On 23 July 2026, the Ministry of Manpower (MOM) launched the open call for the Alliance for Action on Safety and Health for Employment Longevity (AfA-SHEL), a tripartite initiative led jointly with the National Trades Union Congress (NTUC) and the Singapore National Employers Federation (SNEF). Most of the coverage since has focused on what AfA-SHEL means operationally: injury prevention, return-to-work support, and workplace adaptation for an ageing and increasingly diverse workforce. That is useful, but it is not the part that should keep a company director up at night.
The part that matters at board level sits quietly alongside AfA-SHEL: from 1 September 2026, the Top Executive WSH Programme (TEWP), the mandatory training that chief executives and board directors in higher-risk sectors have had to complete since March 2024, has been enhanced with a materially stronger emphasis on executive accountability, governance and due diligence. Read together, AfA-SHEL and the enhanced TEWP are not simply awareness campaigns. They are MOM signalling, again, that the Workplace Safety and Health Act 2006 (WSH Act) already places personal legal exposure on directors and officers, and that regulators expect boards to be able to demonstrate, with evidence, that they exercised due diligence.
This article sets out what has actually changed, why it matters for director accountability specifically rather than for safety teams, and what a Singapore company officer should be doing differently before the enhanced TEWP curriculum takes effect. It does not repeat the general AfA-SHEL explainer already available elsewhere; the focus here is narrowly on the due diligence and board oversight obligations that flow from these developments.
What AfA-SHEL and the Enhanced TEWP Actually Are
AfA-SHEL was announced by Minister of State for Manpower Dinesh Vasu Dash during the Committee of Supply debate in March 2026, and formally launched at the WSH Conference 2026 on 23 July 2026. Its open call for Singapore-registered organisations ran until 31 August 2026, with around 30 selected participants joining a roughly 14-month innovation programme from August 2026, focused on three areas: injury prevention across the general workforce, support for workers returning after a serious injury or health episode, and workplace adaptation and job redesign.
The TEWP is a separate but related requirement. It has been legally mandatory since 1 March 2024 for at least one top executive, typically the chief executive officer or a board director responsible for WSH, in companies operating in the Construction, Manufacturing, Marine, or Process industries, to complete a structured training programme. From 1 September 2026, the curriculum has been enhanced to push executives harder on questions of accountability, governance and due diligence, rather than treating WSH purely as an operational, delegated function. Company officers who have already completed the earlier version of TEWP should not assume that box remains ticked; the enhanced content reflects MOM’s evolving expectations of what board-level oversight should look like.
The Legal Backbone: Section 48 of the WSH Act
None of this exists in a vacuum. Section 48 of the WSH Act already provides that where an offence under the Act is committed by a body corporate, and it is proved that the offence was committed with the consent or connivance of, or was attributable to neglect on the part of, a director, manager, secretary or other similar officer, that individual is personally guilty of the offence and may be punished accordingly. This is a strict framework: an officer does not escape liability simply because the breach occurred on the shop floor rather than in the boardroom.
Critically, section 48 also provides a defence: an officer who can show that they exercised due diligence to prevent the commission of the offence will not be held liable. The burden of proof sits with the officer, not the prosecution. This is where AfA-SHEL and the enhanced TEWP intersect with existing statutory director duties: a director’s general duty to act with reasonable diligence under the Companies Act 1967 already required attention to material operational risks, and WSH exposure has always fallen within that scope. What is new is that MOM is now training executives specifically on how to build and evidence that due diligence, rather than leaving it to be inferred after an incident.
What Due Diligence Looks Like in Practice
MOM’s related Code of Practice on Chief Executives’ and Board of Directors’ Workplace Safety and Health Duties, while not itself mandatory, sets out the kind of measures MOM will treat as evidence of reasonably practicable due diligence. In broad terms, this includes the board receiving regular WSH risk reporting, allocating adequate resources to WSH management, ensuring a competent person is appointed to manage WSH matters, and reviewing incidents and near-misses at board or board-committee level rather than leaving them entirely with operational management. Adopting the Code’s principles does not guarantee immunity, but it is the kind of documented practice that supports a due diligence defence if an incident occurs.
What Changed, Who Is Affected, and By When
| Item | What changed | Who is affected | Effective date |
|---|---|---|---|
| AfA-SHEL | Tripartite alliance launched; open call for organisations to co-create WSH and employment longevity solutions | Singapore-registered organisations applying to participate; broader workforce policy direction for all employers | Launched 23 July 2026; open call closed 31 August 2026 |
| TEWP curriculum | Enhanced with stronger focus on executive accountability, governance and due diligence | CEOs and board directors responsible for WSH in Construction, Manufacturing, Marine and Process industries | From 1 September 2026 |
| WSH Act s48 liability | Unchanged in law, but enforcement and training now foreground the due diligence defence | Directors, managers, secretaries and similar officers of any body corporate | Already in force; renewed emphasis from 2026 |
| Code of Practice (CEOs/Directors) | Continues to serve as the benchmark for what MOM regards as adequate board oversight | All directors and equivalent officers involved in policy-making and executive decisions | Voluntary, ongoing |
Practical Steps for Company Officers
Boards and individual directors, particularly of companies in the higher-risk industries named under TEWP, but arguably of any Singapore company given the general scope of section 48, should treat this as a prompt to check three things.
First, confirm who in the company has actually completed TEWP via MOM’s workplace safety and health resources, and whether that training predates the 1 September 2026 curriculum enhancement. If it does, consider whether refresher training is warranted given MOM’s evident intent to raise the bar on what constitutes adequate board-level engagement with WSH.
Second, review whether WSH risk reporting reaches the board in a documented, minuted form, rather than being handled entirely by an operations or HR function without board visibility. This links directly to the general statutory duty of directors to act with reasonable diligence, discussed in more detail in our article on director statutory duties under the Companies Act.
Third, ensure that the company’s governance structure does not leave an individual director personally exposed through inattention or an unmanaged conflict. Our articles on director fiduciary duties, director personal liability, and director conflicts of interest and related party transactions set out the broader landscape of personal exposure that WSH liability now sits alongside.
Where This Fits With Other 2026 Compliance Changes
AfA-SHEL and the enhanced TEWP are part of a wider pattern of MOM tightening employer obligations through 2026. Employers already juggling other MOM-driven changes, such as those covered in our piece on the expansion of Occupational Progressive Wages from 1 July 2026, should treat WSH governance as part of the same compliance calendar rather than a separate workstream owned solely by a safety officer.
Conclusion
AfA-SHEL’s headline focus areas, injury prevention, return-to-work support and workplace adaptation, are genuinely operational matters best led by HR and WSH professionals. But the enhanced TEWP curriculum arriving on 1 September 2026 is a direct signal to company officers: MOM expects boards to be able to show, not merely assert, that they exercised due diligence under section 48 of the WSH Act. For directors of companies in Construction, Manufacturing, Marine or Process industries, and arguably for officers of any Singapore body corporate given the general reach of the Act, this is a governance issue as much as a safety one.
If your board needs help mapping these obligations against your existing corporate governance framework, or reviewing whether your WSH reporting lines would support a due diligence defence, Raffles Corporate Services can help you review your governance structure alongside your other statutory obligations as a Singapore company officer.
The Editorial Team, Raffles Corporate Services