Commentary · As enacted
Digital Infrastructure Bill introduced for First Reading in Parliament
The text
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DISCLAIMER: This update is intended for your general information only. It is not intended to be, nor should it be, regarded as or relied upon as legal advice. Court decisions referred to herein may be subject to further appeal at the time of publication, and subsequent developments in the law, including new legislation, amendments, court decisions or practice directions, may affect the accuracy or relevance of the matters discussed. We are under no duty to update this publication to reflect any such changes in the law. You should consult a qualified legal professional before taking any action or omitting to take action in relation to matters discussed herein.
WongPartnership LLP (UEN: T08LL0003B) is a limited liability law partnership registered in Singapore under the Limited Liability
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Digital Infrastructure Bill Introduced for First Reading in Parliament
On 8 September 2026, the Ministry of Digital Development and Information (MDDI) introduced the Digital
Infrastructure Bill (Bill) for first reading in Parliament.
The Bill was developed in collaboration with industry stakeholders, including major data centre (DC)
operators, Cloud Service Providers (CSPs), industry associations and enterprise users of digital infrastructure, and seeks to establish two new licensing regimes to strengthen:
(a)
The security and resilience of major DC Facility Services and Cloud Computing Services; and
(b)
The environmental sustainability of DC operations in Singapore.
The proposed regimes are intended to strengthen the foundations on which Singapore’s digital economy is built and provide regulatory clarity that supports long-term infrastructure investment in Singapore.
We set out below the key features of the Bill as highlighted in MDDI’s press release.
Key Features of the Bill
The Bill will establish two licensing regimes administered by the Infocomm Media Development Authority
(IMDA), as follows:
(a)
In relation to major co-location and cloud DCs and major CSPs: All (i) major co-location and cloud DCs with a critical IT load of at least 10 megawatts (MW), which are used to serve other parties unrelated to the operator of the DC; and (ii) major CSPs whose Infrastructure-as-a-Service (IaaS) and Platform-as-a-Service (PaaS) services generate at least S$100 million in average annual revenue from users in Singapore over the three preceding years, will be licensed. These thresholds are calibrated to cover the DCs and CSPs whose disruption would have a significant impact on Singapore’s economy and society. The Bill complements the
Cybersecurity Act 2018 (Cybersecurity Act), which sets out cybersecurity requirements for major foundational digital infrastructure, by covering a broader range of operational resilience risks, such as technical failures, power or cooling issues, fires and other physical or operational incidents, that can also disrupt the delivery of digital services. To manage these risks, licensees will be required to implement security risk management measures, business continuity and disaster recovery plans, and notify IMDA of specified cybersecurity incidents and service-delivery disruptions.
(b)
In relation to operators of DCs: All operators of DCs with a critical IT load of at least 3 MW will be licensed. As a first step, DCs will be required to meet facility-level energy-efficiency
Digital Infrastructure Bill
© WongPartnership LLP
DISCLAIMER: This update is intended for your general information only. It is not intended to be, nor should it be, regarded as or relied upon as legal advice. Court decisions referred to herein may be subject to further appeal at the time of publication, and subsequent developments in the law, including new legislation, amendments, court decisions or practice directions, may affect the accuracy or relevance of the matters discussed. We are under no duty to update this publication to reflect any such changes in the law. You should consult a qualified legal professional before taking any action or omitting to take action in relation to matters discussed herein.
WongPartnership LLP (UEN: T08LL0003B) is a limited liability law partnership registered in Singapore under the Limited Liability
Partnerships Act 2005.
requirements, including Power Usage Effectiveness (PUE) requirements. These requirements will apply to existing and new DCs. The framework will also allow further requirements, including those pertaining to IT equipment energy efficiency and facility-level water efficiency, to be introduced where necessary and following industry consultation. A DC operator that also provides a DC Facility Service falling within the first regime will be required to hold both licences, although IMDA intends to streamline the application process for applicants applying for both.
The Bill also provides a basis for enforcing, as licence conditions, the strategic, economic, and green energy commitments made in exchange for being awarded new DC capacity through exercises such as the Data Centre – Call for Application. This is to ensure that material commitments made in securing scarce capacity are accountable and create broader value for Singapore, given that Singapore’s DC capacity is supported by scarce natural resources, such as land and power.
Public Consultation and Industry Engagement
MDDI and IMDA conducted a public consultation on the draft Bill from 1 to 22 July 2026. For more on the public consultation, please see our update “Public Consultation on the Digital Infrastructure Bill”.
Respondents were supportive of the Bill’s policy objectives and provided feedback on the practical implementation of the licensing regimes and regulatory requirements. The feedback was taken into account in finalising the Bill, with adjustments made where appropriate. In implementing the Bill, MDDI and IMDA will seek to:
(a)
Streamline licensing and reporting processes and, where practicable, recognise existing industry standards and certifications;
(b)
Provide existing DCs with sufficient time to transition to the new regulatory requirements;
(c)
Streamline requirements under the Bill and the Cybersecurity Act; and
(d)
Continue engaging industry on the detailed requirements, transition arrangements and implementation of the regulatory framework.
