporation's own liability.

This differs from the reverse-burden structure in the WSHA section 48 guide. Read each statute on its own terms rather than importing one officer test into the other.

What an uninsured employer still owes

Insurance transfers the covered payment obligation to the designated insurer under the approved policy. It does not create the employer's underlying liability. Section 24(1) describes insurance against liabilities the employer incurs under the Act. Section 7(1) makes the employer liable to pay compensation for a work injury. It sets no condition about insurance.

An uninsured employer therefore faces two separate problems. The prosecution concerns failure to maintain required insurance. The compensation process concerns the employer's liability for the work injury. Do not assume the absence of a policy removes the employee's statutory route or converts the employer's liability into a discretionary payment.

Follow the WICA claim procedure after an accident. Preserve the accident report, employment and wage records, medical documents, policy history and communications with MOM. Obtain legal advice on an uninsured period without delaying accident reporting or required payments.

Controls that prevent an insurance offence

Assign one owner for the policy and a separate reviewer. Record the expiry date, renewal lead time, insurer designation check, approved-policy evidence, employee reconciliation and premium status. Completion means the policy is issued and in force with correct information.

Reconcile after hiring, termination, role changes and payroll changes. The control should identify employees missing from the declared information and discrepancies between policy records and actual employment. Preserve the report and corrective action.

For a company acquisition, inspect the target's policy history, employee data, claims and renewal evidence. A certificate alone does not prove uninterrupted compliance or accurate declarations.

Common Mistakes

  1. Putting the penalty in subsection (2). Section 25(1) contains the offence and penalties. Subsection (2) defines a repeat offender.

  2. Treating subsection (3) as director liability. It is the employer ignorance rule. Officer liability sits in section 72.

  3. Checking only whether a policy document exists. The statute requires an approved employee insurance policy with a designated employer's insurer.

  4. Relying on an old insurer list. A designation can expire, be suspended or be cancelled under WICA section 31 and section 34. Use MOM's current page and retain the verification.

  5. Allowing a renewal gap. A pending renewal does not satisfy the duty to maintain insurance.

  6. Ignoring employee-data changes. Headcount and required liability are matters the employer must take reasonable steps to ascertain.

  7. Charging the premium to employees. Deduction from earnings for the required insurance is a separate offence with separate penalties.

  8. Assuming the corporation must be convicted first. The officer provision applies whether or not the corporation is convicted.

What This Means for Your Business

Make WIC insurance verification an operating control, not a renewal reminder. Your evidence should show which employees are covered, why the policy is approved, why the insurer is designated, when the cover starts and ends, and how changes reach the insurer.

Give senior management visibility of gaps and unresolved discrepancies. The officer test includes people able to influence the corporation's conduct, so the control cannot stop at payroll or administration.

If a gap is discovered, establish the dates and affected employees, notify the appropriate adviser and preserve the evidence. Fix the insurance position without rewriting the record of what occurred.

Questions to Ask Your Adviser

  1. Is this an approved employee insurance policy issued by a currently designated employer's insurer?
  2. Which employees and liabilities must our policy cover under the current prescribed rules?
  3. Does the policy information match our employee numbers, occupations and remuneration records?
  4. What event requires an endorsement or updated declaration, and when does that change take effect?
  5. What evidence confirms that renewal is bound before the current policy expires?
  6. How does the policy respond to an injury discovered during a disputed or uninsured period?
  7. Which people in management fall within our verification and escalation process?

Related Information

WICA duties and claims:

Officer and incident response:

Published 4 May 2026. Source verified 29 September 2026.