Statute Details
- Title: COVID-19 (Temporary Measures) (Temporary Measures for Conduct of Collective Sale of Property) Order 2020
- Act Code: COVID19TMA2020-S870-2020
- Type: Subsidiary Legislation (SL)
- Authorising Act: COVID-19 (Temporary Measures) Act 2020 (section 40)
- Commencement: 6 October 2020
- Current version status: Current version as at 27 March 2026 (per provided extract)
- Key purpose: Enables modified application of certain Land Titles (Strata) Act (LTSA) collective sale requirements where COVID-19 has prevented or made compliance impracticable
- Key sections (from extract): Sections 1–9; Schedule (modifications to LTSA Schedule provisions)
- Notable procedural deadlines: Application deadline: 25 March 2021; service/objection timelines: 10 working days at multiple stages
What Is This Legislation About?
The COVID-19 (Temporary Measures) (Temporary Measures for Conduct of Collective Sale of Property) Order 2020 (“the Order”) is a Singapore legal instrument made under the COVID-19 (Temporary Measures) Act 2020. In practical terms, it addresses a specific problem created by the pandemic: collective sales of strata and related property under the Land Titles (Strata) Act (Cap. 158) (“LTSA”) often depend on strict statutory steps and timelines. COVID-19 disruptions could make it difficult or impossible to satisfy certain LTSA requirements—especially those tied to notices, committee processes, and other procedural conditions.
The Order therefore creates a mechanism for affected parties to apply to the Minister for Law for permission to apply certain LTSA Schedule provisions “with modifications”. In other words, rather than abandoning collective sale processes entirely, the law provides a controlled pathway to continue them while adjusting specified requirements to account for COVID-19-related impracticability.
Importantly, the Order is not a blanket suspension of collective sale rules. It is targeted and conditional. It applies only where the statutory requirement in the LTSA Schedule (as set out opposite the relevant person in the Schedule to the LTSA) was not satisfied (whether before, on or after 6 October 2020) or is unlikely to be satisfied due to the COVID-19 event. The Minister’s approval is required, and procedural safeguards (service, objection, and notification) are built in.
What Are the Key Provisions?
1. Definitions and scope of “affected party” and “applicant” (Section 2)
Section 2 defines key terms that determine who can apply and who must be notified. The “applicant” is the person who makes an application under paragraph 4(1). The “affected party” is broadly defined to include multiple stakeholders in a collective sale context, including:
- subsidiary proprietors of lots in a strata title plan (under specified LTSA provisions);
- proprietors of flats in the development;
- mortgagees/chargees and other persons with notified interests;
- proprietors of land under the relevant LTSA provisions;
- subsidiary proprietors in reversion of leasehold estates;
- mortgagees/chargees with interests notified on the relevant registers; and
- the management corporation.
This definition matters because the Order imposes service and objection rights on affected parties. It also reflects that collective sale processes can affect not only owners but also secured creditors and other registered interest holders.
2. Modified LTSA Schedule provisions for COVID-19 affected collective sales (Section 3 and the Schedule)
The core substantive mechanism is in Section 3. Section 3(1) provides that an application may be made to the Minister by a person specified in the first column of the Order Schedule, in a case mentioned in section 40(2) of the COVID-19 (Temporary Measures) Act 2020.
Section 3(1) further requires that a requirement of an LTSA Schedule set out opposite that person in the second column of the Order Schedule was not satisfied (whether before, on or after 6 October 2020) or is unlikely to be satisfied for the reason in section 40(2)(c) of the Act. Section 3(2) clarifies the purpose: to apply the LTSA Schedule provision to that case with the modifications set out opposite that person in the third column of the Order Schedule. Section 3(3) then states the consequence: if the Minister approves, the modified LTSA Schedule provisions apply.
For practitioners, the Schedule is crucial. It effectively maps (i) who may apply, (ii) which LTSA Schedule requirement is implicated, and (iii) what modification is permitted. The Order is therefore best read together with the LTSA Schedule provisions it modifies. The legal effect is not to rewrite the LTSA generally, but to permit targeted deviations from specified requirements.
3. Application requirements and strict procedural compliance (Section 4)
Section 4 sets out the application process and key compliance steps.
Deadline: Under Section 4(1), the application must be made no later than 25 March 2021. This is a hard deadline; late applications would likely be rejected as not made in accordance with paragraph 4.
Form and content: Section 4(2) requires the application to be made in Form A1 and to specify:
- the date the collective sale committee (subject of the application) is constituted for the purposes of a collective sale under Part VA of the LTSA;
- the LTSA Schedule requirement that was not satisfied or is unlikely to be satisfied; and
- a brief explanation of why it was or will be inexpedient or impracticable to carry out any act necessary for the requirement to be satisfied in view of a COVID-19 event.
Manner of filing: Section 4(3) requires the application to be made in the manner required by the Minister. This is a reminder that procedural directions (e.g., submission method, supporting documents, or online filing requirements) can be decisive.
Service on affected parties: Section 4(4) requires the applicant, within 10 working days after the application date, to serve on every affected party:
- a copy of the application; and
- Form A2, which is the form for making an objection.