In its closing note on the public consultation, MDDI and IMDA set out the following key adjustments and clarifications made following feedback, and the matters on which they will consult the industry further:
To address feedback that Cloud DCs are functionally different from Co-Location DCs, the Bill has drawn a distinction between the two in the definition of “data centre facility service”. MDDI and IMDA also intend to develop separate Codes of Practice for the security and resilience of
Cloud DCs and Co-Location DCs, subject to further consultations with the industry.
To address feedback that DC operators may not own or manage their customers’ IT equipment, mandatory IT equipment energy efficiency requirements will not be imposed at the outset. MDDI and IMDA will consult the industry before introducing any mandatory IT equipment energy efficiency requirements and will provide sufficient transition time.
© WongPartnership LLP
DISCLAIMER: This update is intended for your general information only. It is not intended to be, nor should it be, regarded as or relied upon as legal advice. Court decisions referred to herein may be subject to further appeal at the time of publication, and subsequent developments in the law, including new legislation, amendments, court decisions or practice directions, may affect the accuracy or relevance of the matters discussed. We are under no duty to update this publication to reflect any such changes in the law. You should consult a qualified legal professional before taking any action or omitting to take action in relation to matters discussed herein.
WongPartnership LLP (UEN: T08LL0003B) is a limited liability law partnership registered in Singapore under the Limited Liability
Partnerships Act 2005.
Where cybersecurity incident-reporting requirements under the Cybersecurity Act and the eventual Digital Infrastructure Act (DIA) are similar, licensees will report only to IMDA, which will share relevant information covered by the Cybersecurity Act with the Cyber Security
Agency of Singapore.
To address concerns that the six-month transition period may not provide enough time, MDDI and IMDA have clarified that the period is for the licence application process after the DIA (when passed) comes into effect, and an operator that applies within that period may continue through the licensing process until its licence is granted or its application is refused or withdrawn.
To address requests for clarification on the thresholds for determining whether an operator is covered, MDDI and IMDA will provide information on these implementation details ahead of the commencement of the licensing regimes, in consultation with affected service providers and operators, and will consider publishing these as part of licence application guidelines.
To minimise reporting and compliance burden, MDDI and IMDA will draw on international standards and industry best practices and, where possible, leverage existing industry-recognised audits and certifications for demonstration of compliance, and will continue consultations with industry before finalising the security and resilience requirements.
To address concerns about the transition time needed to meet the PUE requirements, IMDA will continue to work with DC operators and other affected stakeholders on the details, including implementation and transition timelines, before the requirements are finalised in subsequent regulations or Codes of Practice.
To ensure that any standards imposed are practical, MDDI and IMDA will coordinate with relevant government agencies and consult the industry before setting any water efficiency requirements.
Singapore’s Approach to Building Digital Infrastructure
MDDI set out in Annex A to its press release an overview of Singapore’s approach to building digital infrastructure. Among other things, the Singapore Government has worked with the industry over several years to strengthen the security, resilience and sustainability of Singapore’s digital infrastructure.
Measures taken include the following:
IMDA launched the Advisory Guidelines for Resilience and Security of Cloud Services and Data
Centres, which set out industry best practices for managing risks ranging from technical misconfigurations and physical hazards such as fires and cooling failures, to cyberattacks.
MDDI and IMDA have also worked with the industry to chart a sustainable growth pathway for the sector through initiatives such as the Green Data Centre (DC) Roadmap, the refreshed BCA-IMDA Green Mark for Data Centres Scheme, and standards covering IT energy efficiency, liquid cooling and tropical data centres. These measures draw from industry practices, international
© WongPartnership LLP
DISCLAIMER: This update is intended for your general information only. It is not intended to be, nor should it be, regarded as or relied upon as legal advice. Court decisions referred to herein may be subject to further appeal at the time of publication, and subsequent developments in the law, including new legislation, amendments, court decisions or practice directions, may affect the accuracy or relevance of the matters discussed. We are under no duty to update this publication to reflect any such changes in the law. You should consult a qualified legal professional before taking any action or omitting to take action in relation to matters discussed herein.
WongPartnership LLP (UEN: T08LL0003B) is a limited liability law partnership registered in Singapore under the Limited Liability
Partnerships Act 2005.
developments, and lessons from past incidents, and were shaped in extensive consultation with industry stakeholders.
As the risks digital infrastructure faces become more complex, and demand for compute grows against
Singapore’s resource constraints, a common statutory baseline is needed to ensure consistent outcomes across the sector, while retaining flexibility for detailed requirements to evolve as technology, risks, and industry practices change.
Against this background, the Bill intends to convert the earlier efforts to establish clear and enforceable baseline requirements for digital infrastructure of systemic importance.
The Bill is expected to be tabled for a Second Reading at the next available sitting of Parliament.
If you would like information and/or assistance on the above or any other area of law, you may wish to contact the Partner at WongPartnership whom you normally work with or any of the following Partners:
LAM Chung Nian
Head – Intellectual Property,
Technology & Data
Kylie PEH
Partner – Intellectual Property,
Technology & Data
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