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Central Provident Fund (Wages — Excluded Payments) Notification 2019

Overview of the Central Provident Fund (Wages — Excluded Payments) Notification 2019, Singapore subsidiary_legislation.

Statute Details

  • Title: Central Provident Fund (Wages — Excluded Payments) Notification 2019
  • Act Code: CPFA1953-N12
  • Type: Subsidiary legislation (Notification)
  • Current Version: 2025 Revised Edition (17 December 2025), in force as at 26 March 2026
  • Commencement: 1 January 2020 (as indicated by the operative provision)
  • Key Provisions:
    • Section 1: Citation
    • Section 2: Definitions (dental treatment, medical treatment, traditional Chinese medicine treatment, dependant, relevant treatment)
    • Section 3: Payments excluded from “wages” for CPF purposes (reimbursements for relevant treatment)
  • Authorising Act: Central Provident Fund Act 1953 (reference to definition of “wages” in section 2(1))
  • Legislative History (high level):
    • 1 Jan 2020: SL 726/2019
    • 31 Dec 2021 & 15 Jun 2023: Amended by S 372/2023
    • 17 Dec 2025: 2025 Revised Edition

What Is This Legislation About?

The Central Provident Fund (Wages — Excluded Payments) Notification 2019 is a targeted CPF rule that clarifies when certain employer payments should not be treated as “wages” for CPF contribution purposes. In plain terms, it carves out a specific category of employer reimbursements—payments that reimburse an employee (or reimburse for treatment received by the employee’s dependant)—for certain healthcare-related expenses.

The Notification operates by modifying the effect of the definition of “wages” in the Central Provident Fund Act 1953. Rather than changing the CPF contribution regime broadly, it focuses on a narrow question: when an employer reimburses an employee for costs incurred in relation to “relevant treatment”, does that reimbursement count as wages? The Notification answers: no, provided the reimbursement meets the conditions set out in the Notification and becomes due on or after 1 January 2020.

Practically, this means that employer reimbursements for qualifying medical and dental treatment (and traditional Chinese medicine treatment) are excluded from the wage base used to calculate CPF contributions. This reduces CPF costs for employers and can improve employee take-home value where reimbursements are structured appropriately.

What Are the Key Provisions?

Section 1 (Citation) simply identifies the instrument as the “Central Provident Fund (Wages — Excluded Payments) Notification 2019”. While not substantive, citation is important for legal referencing, compliance documentation, and for practitioners advising on the correct legal basis for CPF treatment.

Section 2 (Definitions) is the core interpretive section. It defines the types of treatment and the persons covered, ensuring that the exclusion in section 3 applies only to reimbursements connected to qualifying healthcare services.

First, the Notification defines “dental treatment” as procedures, work, services, investigations, treatment/advice, or attendance that a dentist considers necessary for treating or diagnosing any dental ailment, infirmity, or defect—excluding “solely aesthetic” defects. This is a clinical necessity test: the dentist must consider the treatment necessary for diagnosis or treatment, not merely cosmetic improvement.

Second, it defines “medical treatment” similarly, but for physical or mental ailments, infirmities, or defects. The treatment must be considered necessary by a medical practitioner (again excluding solely aesthetic defects). The defined elements include performance of procedures/work/services/investigations, giving treatment/advice, and attendance.

Third, it defines “traditional Chinese medicine treatment” using the same structure: procedures/work/services/investigations, giving treatment/advice, and attendance, but assessed on the basis of traditional Chinese medicine by a practitioner of traditional Chinese medicine, and excluding solely aesthetic defects.

Fourth, it introduces “relevant treatment” as a collective term covering dental treatment, medical treatment, and traditional Chinese medicine treatment, whether provided in Singapore or elsewhere. This “whether in Singapore or elsewhere” language is significant: it extends the exclusion to overseas treatment costs, provided the practitioner qualification requirements are met.

Fifth, it defines “dependant” in relation to an employee. The dependant may be:

  • a natural child or stepchild of the employee;
  • a child whose adoption, guardianship or foster care by the employee is recognised by law or by a consular authority of the employee’s place of nationality;
  • a spouse of the employee under a marriage recognised by the law of the country/territory/state where the marriage took place.

Finally, section 2(2) clarifies who counts as the relevant healthcare professional. For treatment in Singapore, the practitioner must be registered under the relevant Singapore registration regimes (registered dentist, registered medical practitioner, or registered traditional Chinese medicine practitioner). For treatment outside Singapore, the practitioner must be qualified to practise under the law of the country/territory/state where the treatment is provided. This is a compliance-critical point: reimbursements tied to treatment by an unqualified provider may fall outside the exclusion.

