SINGAPORE Law and Practice Contributed by: Adam Moncrieff, Karthik Kumar, Lynette Lim and Kelly Choo, Orrick, Herrington & Sutcliffe LLP
electricity or gas licensees access to infrastructure where required for their functions. The ETM Act also introduced approval obligations for repurposing key electricity and gas assets. The EMA is expected to balance commercial interests against energy security and system reliability when assessing repurposing requests. Centralised Gas Procurement and Singapore GasCo A further development is the establishment and imple- mentation of Singapore GasCo, established to cen- tralise the procurement and supply of natural gas to the power sector. The legislative framework supports this change by requiring prescribed generation entities that require gas to obtain gas only from the holder of a gas importer’s licence for central import, unless the EMA otherwise allows. Minimum Energy Efficiency Standards for Industrial Facilities Another material development is the commencement of the Energy Conservation (Amendment) Act 2024 on 1 December 2025, replacing Section 26B of the Energy Conservation Act 2012 of Singapore to create a broader framework for minimum energy efficiency standards (MEES) for prescribed energy-consuming systems. Under the new Section 26B, a registered relevant person must assess and monitor prescribed energy-consuming systems and submit reports to the Director-General. Where a prescribed energy-consuming system does not meet the prescribed MEES, the Director-General may direct the registered relevant person to carry out maintenance or take other measures to ensure com- pliance, reassess the system and submit an assess- ment report. Proposed Emissions Standards Code for Generation Units The EMA’s consultation on the proposed Emissions Standards Code is also a material regulatory devel- opment, although it appears to remain a consulta- tion rather than a finalised code in the official sources reviewed. The consultation sought comments on a proposed code to guide implementation of emissions
standards for new and repowered fossil fuel-fired gen- eration units. The standards themselves originate from the EMA’s 2023 policy decision. The EMA announced in Octo- ber 2023 that it would put in place emissions stand- ards for new and repowered fossil fuel-fired genera- tion units and would consult on a code of practice to enforce those standards. The EMA stated that Tier 1 units expected to run regularly would need to com- ply with a 0.355 tCO₂e/MWh emissions intensity limit. The proposed code would set minimum conditions for generation licensees, including obligations relat- ing to emissions monitoring, reporting, validation and hydrogen readiness. New Carbon Market Initiatives Singapore also launched new carbon-market initia- tives on 28 October 2025, which are relevant to the wider energy-transition landscape. The initiatives include voluntary carbon market guidance on the role of carbon credits in corporate decarbonisation, discussions with leading corporates to establish an industry-led buyers’ coalition, and a new Financial Sector Carbon Market Development Grant. The Guidance on Role of Carbon Credits in Corporate Decarbonisation (the “VCM Guidance”) was jointly developed by the National Climate Change Secretar- iat, the Ministry of Trade and Industry and Enterprise Singapore, in partnership with the Singapore Sustain- able Finance Association, industry partners, academ- ics and international organisations. The VCM guid- ance is intended to help companies use and disclose carbon credits as part of a credible decarbonisation plan. It also states that Singapore supports compa- nies’ participation in well-functioning carbon markets and voluntary use of high-quality carbon credits as part of a credible decarbonisation plan. The Monetary Authority of Singapore will set aside SGD15 million over three years until 2028 from the Financial Sector Development Fund to support finan- cial institutions in building carbon-market capabilities and in developing innovative financing solutions and platforms for carbon-project financing, trading, insur- ance and related services.
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