Telecommunications Licensing in Singapore: FBO and SBO Licences

The short answer: when you need a telecommunications licence in Singapore

You need a telecommunications licence in Singapore if you operate or provide telecommunication systems or services to third parties here. The Telecommunications Act 1999 requires it, and the Infocomm Media Development Authority (IMDA) issues two types: a Facilities-Based Operations (FBO) licence if you deploy or operate your own network infrastructure, and a Services-Based Operations (SBO) licence if you lease capacity from licensed operators to provide or resell services.

SBO licences come in two forms. Some services, such as mobile virtual network operation, IP telephony, international simple resale and managed data networks, need an individual licence. Others, such as certain resale and value-added services, fall under a class licence, for which you register rather than apply.

As of October 2026, the competition framework that applies to licensees is also changing. In May 2026 Parliament passed amendments to the IMDA Act to harmonise competition and merger rules across the telecommunications and media sectors, with consequential changes to the Telecommunications Act.

The legal framework

The Telecommunications Act 1999 prohibits operating telecommunication systems or providing telecommunication services without a licence, and gives IMDA power to grant licences, impose conditions and issue codes of practice. Singapore's telecommunications market was fully liberalised from 1 April 2000, and IMDA does not pre-determine how many licences it will issue.

IMDA uses a two-pronged approach that distinguishes facilities-based from services-based operations. The framework is hierarchical: an FBO licensee can offer the services an SBO licensee can, but not the reverse. IMDA intends that an entity should hold a single licence for all its networks and services, so an SBO licensee that later builds its own network must apply for an FBO licence, which then replaces the SBO licence.

All licensees must comply with the Code of Practice for Competition in the Provision of Telecommunication and Media Services 2022, often called the Telecom and Media Competition Code. FBO licensees also face codes such as the Code of Practice for Info-communication Facilities in Buildings and, where applicable, accounting separation guidelines.

Data centre and cloud operators should also check the new digital infrastructure regime, covered in our guide to the Digital Infrastructure Act, and critical information infrastructure duties under the Cybersecurity Act.

FBO or SBO: choosing the right telecommunications licence in Singapore

The dividing line is whether you deploy or operate infrastructure to serve third parties outside your own property boundaries. The table summarises the main differences, based on IMDA's current guidelines.

FBO licensees that commit to substantial infrastructure investment and rollout may apply to be designated as Public Telecommunication Licensees. That designation brings statutory facilitation for installing and protecting systems, but IMDA may also impose basic service obligations.

SBO (Individual) licensees that collect deposits or use prepaid cards must have a minimum paid-up capital at licensing, and class licensees may not collect deposits or use prepaid cards at all. Prepaid models therefore need to be checked against the licence category early.

When you may not need a licence

Two carve-outs in IMDA's guidelines often matter to multinational groups. First, a corporation that leases network elements from licensed operators to provide telecommunication services solely within itself or to its related corporations, as defined by the Companies Act, does not need an FBO or SBO licence. A group's internal wide area network typically falls here.

Second, an entity that activates its own IRU capacity on submarine cables, or lights international dark fibre, purely to transit traffic through Singapore or for self-use may not need an FBO licence. The conditions are strict: it must procure all domestic backhaul and network services from licensed operators in Singapore, must not deploy other infrastructure here, and must not offer telecommunication services in Singapore.

The exemptions are narrow and fact-specific. Once services are offered to unrelated customers, including wholesale international simple resale or IP transit, a licence is likely to be required. Getting the analysis wrong can mean operating without a licence.

How the IMDA application process works

1. Scope the services. Describe each service, the network elements used, who the customers are and whether you will deploy infrastructure. This determines whether you need an FBO, SBO (Individual) or SBO (Class) licence.
2. Set up the right entity. FBO applicants must be Singapore-incorporated companies. SBO applicants can be Singapore companies or registered foreign companies, and class licensees can also be LLPs or LPs.
3. Prepare the proposal. For an FBO licence, IMDA evaluates the applicant's vision, organisation and financial strength, competition strategy, technical soundness and commitments, as well as wider benefits to the industry and economy.
4. Check related authorisations. Some services need further approvals, such as spectrum assignment, internet access service provider registration or permits from other agencies. IMDA's FBO guidelines note that internet access providers must register as an Internet Access Service Provider within 14 days of starting service.
5. Submit and respond to queries. File through IMDA's licensing channels or, for class licences, the GoBusiness Licensing portal. Expect clarification questions on network design, quality of service and customer protection.
6. Accept licence conditions. Review the licence template carefully, including conditions on changes in scope, quality of service, interconnection, numbering and reporting.
7. Build compliance into operations. Set up processes for fee declarations based on annual gross turnover, notifying IMDA of changes, and obtaining prior approval before changing network or service scope.

Documents to prepare

• Corporate documents for the applicant entity and its shareholding structure, including ultimate owners.
• A business plan describing services, target customers, pricing approach and rollout timetable.
• A technical plan covering network architecture, leased elements, interconnection and resilience.
• Financial information showing the capacity to fund the rollout and sustain operations.
• Quality of service commitments and customer service arrangements, including complaint handling.
• Details of any spectrum, numbering or other authorisations sought in parallel.

