On 25 February 2026, the Singapore Competition & Consumer Commission (CCS) issued a draft of its revised guidance on airline alliance agreements (the “PAGN 2026”) for public consultation.
In our response, we offer several economic observations on the PAGN 2026. We welcome the broader and more detailed treatment of certain efficiencies that the updated document provides. However, we highlight two areas that merit closer consideration:
First, the draft places insufficient weight on pricing efficiencies typically associated with airline alliances.
Second, it provides only limited direction on how likely competitive effects should be assessed, relying largely on market shares—despite the previous guidance recognising that a full competitive assessment is essential.
