CCS Issues Updated Guidance Note for Passenger Airline Alliance Agreements

The Competition and Consumer Commission of Singapore (“CCS“) has updated its passenger airline guidance note for alliance agreements between airlines (“PAGN 2026“). The amendments incorporate feedback from a public consultation conducted from 25 February 2026 to 11 March 2026 and seek to provide greater clarity and guidance to airlines on CCS’s assessment framework. To read more about the public consultation, please refer to our February 2026 NewsBytes article titled “Public Consultation on Revised Guidance Note for Passenger Airline Alliance Agreements“.

CCS has published the PAGN 2026 in view of the increasing volume of passenger airline alliance agreements voluntarily notified to CCS for decision since the Competition Act 2004 came into force. The amendments and additions aim to better assist airlines in considering their notification to CCS and further streamline the assessment process.

The main amendments in the PAGN 2026 include the following:

1. Streamlined review process: A streamlined three-step approach for airline alliance notifications has been introduced, which includes: (i) Step 1, where CCS will identify and communicate any competition concerns, following which the airlines will have the opportunity to offer commitments; (ii) Step 2, where airlines should submit their commitments proposal to CCS for market testing purposes, and make the necessary changes to the commitments proposal after discussion with CCS; and (iii) Step 3, where airlines should submit the final set of their commitments proposal. 
   
   

   PAGN 2026 also provides greater clarity on the role of pre-notification discussions, state-of-play meetings, confidentiality claims and circumstances where CCS may pause the review timeline.  

2. Guidance on commitments: PAGN 2026 provides more comprehensive guidance on its assessment of commitments that airlines may offer to address competition concerns. The amendments introduce key considerations that the airlines should consider when formulating commitments, taking into account CCS’s treatment of commitments received over the years. These include the following:

• • Capacity commitments: CCS considers capacity commitments to be one of the most pragmatic solutions to address competition concerns arising from an airline alliance, as they generally disincentivise airlines from raising prices.
  • Capacity growth factor: While CCS generally accepts airline capacity commitments that are sufficient to address competition concerns based on sustained demand on the relevant routes, to maintain the relevance of commitments as a market grows, it is essential to include a mechanism to increase seat capacity by a reasonable amount, such as growth trigger events.
  • Non-fulfilment period: CCS deems it reasonable for a non-fulfilment allowance to be incorporated, where appropriate, if airlines are temporarily unable to fulfil their weekly capacity obligations (typically no more than three weeks out of 52 weeks in a given year).
  • Other forms of commitments: Generally, CCS does not accept fare commitments as an alternative to capacity commitments, or the divestment of slots from the airlines to its competitors.

3. Guidance on CCS’s competition assessment framework: More comprehensive guidance has been provided on CCS’s approach to substantive assessment of passenger airline alliance agreements, including the following:

• • Market definition: PAGN 2026 confirms CCS’s route-by-route approach to market definition, as adopted in CCS’s review of the 18 past passenger airline alliance agreements. The amendments also set out what additional information airlines are required to provide if they wish to advance an alternative market definition.
  • Differentiated airline products: CCS has clarified in the PAGN 2026 that it is of the view that competition has evolved in a way that the distinction between Full Service Airlines and Low Cost Carriers is generally blurring and that it will include Low Cost Carriers in the relevant market at the first instance unless there are unique circumstances which warrant a different approach.
  • Metal neutral agreements: PAGN 2026 clarifies CCS’s approach to analytic approach towards metal-neutral alliances.

4. Guidance on the assessment of Net Economic Benefit (“NEB”): PAGN 2026 sets out CCS’s approach in assessing whether an alliance qualifies for the NEB exclusion under the Competition Act 2004. The amendments explain, among others:

• • how efficiency claims are to be substantiated;
  • examples of efficiencies previously accepted or rejected by CCS;
  • CCS’s strict approach that any benefit needs to offset or mitigate competition concerns from the problematic route (subject to the possibility of a network approach); and
  • CCS’s assessment of benefits arising from closely related markets.

The PAGN 2026 supersedes the previous guidance note with effect from 27 July 2026. CCS has highlighted that the guidance note will be reviewed periodically to ensure its continued efficacy.

Click on the following links for more information (available on the CCS website at www.ccs.gov.sg):

• • CCS Press Release titled “CCS Updates Passenger Airline Guidance Note for Alliance Agreements”
  • CCS Guidance Note for Passenger Airline Alliance Agreements Relating to Passenger Services

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