2026 FDI and National Security Review

In deciding whether an entity should be a designated entity, the Minister considers if such entity provides a critical function in relation to Singapore’s national security interests (for instance, being a key provider of security-related functions where there are few or no alternatives), and whether it is already adequately covered by existing sectoral legislation. A list of nine designated entities was first published on May 31, 2024, in the government Gazette, and is reviewed by the OSIR on a continuous basis. To date, entities designated under the SIRA have included entities active in the defense, logistics, petrochemicals, public security and technology sectors. One entity, Aster Chemicals and Energy Pte. Ltd., was added to this list on November 21, 2024. Additionally, one entity, Shell Singapore, was removed from the list on November 19, 2025, leaving the current count at nine entities. On February 26, 2025, the Prime Minister exercised his power under SIRA to transfer ministerial responsibility for certain designated entities to other Ministers. Specifically, oversight of Sembcorp Specialised Construction Pte. Ltd., ST Engineering Marine Ltd., ST Engineering Land Systems Ltd., ST Engineering Defence Aviation Services Pte. Ltd., and ST Engineering Digital Systems Pte. Ltd. was transferred to the Minister for Defence, while oversight of ST Logistics Pte. Ltd. was transferred to the Minister for Home Affairs. ExxonMobil Asia Pacific Pte. Ltd., Singapore Refining Company Pte. Ltd., and Aster Chemicals and Energy Pte. Ltd. remain under the purview of the Minister for Trade and Industry. The OSIR continues to serve as the single point of

contact for all SIRA matters regardless of which Minister holds responsibility for a particular designated entity. In October 2025, the Significant Investments Review (Disregarded Equity Interests) Regulations 2025 came into effect, clarifying how certain equity interests are treated for the purpose of calculating controller thresholds under SIRA. Specifically, equity interests held purely as a bare trustee, or held by a lender as security in the ordinary course of a money-lending business, are disregarded in computing whether a person has reached a relevant controller threshold. This clarification is of particular relevance to financial institutions and fund managers that may hold equity interests in designated entities in a custodial or collateral capacity. Designated entities are subject to notification and approval obligations under the SIRA, as elaborated on below. Notification and approval obligations relating to ownership and control of designated entities: ^ Buyers must notify the Minister within seven days after they become a 5% controller 1 of a designated entity. ^ Buyers must seek the prior written approval of the Minister before (i) becoming a 12%, 25% or 50% controller of a designated entity, (ii) becoming an indirect controller 2 of a designated entity or (iii) acquiring the business or undertaking (or any part thereof) of a designated entity as a going concern. ^ In reviewing an application for approval, the Minister may consider, among other factors, whether the relevant person (or in the case of

1 A controller, in relation to a designated entity, means a person who, alone or together with associates, holds a certain percentage of the total equity interests in the designated entity, or is in a position to control a certain percentage of the voting power in the designated entity. 2 An indirect controller, in relation to an entity, generally means any person (whether acting alone or together with other person(s), and whether with or without holding equity interests or controlling any voting power of an entity) (i) whose directions, instructions or wishes the directors, officers or trustee (as applicable) of the entity are accustomed or under an obligation to act in accordance with, or (ii) who is in a position to determine the policy of the entity.

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FDI and National Security Review

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