IMDA's FBO guidelines and SBO guidelines set out the information required, and the SBO licence page links to the current licence template. Class licence registration is handled through GoBusiness.

Ongoing obligations for licensees

A telecommunications licence in Singapore is a continuing relationship with IMDA. Licensees must seek IMDA's prior approval for changes to the scope of networks or services, and SBO (Individual) licensees must notify IMDA of changes in particulars within a short period. Fees are recalculated annually on gross turnover from licensable activities, so revenue allocation between licensed and unlicensed activities needs care.

Licensees must meet IMDA's quality of service standards and comply with the competition code, which prohibits abuse of dominance and anti-competitive agreements and includes consumer protection provisions. Dominant licensees face additional obligations, such as interconnection and non-discrimination duties.

Cybersecurity and resilience obligations are increasing. Telecommunications operators designated as owners of critical information infrastructure face specific duties, and IMDA has issued codes on telecommunications cybersecurity. Our telecommunications regulation page covers these obligations in more depth.

How FBO fees work in practice

FBO fees are tiered. IMDA's guidelines set a fixed amount for the first S$50 million of annual gross turnover, a percentage on turnover between S$50 million and S$100 million, and a higher percentage above that. IMDA gives a worked example: an FBO licensee with annual gross turnover of S$60 million pays the S$80,000 base amount plus 0.8% of the incremental S$10 million.

Because turnover means consideration for licensable activities, groups that combine telecommunication services with software, hardware or consulting should document how revenue is allocated. A clear allocation methodology, agreed with auditors, reduces the risk of disputes when fee declarations are reviewed.

The 2026 harmonised competition changes

On 7 May 2026 Parliament passed the Info-communications Media Development Authority (Amendment) Bill. Its main purpose is to align the media sector's competition and consumer protection framework with that already applied to telecommunications, with consequential amendments to the Telecommunications Act so that the language and approach are consistent across both sectors.

For media businesses, the headline change is broader merger control: transactions by any person that result in acquiring 30% or more of equity or voting power in a regulated media entity, effective control, or its business as a going concern, will need IMDA's prior approval. Pro forma transactions that do not change voting power are to move from approval to notification, mirroring the telecommunications approach.

IMDA also gains clearer powers to issue directions on market conduct and consumer protection, to gather information on shareholdings and essential resources, and to approve codes of practice prepared by others. Commentators have also noted new options to seek reconsideration of IMDA decisions or appeal to the Minister. Commencement dates should be checked before any transaction closes. Our pages on merger control and competition law explain how these sector rules interact with the general regime.

Illustrative scenario: an IoT connectivity start-up

This scenario is illustrative only and does not describe any real matter. A start-up plans to sell connected sensors to building owners, with SIM-based connectivity bundled into a monthly fee. It leases mobile capacity from a licensed operator and manages the devices through its own cloud platform.

Because it provides connectivity to third-party customers using leased network elements, it is likely to need an SBO licence. Machine-to-machine services fall within the SBO (Individual) category under IMDA's guidelines. The start-up sets up a Singapore company, prepares its application and reviews its customer contracts against licence conditions.

A year later, it considers deploying its own low-power wide-area gateways on clients' rooftops to serve multiple buildings. That would mean operating its own network facilities to serve third parties, so it would need to apply for an FBO licence, which would replace its SBO licence. Planning that transition early avoids a gap in authorisation.

Risks and common mistakes

Cross-border angle and next steps

Singapore's lack of foreign equity limits makes it attractive for regional operators. Groups from Bangladesh, the UAE, China and the UK often use Singapore as a hub for subsea capacity, data centres and regional enterprise services. Our data centres and digital infrastructure and foreign direct investment pages cover related structuring and approval questions.

Before applying for a telecommunications licence in Singapore, confirm the service map, the licence category, the right entity, related registrations and any transaction approvals. Then build fee calculation, change approvals and competition compliance into operations.

Where licensing questions connect with transactions or disputes, we coordinate across our network. Where Singapore court or tribunal representation is required, we work alongside Singapore-qualified counsel. To discuss which telecommunications licence in Singapore fits your business, please contact us.

Frequently asked questions

Sources and official materials

1. IMDA: Guidelines on Submission of Application for Facilities-Based Operations Licence — FBO scope, eligibility, evaluation, fees and duration
2. IMDA: Guidelines for Submission of Application for Services-Based Operations Licence — SBO individual and class categories, eligibility, duration
3. IMDA: Services-Based Operations (SBO) Licence — Licence page and template
4. Telecommunications Act 1999 — Licensing requirement and IMDA powers
5. GoBusiness Licensing — Class licence registration portal
6. Infocomm Media Development Authority — Regulator for telecommunications and media

General information only, current as at 20 October 2026. It is not legal advice and does not create a lawyer–client relationship. Singapore law and regulatory practice change; check current official sources and take advice on the facts of your matter.