Statute Details
- Title: Private Security Industry (Exemptions) Order 2025
- Act Code: PSIA2007-S573-2025
- Type: Subsidiary legislation (SL)
- Authorising Act: Private Security Industry Act 2007
- Enacting power: Section 37 of the Private Security Industry Act 2007
- Commencement: 1 September 2025
- Legislation status: Current version as at 27 Mar 2026
- Primary operative provisions: Sections 3 to 5 (exemptions) and Section 6 (excluded persons)
- Key definitions: “public agency” (Section 2)
- Legislative instrument number: SL 573/2025 (No. S 573)
- Made on: 29 August 2025
- Maker: Permanent Secretary, Ministry of Home Affairs
What Is This Legislation About?
The Private Security Industry (Exemptions) Order 2025 (“Exemptions Order”) is a Singapore subsidiary legislation made under the Private Security Industry Act 2007 (“PSIA”). Its central purpose is to carve out specific exemptions from certain licensing and regulatory requirements in the PSIA for particular categories of persons who perform private investigation functions in connection with work done for, or supplied to, public agencies.
In plain language, the Exemptions Order recognises that investigations and enforcement activities may be carried out by private investigators and related parties when they are appointed by, or provide services to, government bodies and other public sector entities. Rather than treating these arrangements as ordinary “private security industry” activity requiring the full suite of PSIA controls, the Order exempts defined persons from the relevant PSIA provisions—provided the work is carried out in the manner and for the purposes described in the Order.
The Order therefore operates as a targeted regulatory adjustment. It does not broadly deregulate the private security industry; instead, it limits exemptions to (i) private investigators appointed by a public agency, (ii) suppliers who provide private investigation services to a public agency for reward, and (iii) the employers of such private investigators. It also includes a “savings” style exclusion clause to ensure that the Order does not apply where the PSIA itself does not apply, or where earlier exemptions already cover the relevant persons.
What Are the Key Provisions?
1. Citation, commencement, and the operative framework
Section 1 provides the formal citation and commencement: the Order is the Private Security Industry (Exemptions) Order 2025 and comes into operation on 1 September 2025. This matters for practitioners because exemption status is time-sensitive: parties should ensure that their arrangements fall within the Order’s effective period.
2. Definition of “public agency” (Section 2)
Section 2 defines “public agency” for the purposes of the exemptions. It includes:
- a Ministry or department of the Government;
- an Organ of State; and
- a body corporate established by or under a public Act for the purposes of a public function.
This definition is crucial because the exemptions in Sections 3 to 5 depend entirely on whether the appointment or service is connected to a “public agency”. Practitioners should therefore map the counterparty entity’s legal status: whether it is a ministry/department, an organ of state, or a statutory body corporate performing a public function under a public Act.
3. Exemption for private investigators appointed by a public agency (Section 3)
Section 3 is the core exemption. It states that Section 6 of the PSIA does not apply to any person who carries out the functions of a private investigator (as defined in Section 5 of the PSIA) in the course of the person’s appointment under any written law or under an agreement or arrangement with a public agency.
The exemption is further limited by the purpose of the investigation/enforcement. The private investigator must conduct investigation or enforcement in connection with the discharge of either:
- any function of the public agency; or
- any function under any written law administered by the public agency.
Practical implications: This provision is designed for situations where a public agency engages an individual (or where the individual is appointed by law) to perform investigative or enforcement-related work. The exemption is not triggered merely because the investigator is “working with” a public body; it must be tied to the investigator’s appointment and to the discharge of the public agency’s functions or functions under written law.
4. Exemption for suppliers of private investigation services to a public agency (Section 4)
Section 4 addresses the supply side. It provides that Section 7 of the PSIA does not apply to any person who:
- supplies to a public agency, for reward; or
- advertises, or in any way holds out, to a public agency that the person supplies for reward, or is willing to supply for reward, the services of a private investigator for the purpose of an appointment mentioned in Section 3.
