Statute Details
- Title: Parking Places (Exemption from Part 3) Order 2018
- Act Code: PPA1974-S283-2018
- Legislation Type: Subsidiary Legislation (SL)
- Authorising Act: Parking Places Act (Chapter 214)
- Enacting Authority: Minister for Transport
- Enacting Formula / Power Source: Section 21 of the Parking Places Act
- Commencement: 8 May 2018
- SL Number: S 283/2018
- Status: Current version as at 27 Mar 2026
- Key Provisions: Section 1 (Citation and commencement); Section 2 (Exemption)
What Is This Legislation About?
The Parking Places (Exemption from Part 3) Order 2018 is a short but legally significant instrument. It operates as an exemption order made under the Parking Places Act (Chapter 214). In plain language, it tells you that certain persons are not required to comply with the requirements found in Part 3 of the Act, provided they meet a specific condition.
At its core, the Order addresses a compliance question: what happens when a person’s activities fall within a category of “licensable activity” but the person does not carry out the broader set of activities that would normally trigger Part 3 obligations. The Order answers that question by carving out a limited exemption for persons who only carry out a particular type of licensable activity.
Because the Order is tied to a reference in section 8(3)(b) of the Parking Places Act, its practical effect depends on how that provision defines the relevant “licensable activity.” Accordingly, practitioners should read this Order together with the Parking Places Act—especially the provisions that describe licensable activities and the obligations contained in Part 3.
What Are the Key Provisions?
Section 1 (Citation and commencement) is straightforward. It provides the legal name of the instrument and states that it comes into operation on 8 May 2018. For practitioners, this matters for determining whether the exemption applies to conduct occurring on or after that date, and for assessing any regulatory or enforcement actions taken before commencement.
Section 2 (Exemption) is the operative provision. It states that the Minister exempts from Part 3 of the Act a person who only carries out a licensable activity described in section 8(3)(b) of the Parking Places Act.
This wording contains several important legal elements:
- Exemption is from “Part 3 of the Act”: the person is relieved from the requirements, prohibitions, or regulatory framework contained in Part 3. The exact nature of those obligations will be found in the Parking Places Act’s Part 3 provisions.
- Exemption applies to “a person”: the exemption is not limited to a particular corporate form or industry label in the Order itself. It is framed broadly, but the person must meet the activity condition.
- Condition is strict: “only carries out”: the exemption is limited to persons whose activities are confined to the specified licensable activity. If the person carries out additional activities beyond what is described in section 8(3)(b), the exemption may not apply.
- Activity must be within section 8(3)(b): the Order does not define the licensable activity itself. Instead, it incorporates by reference the description in the Act. This is a classic legislative drafting technique that ensures the exemption tracks the Act’s definitions.
Practical compliance implication: The “only” requirement means that a mixed-activity operator may need to consider whether its other activities trigger Part 3 obligations. In enforcement or licensing contexts, regulators often scrutinise whether an operator’s actual operations match the scope of an exemption. Therefore, practitioners should advise clients to document the nature of their activities and ensure that any ancillary or overlapping activities do not fall outside the section 8(3)(b) category.
Although the extract provided does not reproduce the text of section 8(3)(b) or Part 3, the structure of the Order indicates that it is designed to provide regulatory relief to a narrower class of operators. Typically, Part 3 of such an Act would contain licensing, permit, or operational requirements—possibly including obligations relating to the management of parking places, compliance with conditions, reporting, or other regulatory controls. The exemption order therefore functions as a targeted carve-out rather than a wholesale repeal or amendment of the Act.
How Is This Legislation Structured?
The Order is structured in a minimal, two-section format:
- Section 1 (Citation and commencement): identifies the instrument and its effective date (8 May 2018).
- Section 2 (Exemption): sets out the exemption from Part 3 for persons who only carry out the specified licensable activity described in section 8(3)(b) of the Parking Places Act.
There are no schedules, definitions sections, or additional procedural provisions in the extract. As a result, the legal work for practitioners is largely interpretive: understanding the scope of “Part 3” and the meaning of “licensable activity described in section 8(3)(b).” The Order’s brevity increases the importance of reading the referenced provisions in the parent Act.
Who Does This Legislation Apply To?
The exemption applies to “a person”—which, in regulatory legislation, generally means any legal or natural person within the Act’s definitional framework. However, the exemption is conditional. It applies only where the person only carries out a licensable activity described in section 8(3)(b) of the Parking Places Act.
Accordingly, the Order is not a general exemption for all parking-related businesses. It is a narrow exemption for a specific category of licensable activity. Practitioners should therefore assess:
- whether the client’s activities fall within the precise description of section 8(3)(b);
- whether the client carries out any other licensable activities or related activities that might bring it outside the “only” limitation;
- whether the client’s activities are performed in a manner that is consistent with the licensing framework of the Act.
Because the Order exempts from Part 3, it is also relevant to determine what Part 3 requires. If Part 3 contains licensing or operational conditions, the exemption may reduce regulatory burdens for qualifying persons. Conversely, if Part 3 includes enforcement mechanisms, the exemption could affect how compliance is monitored.
Why Is This Legislation Important?
Even though the Parking Places (Exemption from Part 3) Order 2018 is brief, it can have significant consequences for regulatory compliance and risk management. Exemptions are often relied upon by operators to determine whether they must obtain licences, comply with conditions, or meet administrative requirements. A misinterpretation of the exemption’s scope can lead to enforcement exposure, including potential penalties or the need to regularise compliance.
The Order is also important because it demonstrates how Singapore’s regulatory framework uses subsidiary legislation to fine-tune the operation of a parent statute. Rather than amending the Parking Places Act directly, the Minister uses powers under section 21 to create a targeted exemption. This approach allows the regulatory system to adapt to practical industry needs—such as distinguishing between different types of licensable activities and calibrating the level of regulatory oversight.
From a practitioner’s perspective, the most critical feature is the “only carries out” condition. This creates a factual and legal boundary. Clients should be advised to conduct an activity mapping exercise: identify each activity they perform, classify it against the licensable activity categories in section 8(3)(b), and confirm that no other activities are carried out that would defeat the exemption. Where uncertainty exists, legal advice should be sought on whether the exemption applies and whether alternative compliance steps are required.
Finally, the commencement date (8 May 2018) is relevant for transitional compliance. If an operator began activities before the commencement date, the exemption would not have been available for that earlier period. Practitioners should therefore consider timelines when assessing historical compliance and any regulatory correspondence.
Related Legislation
- Parking Places Act (Chapter 214) — in particular:
- Section 21 (power to make exemption orders)
- Section 8(3)(b) (description of the relevant licensable activity)
- Part 3 (the provisions from which the exemption applies)
- Parking Places (Exemption from Part 3) Order 2018 — SL 283/2018 (this instrument)
Source Documents
This article provides an overview of the Parking Places (Exemption from Part 3) Order 2018 for legal research and educational purposes. It does not constitute legal advice. Readers should consult the official text for authoritative provisions.