CCS updates passenger airline guidance note for alliance agreements
27 August 2026
On 27 July 2026, the Competition and Consumer Commission of Singapore (“CCS”) announced that it has updated the CCS Guidance Note for Passenger Airline Alliance Agreements relating to Passenger Services (“PAGN 2026”).
PAGN 2026, which took effect from 27 July 2026, provides greater clarity and guidance to airlines on CCS’s assessment framework and review process, incorporating stakeholder feedback from a public consultation conducted from 25 February 2026 to 11 March 2026. The business and legal community were generally supportive and offered constructive feedback on certain aspects. For more on the public consultation, please read our article “CCS conducts public consultation on revised guidance note for passenger airline alliance agreements”.
Key amendments
The main changes found in PAGN 2026 include:
- A more streamlined review process for airline alliance notifications: PAGN 2026 introduces a streamlined three-step approach for all airline alliance notifications, with specific milestones on when airlines should initiate commitment discussions with CCS and when to finalise commitments for market testing. PAGN 2026 also provides greater clarity on the role of
pre-notification discussions, state-of-play meetings, and circumstances where CCS may pause the review timeline to facilitate a robust assessment. - More comprehensive guidance on commitments: PAGN 2026 expands the guidance on commitments that airlines may offer to address competition concerns. This includes practical guidance on capacity commitments, capacity growth mechanisms, non-fulfilment allowances, as well as examples of other forms of pro-competitive commitments that CCS may consider on a case-by-case basis.
- Expanded guidance on CCS’s competition assessment framework: PAGN 2026 provides more comprehensive guidance on CCS’s substantive assessment of passenger airline alliance agreements, including counterfactual analysis, market definition, the treatment of differentiated airline products such as full service airlines and low cost carriers, as well as CCS’s analytic approach towards metal-neutral alliances.
- Enhanced guidance on the assessment of net economic benefit: PAGN 2026 sets out CCS’s analytical framework for assessing whether an alliance qualifies for the net economic benefit exclusion under the Competition Act 2004. It explains the evidential requirements for substantiating efficiency claims, provides examples of efficiencies previously accepted or rejected by CCS, and clarifies CCS’s approach to assessing benefits arising from closely related markets.
For further details, Appendix A to the CCS media release provides a summary of the key enhancements introduced in PAGN 2026, while Appendix B sets out CCS’s responses to the consultation feedback.
Reference materials
The following materials are available on the CCS website www.ccs.gov.sg: