Statute Details
- Title: Air Navigation (Voluntary Reporting) Rules 2020
- Act Code: ANA1966-S592-2020
- Type: Subsidiary Legislation (SL)
- Authorising Act: Air Navigation Act (Cap. 6)
- Enacting Power: Made under section 12A of the Air Navigation Act
- Commencement: 27 July 2020
- Current Version: Current version as at 26 March 2026
- Key Amendments Noted in Extract: Amended by S 680/2024 (effective 31 December 2021)
- Parts: Part 1 (Preliminary), Part 2 (Designated Person), Part 3 (Reporting), Part 4 (Accepting and Dealing with Reports), Part 5 (Use and Disclosure of Reports)
- Extracted Key Definitions: “Tell Sarah database”, “Tell Sarah scheme”, “protected information”, “report”, “reporter”
What Is This Legislation About?
The Air Navigation (Voluntary Reporting) Rules 2020 establish a structured, voluntary, and confidential reporting framework for aviation safety matters in Singapore. In practical terms, the Rules create a “safe channel” through which individuals and organisations can report safety concerns without the report being treated as a conventional complaint or enforcement trigger. The overarching goal is to encourage early disclosure of safety issues so that systemic deficiencies can be identified and addressed.
The Rules are made under the Air Navigation Act, specifically to support the statutory purpose of enabling voluntary reporting for aviation safety. The scheme is designed to be confidential and to limit the use of reported information. Rather than being used to apportion blame, the scheme is intended to facilitate safety action and awareness by the aviation regulator (the “Authority”), and to drive improvements in aviation safety.
In the extract provided, the scheme is expressly named the “Tell Sarah scheme”, supported by a “Tell Sarah database” maintained by a “designated person”. The Rules also define “protected information” by reference to section 45 of the Air Navigation Act, signalling that the confidentiality and handling of information are central to the legislative design.
What Are the Key Provisions?
1. Citation, commencement, and definitions (Rules 1–2)
Rule 1 confirms that the Rules are the Air Navigation (Voluntary Reporting) Rules 2020 and that they come into operation on 27 July 2020. Rule 2 then sets out key definitions that govern how the scheme operates. For practitioners, the definitions are important because they determine (i) what counts as a “report”, (ii) who is responsible for receiving and recording reports, and (iii) what information is treated as protected.
Notably, Rule 2 defines “appropriate form” as the relevant form provided by the designated person and published on a specified website (https://www.tellsarah-vrs.com/). This indicates that the reporting mechanism is operationalised through prescribed forms, likely to standardise submissions and ensure consistent categorisation of aviation safety matters.
2. Establishment of the Tell Sarah scheme (Rule 3)
Rule 3 is the core “purpose and architecture” provision. It establishes, for the purpose of section 46 of the Air Navigation Act, the “Tell Sarah scheme” for the voluntary and confidential reporting of any aviation safety matter. The Rule also sets out the scheme’s purposes:
- Provide a voluntary and confidential reporting scheme for aviation safety matters.
- Identify deficiencies and problems arising out of such reports.
- Give information to only the Authority about an identified aviation safety matter to facilitate:
- action and awareness about aviation safety; and
- improvements in aviation safety.
From a legal perspective, Rule 3(2)(c) is particularly significant: it frames the information flow as restricted—information is to be given to “only the Authority”. This supports the confidentiality rationale and helps limit secondary uses by other parties. It also suggests that the scheme is not intended to function as a general reporting channel for private disputes or disciplinary processes.
3. Designated person and its role (Rules 4–5)
While the extract does not reproduce Rules 4 and 5, the table of contents indicates that Part 2 deals with the “designated person” and its functions. The definitions in Rule 2 refer to a “Tell Sarah database” established and maintained by a designated person for recording information contained in reports. This implies that the designated person is the operational gatekeeper who receives reports (or at least manages the reporting interface), records them in the database, and likely ensures that submissions are handled in accordance with the confidentiality and protected-information rules.
For practitioners advising aviation stakeholders, the designated person’s functions are critical because they determine where confidentiality obligations attach, what procedural steps must be followed when submitting a report, and how the scheme interfaces with the Authority.
4. Reporting: what can be reported, and what is excluded (Rules 6–8)
Part 3 is titled “Reporting” and includes Rules 6 (aviation safety matter), 7 (excluded information and not aviation safety matter), and 8 (reporting). Even though the extract does not provide the text of these provisions, their headings show that the scheme is not open-ended. It likely distinguishes between:
- matters that qualify as “aviation safety matters” (eligible for the scheme);
- information that is excluded or does not qualify as an aviation safety matter; and
- the procedural requirements for making a report (Rule 8).
This distinction matters because the legal protections associated with voluntary reporting typically depend on whether the submission falls within the statutory definition and scope. If a report contains excluded content, it may not receive the same confidentiality treatment or may be handled differently.
5. Accepting and dealing with reports; false or misleading information (Rules 9–12)
Part 4 addresses the Authority’s and/or designated person’s handling of reports. It includes provisions on accepting a report (Rule 9), dealing with a report (Rule 10), handling reports with false or misleading information (Rule 11), and handling information about offences (Rule 12).
For legal practitioners, these provisions are essential because they balance confidentiality with accountability. Voluntary reporting schemes often provide protections to encourage candour, but they usually include safeguards against abuse. Rule 11’s heading indicates that false or misleading information is not protected in the same way as genuine safety disclosures. Rule 12’s heading suggests that where a report contains information about offences, the scheme may require disclosure or other handling steps consistent with criminal or regulatory enforcement.
6. Use and disclosure of reports; compliance by third parties; saving (Rules 13–16)
Part 5 governs how reports can be used and disclosed. It includes:
- Rule 13: “Competent authority” (identifying who can act on reports);
- Rule 14: “Disclosure of information in reports” (setting limits and conditions);
- Rule 15: “Compliance by third party with disclosed information” (imposing obligations on recipients);
- Rule 16: “Saving” (preserving other legal rights/obligations or clarifying that the Rules do not override certain regimes).
These provisions are the legal backbone of confidentiality. In practice, they determine whether the Authority can share information with other agencies, whether third parties can be informed, and what restrictions apply to recipients. Rule 15 is particularly relevant where the Authority discloses information to a third party (for example, an aviation operator or safety investigator) and must ensure that confidentiality and handling requirements continue downstream.
How Is This Legislation Structured?
The Rules are structured into five parts, moving from foundational concepts to operational reporting and finally to information governance:
- Part 1 (Preliminary): Citation and commencement (Rule 1), definitions (Rule 2), and establishment of the Tell Sarah scheme (Rule 3).
- Part 2 (Designated Person): Establishes who the designated person is (Rule 4) and sets out its functions (Rule 5), including likely administration of the reporting interface and the Tell Sarah database.
- Part 3 (Reporting): Defines what qualifies as an aviation safety matter (Rule 6), what is excluded (Rule 7), and how reporting is to be done (Rule 8).
- Part 4 (Accepting and Dealing with Reports): Covers acceptance and handling of reports (Rules 9–10), and addresses integrity and enforcement interfaces through Rules 11–12.
- Part 5 (Use and Disclosure of Reports): Sets out the competent authority (Rule 13), disclosure rules (Rule 14), third-party compliance (Rule 15), and a saving provision (Rule 16).
Who Does This Legislation Apply To?
The Rules apply to persons who make voluntary reports of aviation safety matters under the Tell Sarah scheme, and to the designated person responsible for administering the scheme and maintaining the Tell Sarah database. They also apply to the competent authority/Authority that accepts, deals with, and potentially discloses information contained in reports.
Although the extract does not specify every category of “reporter” or “aviation safety matter” stakeholder, the scheme is clearly intended to be accessible to individuals who have information about safety deficiencies. At the same time, the Rules are carefully bounded: excluded information and not-aviation-safety matters are carved out, and reports containing false or misleading information or information about offences are subject to special handling.
Why Is This Legislation Important?
The Air Navigation (Voluntary Reporting) Rules 2020 are important because they operationalise a safety culture approach: encouraging reporting of safety issues without turning every disclosure into an adversarial process. By establishing a voluntary and confidential scheme and restricting information flow to the Authority, the Rules aim to improve aviation safety outcomes through learning and systemic improvement.
For practitioners, the Rules also have direct compliance and risk implications. Aviation organisations and individuals need to understand what can be reported, how to submit reports using the appropriate forms, and how confidentiality and protected-information rules may affect internal investigations, regulatory engagement, and potential enforcement exposure. The presence of provisions addressing false or misleading information and offences indicates that the scheme is not a shield for misconduct; rather, it is a structured mechanism for responsible disclosure.
Finally, the information governance provisions in Part 5—particularly disclosure limits and third-party compliance—matter for legal strategy. Where reports are shared with other parties, the Rules likely impose conditions that affect admissibility, confidentiality obligations, and the permissible scope of use. Lawyers advising aviation clients should therefore treat the scheme as both a safety tool and a legal framework governing sensitive information.
Related Legislation
- Air Navigation Act (Cap. 6) — in particular, provisions referenced in the Rules (including sections 12A, 46, and 45 as referenced in the definitions of “protected information” and the establishment of the Tell Sarah scheme).
- Legislation Timeline / Amendments — including S 680/2024 (effective 31 December 2021) which amended key definitions and scheme-related provisions.
Source Documents
This article provides an overview of the Air Navigation (Voluntary Reporting) Rules 2020 for legal research and educational purposes. It does not constitute legal advice. Readers should consult the official text for authoritative provisions.