The Competition and Consumer Commission of Singapore (CCS) has revised its guidance note for airline alliance agreements, effective from 27 July 2026. The updated Passenger Airline Guidance Note 2026 (PAGN 2026) introduces a streamlined review process and expanded guidance on commitments and competition assessments, following feedback from a public consultation held earlier this year.
The key amendments in PAGN 2026 include a three-step review process for airline alliance notifications, designed to provide procedural certainty and facilitate earlier engagement with CCS. This process outlines specific milestones for commitment discussions and market testing, enhancing the efficiency of reviews. Additionally, the guidance note offers more comprehensive advice on commitments, including capacity commitments and growth mechanisms, to address competition concerns effectively.
PAGN 2026 also expands on CCS’s competition assessment framework, providing detailed guidance on market definition, counterfactual analysis, and the treatment of differentiated airline products such as Full Service Airlines and Low Cost Carriers. The note clarifies the assessment of Net Economic Benefit (NEB) claims, outlining evidential requirements and examples of efficiencies that may qualify for NEB exclusion under the Competition Act.
The revisions aim to enhance regulatory certainty and provide clearer guidance to industry participants. CCS plans to review the guidance periodically, incorporating insights from its cases and best practices from other jurisdictions.
