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Electricity (Prescribed Generation Entities) Regulations 2025

Overview of the Electricity (Prescribed Generation Entities) Regulations 2025, Singapore sl.

Statute Details

  • Title: Electricity (Prescribed Generation Entities) Regulations 2025
  • Act Code: EA2001-S566-2025
  • Legislation Type: Subsidiary Legislation (SL)
  • Authorising Act: Electricity Act 2001
  • Enacting Authority: Energy Market Authority of Singapore (EMA), with Ministerial approval
  • Legal Basis: Made under section 103 of the Electricity Act 2001
  • Commencement: 1 September 2025
  • Key Provisions:
    • Section 2: Definitions
    • Section 3: Prescribes entities listed in the Schedule as “prescribed generation entities” (PGEs) for Part 5B of the Act
    • Section 4: Sets minimum gas procurement amounts for each PGE across each 10-year forward period, including how quantities are calculated and allocated
  • Schedule: “Prescribed generation entities” (entities specified by name)

What Is This Legislation About?

The Electricity (Prescribed Generation Entities) Regulations 2025 (“PGE Regulations”) are subsidiary legislation made under the Electricity Act 2001 to operationalise Part 5B of the Act. In practical terms, the Regulations identify specific electricity generation companies (the entities named in the Schedule) as “prescribed generation entities” or “PGEs”, and then impose a structured requirement on those PGEs to secure gas supply over long planning horizons.

The core policy objective is to ensure that Singapore’s electricity generation system—particularly gas-driven generation—has a predictable and bankable level of gas procurement. The Regulations do this by requiring each PGE, through its gas supply contract with the gas importer (Gasco), to include terms obligating the PGE to obtain gas from Gasco for each year in a 10-year forward period, subject to a formula that reflects projected electricity demand and the PGE’s expected share of gas-driven generation.

Although the Regulations are technical, they are commercially significant: they determine minimum gas quantities that a PGE must contract for, and they also create a mechanism for the Energy Market Authority (EMA) to allocate and (in limited circumstances) revise those quantities when new circumstances arise.

What Are the Key Provisions?

1. Prescribing which entities are PGEs (Section 3 and the Schedule). Section 3 provides that each entity specified in the Schedule is prescribed for the purposes of Part 5B of the Electricity Act 2001 as a “prescribed generation entity”. This is the gateway provision: only entities named in the Schedule are subject to the gas minimums and allocation regime in the Regulations.

2. Defining the planning horizon and key concepts (Section 2). The Regulations introduce several definitions that drive the calculation in Section 4. The “10-year forward period” is defined as a period of 10 years beginning with a first period that starts on 1 January 2028, and then each subsequent 10-year period begins on 1 January of every even-numbered year. This matters because the minimum gas obligations are calculated and allocated on a year-by-year basis within each 10-year period.

The Regulations also define “Gas Demand Forecast” (GDF) as the total quantity of gas EMA projects will be required for electricity generation by all PGEs to meet projected electricity demand in Singapore for a given year. Further, “gas driven generating unit” is a generating unit that uses gas for electricity generation. These definitions ensure that the minimum gas formula is anchored to system-level forecasts rather than purely contractual assumptions.

3. The minimum gas procurement formula (Section 4(1) and Section 4(2)). Section 4 is the heart of the Regulations. For every 10-year forward period, a PGE must, in its contract with Gasco, include a term requiring the PGE to obtain gas from Gasco for the 10-year forward period of an amount not less than a calculated figure for each year.

The minimum amount for each year is expressed as: (A × B × C) − D.

  • A is the GDF for that year (EMA’s forecast of total gas needed for electricity generation by all PGEs).
  • B is a time-weighting factor that declines across the 10-year period:
    • 80% if the year is the first or second year;
    • 60% if the year is the third or fourth;
    • 45% if the year is the fifth or sixth;
    • 30% if the year is the seventh or eighth;
    • 15% if the year is the ninth or tenth.
  • C is the percentage of expected total electricity generation by all PGEs for that year that may be attributed to the specified PGE’s gas-driven generating units.
  • D is the amount of gas for which the specified PGE has already contracted for that year under specified contracts entered into pursuant to section 41I(1) and section 41I(2) of the Act.

Negative amounts are treated as zero (Section 4(4)). If the formula yields a negative number for any year, the minimum amount is treated as zero. This is a practical safeguard: it prevents the minimum obligation from becoming counterintuitive where the PGE has already contracted for more gas than the formula would otherwise require.

