Alvin, can you briefly describe your professional background?
In my role as chief executive of the Competition and Consumer Commission of Singapore (CCS), I oversee the administration and enforcement of Singapore’s competition, consumer protection, and legal metrology laws to ensure Singapore’s markets remain competitive and consumers are protected from unfair trading practices. This is my second stint with CCS. During my first stint, from June 2010 to August 2012, I served as director of legal and enforcement.
I have been serving in the Singapore Public Service for over two decades. I started my career as a justices’ law clerk to the chief justice and judges of the Supreme Court.
I previously served in the Attorney-General’s Chambers as a deputy senior state counsel and a deputy public prosecutor, where I specialized in white-collar and major crimes. I was also a judicial officer in the State Courts, where I presided over Penal Code offenses, civil disputes, and tribunal matters.
My career has taken me across various facets of government legal work, ranging from intellectual property, tax law, labor relations, and procurement.
Previously, I was a tribunal member with the Ministry of Defence’s Compensation Board, the Work Injury Compensation Board, and president of the General Court Martial. Currently, I sit on the Ministry of Law’s Copyright Tribunal and am also a Lien Fellow with Nanyang Technological University’s Nanyang Centre for Public Administration.
Singapore competition law is both highly relevant and relatively unfamiliar to many readers. Can you give a high-level overview of recent antitrust developments?
CCS has completed over 50 cases in Fiscal Year 2024, encompassing investigations, merger assessments, and government advisories, demonstrating our active enforcement approach across diverse sectors.
The momentum has continued strongly into 2025. We issued positive guidance in our inaugural case under the streamlined process for collaborations pursuing environmental sustainability objectives in January 2025. Our enforcement activities have included infringement decisions against contractors for bid-rigging in public-sector tenders in May 2025, and against Chinese yuan remittance service providers for anticompetitive information exchanges in July 2025. We also have several investigations that are currently underway.
In the aviation sector, we maintained a balanced and rigorous approach in our assessments. We completed our review of several joint-venture and commercial-cooperation proposals, including conditional approvals for the proposed expanded joint venture between Singapore Airlines and Deutsche Lufthansa AG in January 2025, and the proposed commercial cooperation between Singapore Airlines and Malaysia Airlines after accepting commitments in July 2025. In 2024, we released Qantas and Emirates from capacity commitments on the Singapore-Brisbane and vice versa routes.
We have continued to review and refine our competition framework to streamline processes and increase efficiency, maintaining Singapore’s reputation as a business-conducive jurisdiction while ensuring robust competition enforcement. In October 2025, we launched consultations on proposed changes to two key competition guidelines: the streamlining of the merger regime and a new settlement procedure. The proposed changes to the merger procedure guidelines are designed to ensure our merger regime continues to operate optimally, with merger notifications processed in a timely manner without compromising the robustness of our assessment. That has since been finalized and is slated to take effect May 1.
Under the proposed new settlement procedure, we intend to introduce a streamlined settlement procedure that will increase the maximum settlement-discount quantum to recognize the greater efficiencies reaped when parties successfully conclude an investigation via settlement, facilitate the ease with which parties can initiate settlement, and provide greater clarity on our position should a party that has entered into a settlement agreement subsequently appeal against our decision. The public consultation for that set of settlement guidelines is currently being evaluated.
Significant milestones in the past year included CCS’s 20th anniversary celebrations, the unveiling of our new logo, and hosting the 11th Association of Southeast Asian Nations (ASEAN) Competition Conference and CCS Conference in September 2025. The anniversary marked two decades of competition enforcement in Singapore, while the conferences provided invaluable platforms for competition practitioners across the region to discuss the latest policy developments, share best practices, and explore how competition enforcement can build a more resilient and inclusive regional economy. It also allowed us to examine emerging trends in competition and consumer protection compliance across Singapore and ASEAN.
These activities underscore Singapore’s role as a leading competition-policy hub in Asia, balancing robust enforcement with clear guidance to support business compliance and economic growth.
In 2020, CCS conducted a market study on e-commerce platforms. What did it find, and how has it shaped your approach to digital markets?
