Media Releases
CCS Consults on Proposed Commitments in Acquisition Involving Marina Operators
12 November 2026
(View media release [PDF, 493.41 KB] (opens in new tab) in PDF)
CCS Consults on Proposed Commitments in Acquisition Involving Marina Operators
1. The Competition and Consumer Commission of Singapore (“CCS”) is inviting public feedback on commitments proposed by SUTL Group (comprising SUTL Enterprise Ltd and its subsidiaries) to address potential competition concerns identified by CCS in relation to SUTL Enterprise Ltd (“SUTL”)'s proposed acquisition, through its wholly-owned subsidiary One15 Marina KB Pte. Ltd., of the property and assets at Marina at Keppel Bay (“MKB”) from Keppel Bay Pte Ltd (collectively, the “Parties”) (the “Proposed Transaction”).
Background
2. CCS commenced its Phase 1 review on 27 February 2026, following the acceptance of an application from the Parties.[1] Following the completion of its Phase 1 review, CCS raised competition concerns with the Parties on the Proposed Transaction on 27 April 2026.[2]
3. CCS subsequently commenced an in-depth Phase 2 review of the Proposed Transaction following further filing of the relevant documents by the Parties on 14 July 2026.[3]
4. Feedback received during CCS's review suggested that the Proposed Transaction could raise competition concerns, as the Parties operate neighbouring marinas and may be each other's closest competitors, with charter operators potentially facing the greatest impact.
SUTL Group’s Proposed Commitments
5. To address these competition concerns, SUTL Group has proposed a set of commitments, which include:
a. A Price Cap on wet berthing rates: Annual increases, including associated surcharges, will be limited to the Consumer Price Index (“CPI”) plus three (3) percentage points. SUTL Group will also be restricted from introducing new fees or charges that could potentially circumvent the cap, subject to certain exceptions[4].
b. Credit on wet berthing rates for charter operators: In addition to the cap on annual rate increases, charter operators will receive an additional 1% credit on their wet berthing charges. SUTL Group has also committed not to terminate or refuse to renew charter operators’ berthing contracts without specified reasons and continue its current policy to allocate berths to customers on its waiting list on a first-come, first-served basis.
c. Service standards: Both marinas will maintain minimum specified service standards, including for berthing assistance, security, utilities, fuel supply and other marina services.
d. Temporary berthing access: Both marinas will provide a designated berth for the temporary embarkation and disembarkation of passengers to commercial pleasure crafts. This service will be available daily from 8am to 10pm, subject to specified conditions and availability.
6. The Proposed Commitments will apply for five years from the date specified in CCS's favourable decision on the Proposed Transaction, except that the commitments relating to charter operators in relation to berthing rates, berth allocation and berthing contracts, and temporary berthing access for charter operators will apply for seven years.
7. SUTL Group has also proposed to appoint an independent Monitoring Trustee, subject to CCS's approval, to monitor compliance with the Proposed Commitments, with six-monthly submission of reports to CCS.
Public Consultation
8. CCS is inviting public feedback on the Proposed Commitments set out in Annex A [PDF, 352.42 KB] (opens in new tab), from 12 November 2026 to 5pm on 26 November 2026, as part of assessing whether the Proposed Commitments would sufficiently address the competition concerns arising from the Proposed Transaction.
9. Public feedback can be provided via the official online form (opens in new tab), or by email to CCS_consultation@ccs.gov.sg. If the submission or correspondence contains confidential information, please also provide CCS with a non-confidential version of the submission or correspondence.
10. More information on the Proposed Transaction can be accessed and downloaded from the CCS website at ccs.gov.sg (opens in new tab) under the section “Public Consultation (opens in new tab)”.
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About the Competition & Consumer Commission of Singapore
The Competition and Consumer Commission of Singapore (“CCS”) is a statutory board of the Ministry of Energy, Trade and Industry. Our mission is to make markets work well to create opportunities and choices for businesses and consumers in Singapore.
CCS administers and enforces the Competition Act 2004 and the Consumer Protection (Fair Trading) Act 2003, to guard against anti-competitive activities and unfair trade practices. Additionally, CCS ensures that businesses observe fair trade measurement practices by administering the Weights and Measures Act 1975, and ensures the supply of safe consumer goods by enforcing and implementing the Consumer Protection (Trade Descriptions and Safety Requirements) Act 1975 and its associated Regulations.
For more information, please visit www.ccs.gov.sg (opens in new tab).
[1] For more information on the Proposed Transaction, please refer to CCS’s public register dated 2 March 2026 (opens in new tab).
[4] These exceptions are listed in full at paragraphs 4.2.3 and 4.2.4 of Annex A.
About the Section 54 Prohibition under the Competition Act & Merger Procedures
Section 54 of the Competition Act 2004 (“the Act”) prohibits mergers that have resulted, or may be expected to result, in a substantial lessening of competition in Singapore. CCS is generally of the view that competition concerns are unlikely to arise in a merger situation unless:
The merged entity has/will have a market share of 40% or more; or
The merged entity has/will have a market share of between 20% to 40% and the post-merger combined market share of the three largest firms is 70% or more.
Merging entities are not required to notify CCS of their merger but they should conduct a self-assessment to ascertain if a notification to CCS is necessary. If they are concerned that the merger has infringed, or is likely to infringe, the Act, they should notify their merger to CCS. In such cases, CCS will assess the effect of the merger on competition and decide if the merger has resulted, or is likely to result, in a substantial lessening of competition (“SLC”) in Singapore.
Separately, CCS has the ability to conduct an investigation into an un-notified merger if there are reasonable grounds for suspecting that the merger infringes section 54 of the Act. In the event CCS finds that a merger situation has resulted or is expected to result in an SLC, CCS has powers to give directions to remedy the SLC. For example, CCS can require the merger to be unwound or modified to address or prevent the SLC, as the case may be. CCS may also consider issuing interim measures prior to the final determination of the investigation.
Phase 1 and Phase 2 Merger Review
A Phase 1 review entails a quick review and allows merger situations that do not raise competition concerns under the section 54 prohibition to proceed. CCS expects to complete a Phase 1 review within 30 business days. By the end of this period, CCS will determine whether to issue a favourable decision and allow the merger situation to proceed. If CCS is unable, at the end of the 30-day period, to conclude that the merger situation will not result in a substantial lessening of competition, CCS will inform the merger parties and the merger parties may file further information and supporting documents as listed in Form M2. Upon receipt of Form M2, CCS will proceed to a Phase 2 review.
A Phase 2 review entails a more detailed and extensive examination of the merger situation. While the principles of substantive assessment are the same, CCS will require access to more extensive and detailed information regarding the merger parties and the markets in question.
As the Phase 2 review is more complex, CCS will endeavour to complete a Phase 2 review within 120 business days.
Commitments
Section 60A of the Act states that CCS may, at any time before making a decision as to whether the section 54 prohibition has been or will be infringed, accept commitments that remedy, mitigate or prevent the substantial lessening of competition or any adverse effect arising from the merger situation. Where CCS has accepted a commitment, CCS will make a favourable decision.
Further details can be found in the CCS Guidelines on Merger Procedures (opens in new tab).
For more information, please visit www.ccs.gov.sg (opens in new tab).