4. How EMA determines the PGE’s share (C) using an economic dispatch model (Section 4(3)). The Regulations require EMA to determine C using an economic dispatch model. EMA must simulate expected total electricity generation by all PGEs for the relevant year and then attribute a percentage of that expected generation to the specified PGE’s gas-driven generating units. The attribution is based on the respective capacities and efficiencies of the gas-driven generating units of all PGEs.

This is important for practitioners because it signals that the allocation is not a simple contractual or historical allocation. Instead, it is model-based and grounded in operational performance characteristics (capacity and efficiency), which may change over time due to plant upgrades, retirements, or efficiency improvements.

5. Notification and revision of allocated quantities (Sections 4(5) and 4(6)). EMA must notify each PGE in writing of its allocated quantities for each year in the 10-year forward period no later than 18 months before the start of that period. This provides lead time for contracting and risk management.

However, Section 4(6) allows EMA to change any allocated quantity earlier notified if new circumstances arise that necessitate the change. EMA must then immediately notify the PGE in writing of the change. The “new circumstances” trigger is not defined in the extract, but the structure implies an administrative power to respond to material changes in forecasts, system conditions, or modelling inputs.

6. Contractual “modification” terms must be included (Section 4(7)). Finally, the Regulations require that each specified PGE’s contract with Gasco for the 10-year forward period include a term stating that the allocated quantity for any year is to be modified to take into account any change made by EMA. This ensures that the regulatory allocation is not merely informational; it is contractually enforceable and adaptable.

How Is This Legislation Structured?

The PGE Regulations are structured as a short instrument with a clear hierarchy:

(i) Enacting formula and commencement (Regulation 1) set the legal basis and effective date (1 September 2025).

(ii) Definitions (Regulation 2) provide the technical terms used in the calculation and allocation framework, including the 10-year forward period, GDF, and the meaning of PGE.

(iii) Prescribed generation entities (Regulation 3) identifies the regulated entities by reference to the Schedule.

(iv) Minimum amounts of gas (Regulation 4) establishes the minimum gas procurement obligation, the formula for calculating it, the method for determining the PGE’s share (C), and the administrative allocation and revision process.

(v) The Schedule lists the entities that are prescribed as PGEs.

Who Does This Legislation Apply To?

The Regulations apply to each entity specified in the Schedule as a prescribed generation entity for the purposes of Part 5B of the Electricity Act 2001. In other words, the regulated “PGE” population is fixed by the Schedule rather than by a broad activity-based definition.

In addition, the Regulations operate through the contracting relationship between each PGE and Gasco, defined as the holder of a gas importer’s licence (central import) under the Gas Act 2001. While the Regulations impose obligations on the PGE to include specific terms in its contract with Gasco, the practical effect is that Gasco’s contracting framework must accommodate the regulatory allocation and modification mechanism.

Why Is This Legislation Important?

For practitioners, the significance of the PGE Regulations lies in how they translate system planning into enforceable contracting requirements. The minimum gas procurement obligation is not discretionary: it is anchored to EMA’s forecasts (GDF), a time-weighting factor (B), and a model-based attribution of generation share (C), with an offset for already-contracted quantities (D). This creates a structured compliance framework that affects long-term procurement strategy, financing assumptions, and risk allocation.

The Regulations also matter because they embed an administrative allocation process with revision powers. EMA must notify allocated quantities at least 18 months before the start of each 10-year forward period, but it may revise allocations if new circumstances arise. This means that contracts must be drafted to anticipate regulatory change—hence the mandatory contractual modification clause in Section 4(7).

Finally, the use of an economic dispatch model to determine C indicates that compliance and disputes may turn on modelling inputs and assumptions (such as unit capacities and efficiencies). Lawyers advising PGEs should therefore pay close attention to how those inputs are established, updated, and reflected in the allocation outcome, and how the PGE’s existing contracts under section 41I are measured for the D offset.

  • Electricity Act 2001 (including Part 5B and sections 41G and 41I, and the regulation-making power in section 103)
  • Gas Act 2001 (definition and licensing framework for Gasco as a gas importer’s licence (central import) holder)

Source Documents

This article provides an overview of the Electricity (Prescribed Generation Entities) Regulations 2025 for legal research and educational purposes. It does not constitute legal advice. Readers should consult the official text for authoritative provisions.

Written by Sushant Shukla

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