In 2020, we undertook a market study on e-commerce platforms to gain an in-depth understanding of the business models and operating environment of e-commerce platforms, which compete across multiple market segments offering distinct products and services.
Our market study in 2020 did not find any major competition concerns relating to e-commerce platforms in Singapore. We found that several e-commerce platforms compete aggressively for customers. While customers do display a certain degree of platform loyalty, a significant number practice multi-homing, in that they use more than one platform simultaneously to buy or sell. We also found that while data collected by e-commerce platforms benefits platform operators by allowing them to improve the quality of service offered to customers, the lack of data is not currently regarded by new entrants as an insurmountable barrier to entry.
We identified key areas in which further clarity and guidance by CCS could be beneficial to assist businesses in the application of the Competition Act in the digital platform economy. For example, in the context of merger assessment, to ensure that CCS’s merger regime remains well placed to address instances of “killer acquisitions,” we amended our guidelines on merger assessment to clarify our approach toward assessing mergers involving markets where innovation is an important feature of competition, and where one or more of the merger parties is an important innovator, even if they do not have a large market share.
We also updated our guidelines relating to how markets are defined for multi-sided platforms, so that businesses can better understand how CCS assesses markets involving multi-sided platforms or digital-platform companies. For instance, we have included specific features of multi-sided platforms (e.g., number of markets to be defined, indirect network effects, price structure) that may be taken into consideration when assessing whether there is a “product ecosystem” comprising multiple products and/or services sold by the same seller.
CCS flagged several AI-related theories of harm in its 2024 OECD report. Have any materialized?
We remain vigilant in monitoring developments in the AI sector. To this end, we commenced a market study into AI last year. The market study aims to provide an analysis of the current AI landscape in Singapore, identify emerging competition and consumer concerns, and recommend appropriate regulatory responses where necessary.
As part of this study, we have been actively engaging with stakeholders across the AI ecosystem to gather insights. This includes discussions with other government agencies, AI developers (both local and multinational developers), businesses utilizing AI technologies, and other relevant parties. We anticipate publishing our findings and recommendations later this year.
Beyond competition matters, we have also observed consumer protection issues related to AI materializing, for example, in the Lambency Detailing case, which involved AI-generated fake reviews.
In addition, in 2026, ASEAN member states will embark on an ASEAN market study into AI, with Singapore as the lead member state for this study. That process is currently underway.
Singapore’s AI Markets Toolkit allows developers to self-assess compliance. How does it work in practice?
I must say that the initiative has been well received. We actively address emerging competition and consumer protection issues in AI. We launched the AI Markets Toolkit in late September 2025, in collaboration with Singapore’s Infocomm Media Development Authority (IMDA).
The AIM Toolkit is a voluntary self-assessment tool that helps businesses evaluate their AI models and business practices for competition and consumer protection compliance through a series of process checks and technical tests. This toolkit runs entirely on the business’s local system, and neither CCS nor any third parties will have access to any of the data, model, or information uploaded. Upon completing the self-assessment, a report, comprising a summary of results and recommendations, will be automatically generated for the business. CCS will not be able to see the results of the toolkit.
Implementing the AIM Toolkit would minimize the risk of a business inadvertently engaging in anticompetitive or unfair trading practices. The AIM Toolkit is part of CCS’s modernized compliance program and is unique globally because it signals that we are here to work with industry, and not just act as an enforcer while companies flounder amid new technology. Usage of the toolkit can be considered a mitigating factor for the purposes of financial-penalty calculation in the event of an infringement. We hope that use of this tool can help businesses identify possible infringements early and take appropriate and timely remedial actions.
Are there any notable recent or upcoming regulations in digital platforms, AI, or data?
The government has introduced regulations to address specific harms in the digital space. For instance, the Online Criminal Harms Act 2023 deals with criminal content and activities on digital platforms, while the more recent Online Safety Bill, introduced in November 2025, allows victims of online harm (such as harassment and doxing) to seek recourse, with an Online Safety Commission to be established to administer this act.
Singapore is also drawing up regulations for data centers and cloud-service providers under the Digital Infrastructure Act, which will, inter alia, require these providers to put in place cybersecurity and service-disruption measures to ensure network resiliency in Singapore. This legislation will be tabled in Parliament later this year.