Public notice / affixing requirement: Section 4(5) requires the applicant to affix a copy of the application to a conspicuous part of each building comprised in the strata title plan or the development.
Consequence of non-compliance: Section 4(6) provides that if the applicant fails to satisfy the Minister that the applicant has complied with Sections 4(4) and (5), the Minister must reject the application. This is a mandatory rejection trigger, underscoring that service and notice are not optional formalities.
4. Objection and Ministerial determination (Sections 5–7)
Section 5 gives affected parties a right to object. An affected party may, no later than 10 working days after being served with the application and Form A2, submit an objection to the Minister in Form A2 and serve a copy of the objection on the applicant.
Section 6 governs the Minister’s approach. Under Section 6(1), the Minister may refuse to consider an application if it is incomplete, not accompanied by documents specified in the form or by the Minister, or not made in accordance with paragraph 4. Under Section 6(2), the Minister may either approve or reject after considering the application and objections (if any).
Section 7 then sets out notification mechanics. The Minister must notify the applicant “as soon as practicable” after deciding. The applicant must then, within 10 working days after receiving notice, serve a notice of the outcome on every affected party and affix a copy on conspicuous parts of the relevant buildings (Section 7(2)–(3)).
5. Forms and service of documents (Sections 8–9)
Section 8 provides that the forms used are those set out on the MLAW website, and references to numbered forms refer to the current version displayed online. It also allows variations to be made to forms depending on circumstances, while requiring that forms contain specified particulars, comply with requirements, and be accompanied by specified documents.
Section 9 addresses service of documents in connection with an application. Service may be effected by personal delivery, prepaid registered post to an “appropriate address”, or sending to the person’s last email address. Section 9(2) specifies what constitutes an appropriate address depending on the category of affected party (e.g., strata roll address for subsidiary proprietors; last recorded address at the Land Titles Registry or Registry of Deeds for proprietors; and land-register notified addresses for mortgagees/chargees and other interest holders). For practitioners, this is a key evidential issue: correct service under Section 9 is likely to be scrutinised in any dispute about procedural fairness.
How Is This Legislation Structured?
The Order is structured as a short procedural instrument with a substantive “modification” core:
- Section 1 sets citation and commencement (6 October 2020).
- Section 2 provides definitions, including “affected party”, “applicant”, and key LTSA terms.
- Section 3 explains the modified application of LTSA Schedule provisions and links the mechanism to the COVID-19 (Temporary Measures) Act 2020.
- Sections 4–7 set out the application process: requirements, service, objection, determination, and notification.
- Section 8 addresses forms and how they are updated via the MLAW website.
- Section 9 sets out permitted methods and addresses for service of documents.
- The Schedule contains the mapping of persons and the specific LTSA Schedule requirements that may be modified, including the modifications themselves.
Who Does This Legislation Apply To?
The Order applies to persons who are specified in the first column of the Order Schedule and who seek relief in cases falling within section 40(2) of the COVID-19 (Temporary Measures) Act 2020. In practice, this will typically involve stakeholders in collective sale processes under Part VA of the LTSA—such as collective sale committee-related applicants and other persons authorised by the Order Schedule.
It also applies to a wider set of stakeholders as “affected parties”. Affected parties must be served with the application and outcome, and they have a statutory objection window. This includes subsidiary proprietors, flat proprietors, land proprietors, mortgagees/chargees, other notified interest holders, and the management corporation. The inclusion of mortgagees/chargees and other registered interest holders is particularly important for practitioners advising secured lenders or parties with registered charges.
Why Is This Legislation Important?
From a practitioner’s perspective, the Order is important because it provides a legally recognised pathway to continue collective sale processes despite COVID-19-related non-compliance with certain LTSA Schedule requirements. Without such relief, strict procedural requirements could have invalidated steps or prevented applications from proceeding. The Order mitigates that risk by allowing the Minister to approve modified application of specified LTSA Schedule provisions.
Equally important are the procedural safeguards. The Order requires timely service on affected parties, provides a defined objection period, and mandates notification and public affixing. These requirements protect due process and transparency in collective sale matters, where outcomes can materially affect owners and secured creditors.
Finally, the Order’s deadlines and mandatory rejection triggers mean that compliance must be managed carefully. The application deadline (25 March 2021), the 10-working-day service and objection periods, and the mandatory rejection if service/affixing is not proven are all points where legal teams should ensure meticulous documentation and evidence of compliance (e.g., proof of registered post, email delivery records, and photographs or affidavits regarding affixing to conspicuous parts of buildings).
Related Legislation
- COVID-19 (Temporary Measures) Act 2020 (particularly section 40)
- Land Titles (Strata) Act (Cap. 158) (“LTSA”), including Part VA (collective sale) and the LTSA Schedule provisions referenced in the Order
- LTSA Schedule (as modified by the Order’s Schedule)
Source Documents
This article provides an overview of the COVID-19 (Temporary Measures) (Temporary Measures for Conduct of Collective Sale of Property) Order 2020 for legal research and educational purposes. It does not constitute legal advice. Readers should consult the official text for authoritative provisions.