Section 3 (Payments excluded from wages) is the operative provision. It states that the definition of “wages” in section 2(1) of the Central Provident Fund Act 1953 does not include any payment that becomes due on or after 1 January 2020 to an employee from the employee’s employer to reimburse the employee for any amount incurred in respect of relevant treatment received (or to be received) by:

(a) the employee; or (b) an individual who is a dependant of the employee at the time the payment becomes due.

Several practical elements are embedded in this wording:

  • Timing (“becomes due”): The exclusion applies to payments that become due on or after 1 January 2020. This matters for accounting and payroll timing—practitioners should consider when the reimbursement obligation crystallises, not merely when it is paid.
  • Reimbursement purpose: The payment must reimburse amounts incurred (or to be incurred) in respect of relevant treatment. It is not a general health allowance; it must be linked to qualifying treatment costs.
  • Scope of treatment: The reimbursement must relate to dental treatment, medical treatment, or traditional Chinese medicine treatment, and must satisfy the clinical necessity and “not solely aesthetic” exclusions.
  • Dependants: The exclusion extends beyond the employee to reimbursements for treatment received by dependants, provided the person qualifies as a “dependant” under the Notification at the relevant time.

Notably, the Notification does not expressly address administrative requirements (such as documentation or claim forms). However, because the exclusion depends on defined terms (including practitioner registration/qualification and the “necessary for diagnosis or treatment” standard), employers and employees should maintain evidence to support the classification of the reimbursement as excluded from wages.

How Is This Legislation Structured?

The Notification is structured in a simple, practitioner-friendly format with three provisions:

  • Section 1: Citation.
  • Section 2: Definitions that determine the scope of “relevant treatment” and the persons covered (including “dependant” and the relevant healthcare professionals).
  • Section 3: The exclusion rule—payments reimbursing qualifying treatment costs are excluded from the statutory definition of “wages” for CPF purposes, subject to the timing condition (payments due on or after 1 January 2020).

Because the Notification is a subsidiary instrument, it does not create a standalone CPF contribution regime. Instead, it modifies how the CPF Act’s “wages” concept is applied in a specific scenario.

Who Does This Legislation Apply To?

This Notification applies to employers and employees in Singapore who are subject to the CPF framework under the Central Provident Fund Act 1953. Its effect is felt in payroll and CPF computation: when an employer reimburses an employee for qualifying treatment costs, that reimbursement is excluded from “wages” for CPF purposes.

It also applies indirectly to dependants of employees, because the exclusion covers reimbursements for relevant treatment received by a dependant (as defined). The key is that the dependant must meet the Notification’s definition at the time the payment becomes due, and the treatment must be provided by a qualifying practitioner (registered in Singapore or properly qualified overseas).

Why Is This Legislation Important?

For practitioners, the Notification is important because it provides a clear legal basis to exclude certain employer reimbursements from CPF contributions. Without such an exclusion, reimbursements could be treated as part of remuneration and therefore included in the wage base, increasing CPF costs and potentially creating compliance disputes.

From an employer compliance perspective, the Notification offers a structured pathway to design benefits and reimbursement schemes that align with CPF rules. For example, employers may reimburse medical, dental, and traditional Chinese medicine treatment costs for employees and their dependants, while excluding those reimbursements from CPF wages—provided the reimbursement is properly characterised and the underlying treatment meets the defined criteria.

From an employee perspective, the Notification can support more effective benefit delivery. If reimbursements are excluded from wages, the employee’s reimbursement is less likely to be reduced by CPF-related deductions (depending on how the employer structures the benefit and payroll). It also encourages the use of legitimate healthcare services rather than relying on informal or ambiguous “allowances”.

Finally, the Notification’s emphasis on practitioner qualification and the “not solely aesthetic” limitation is a compliance safeguard. It reduces the risk that employers will treat cosmetic or non-clinically necessary services as excluded medical expenses. In practice, disputes are most likely to arise where the treatment’s necessity is unclear, where the provider’s qualification is questionable, or where the reimbursement is not clearly linked to “relevant treatment”.

  • Central Provident Fund Act 1953 (particularly the definition of “wages” in section 2(1))
  • Dental Registration Act 1999 (definition of “registered dentist” in section 2)
  • Medical Registration Act 1997 (definition of “registered medical practitioner” in section 2(1))
  • Traditional Chinese Medicine Practitioners Act 2000 (definition of “registered person” in section 2)

Source Documents

This article provides an overview of the Central Provident Fund (Wages — Excluded Payments) Notification 2019 for legal research and educational purposes. It does not constitute legal advice. Readers should consult the official text for authoritative provisions.

Written by Sushant Shukla

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