These developments are of keen interest to CCS because issues in the digital space are often multidisciplinary and cut across different domains, including areas involving competition and consumer protection. This requires a whole-of-government approach to address these challenges. As an active participant in this space, CCS will need to review its toolkit and framework continuously to ensure they are fit for purpose and complement tools used by other government agencies. This includes being robust in enforcement approaches, including the use of nonregulatory tools.
For instance, CCS has recently updated Singapore’s national standards for e-commerce transactions, with best practices that e-marketplaces and e-retailers can adopt to enhance consumer protection and trust, as well as to foster an open and competitive e-commerce sector. These best practices were introduced in consultation with stakeholders in the e-commerce industry (e.g., online marketplaces, merchants, consumer representatives, government agencies, and industry experts) to achieve a consensus-based outcome, such that businesses can resolve issues without requiring stronger intervention. This reflects our approach of co-creating solutions with industry rather than relying solely on regulation.
How does Singapore view the European Union’s Digital Markets Act? Are similar measures under consideration?
Over the years, CCS has observed that different jurisdictions have moved toward prescriptive ex ante regulation of digital platforms to supplement existing competition and consumer law frameworks, with the European Union’s Digital Markets Act (DMA) as a prime example. We note that several other jurisdictions, including Australia, the United Kingdom, Japan, South Korea, and certain ASEAN member states, are also developing their own regulatory responses to digital-market challenges, though their approaches vary considerably.
Although the jury on the overall efficacy of the DMA is still out, the issues it seeks to address are common across competition agencies. Smaller agencies such as CCS need to find ways to address these issues, recognizing that there is no one-size-fits-all approach. This is especially important for a small jurisdiction like Singapore, where such regulations can have a significant impact on the digital economy.
For this reason, CCS has explored innovative ways to achieve balanced solutions that work for Singapore. For instance, CCS has pursued voluntary industry initiatives to raise consumer protection and competition standards in the e-commerce sector by introducing guidance for businesses. This allows us to co-create solutions with stakeholders and resolve issues without regulatory intervention.
Concurrently, we are undertaking a systematic review of global regulatory frameworks to assess their relevance to Singapore. While we do not rule out regulatory approaches, any measures would need to be introduced in a calibrated manner, taking into account market conditions, the state of competition, and the impact on businesses.
What role could industrial policy play in antitrust enforcement in Singapore?
I see industrial policy and competition policy as potentially complementary rather than at odds. Competition policy can inform industrial policy to bring about sustainable, long-term economic growth.
Conventional competition policy suggests that businesses should compete and grow on their own merit, with minimal government intervention, so that they can scale and compete effectively regionally and internationally. Naturally innovative and productive businesses will compete better in global markets. Markets, however, do not operate in perfect competition, and certain factors may hamper growth.
Market studies conducted by CCS can shed light on these factors and provide the government with insights into specific market dynamics. Armed with such insights, targeted industrial policies—such as grants, subsidies, and tax incentives—may be implemented to preserve a level playing field and encourage entry.
CCS also advises the Singapore government and other public agencies on competition-related aspects of policymaking. For example, CCS previously worked with another agency to improve capacity-sharing arrangements for container haulage to ensure the market remains competitive while encouraging resource optimization.
Through such efforts, a balance can be struck between industrial policy and competition policy.
Is there anything else you would like to add?
Looking ahead, CCS will continue to strengthen its regulatory capabilities through the strategic adoption of emerging technologies and AI tools.
CCS will continue to evolve its regulatory framework to meet the needs of Singapore in an increasingly complex global environment.
On the international front, CCS will continue strengthening its leadership through active participation in key forums. I was recently appointed vice chair of the International Competition Network (ICN) and look forward to advancing competition policy worldwide.
As vice chair of the ICN, I am committed to ensuring it remains relevant and valuable to competition agencies across all stages of development, sizes, and regions. My focus is on enhancing platforms that bridge existing gaps and enable agencies to participate meaningfully in tailored knowledge-sharing initiatives. The goal is to foster an inclusive environment where agencies not only learn from established authorities but also contribute their own perspectives and solutions to shared challenges.