This is significant because PSIA provisions regulating “supply” and marketing/holding out can capture not only formal contracts but also promotional conduct. The exemption therefore extends to suppliers who actively market their willingness to provide private investigator services to public agencies, but only for the purpose of the Section 3 appointment framework.
5. Exemption for employers of such private investigators (Section 5)
Section 5 provides that Section 8 of the PSIA does not apply to the employer of any person mentioned in paragraph 3 (i.e., the private investigator carrying out functions under the Section 3 appointment). The employer is exempted where the private investigator carries out the functions in the manner described in Section 3.
Practical implications: This employer exemption is important for employment and compliance planning. Without it, an employer could face PSIA exposure merely because its employee performs investigative functions for a public agency under the relevant appointment. Section 5 reduces that risk, but again only within the Section 3 conditions (appointment and connection to the public agency’s functions or written-law functions).
6. Excluded persons / non-application clause (Section 6)
Section 6 clarifies the boundaries of the Order. It states that the Order does not apply to:
- any person to whom the PSIA does not apply by virtue of Section 3 of the PSIA; or
- any person exempted by paragraph 3(1)(a) or 4(a) of the Private Security Industry (Exemptions) Order 2009 (G.N. No. S 172/2009).
This clause serves two functions. First, it avoids redundancy: if the PSIA already does not apply to a person under its own scope provisions, the Exemptions Order should not be used to create confusion. Second, it preserves the effect of certain exemptions in the 2009 Order for specified categories, preventing overlap or unintended expansion.
How Is This Legislation Structured?
The Exemptions Order is short and structured as a set of targeted exemptions rather than a comprehensive regulatory code. It contains:
- Section 1 (Citation and commencement): establishes the instrument identity and effective date.
- Section 2 (Definition): defines “public agency”, which is the key trigger for all exemptions.
- Section 3 (Exemption of private investigators appointed by public agency): exempts the investigator from the relevant PSIA provision (Section 6 of the PSIA) when appointed under written law or agreement/arrangement and when conducting investigations/enforcement connected to the public agency’s functions or written-law functions.
- Section 4 (Exemption of suppliers): exempts persons supplying or holding out to supply private investigation services to a public agency for reward, again for the purpose of the Section 3 appointment.
- Section 5 (Exemption of employers): exempts the employer of the relevant private investigator, provided the investigator performs in the Section 3 manner.
- Section 6 (Excluded persons): limits the Order’s application where the PSIA does not apply or where earlier exemptions already cover the persons.
Who Does This Legislation Apply To?
The exemptions apply to three connected groups, but only in the context of work involving a “public agency” as defined in Section 2. First, it applies to private investigators performing investigative/enforcement functions in the course of an appointment under written law or under an agreement/arrangement with a public agency (Section 3). Second, it applies to suppliers who supply or hold out to supply private investigation services to a public agency for reward for the purpose of such appointments (Section 4). Third, it applies to the employers of those private investigators when the investigators carry out the functions in the Section 3 manner (Section 5).
However, Section 6 limits the Order’s reach. It does not apply to persons outside the PSIA’s scope under PSIA Section 3, and it does not apply to persons already exempted under specified provisions of the 2009 Exemptions Order. Practitioners should therefore conduct a two-step analysis: (1) whether the PSIA applies at all to the person, and (2) whether the person’s circumstances fall within the 2025 exemptions or within the preserved 2009 exemptions.
Why Is This Legislation Important?
This Exemptions Order is important because it affects compliance obligations and risk allocation in arrangements between public agencies and private investigation providers. In practice, public agencies may require investigative support for enforcement, compliance, or other statutory functions. The PSIA framework is designed to regulate the private security industry, but the Exemptions Order recognises that certain public-sector investigative engagements should not be treated identically to purely commercial private security work.
For lawyers advising public agencies, private investigation firms, or individual investigators, the Order provides a structured pathway to determine when PSIA provisions (Sections 6, 7, and 8 as referenced) do not apply. This can influence licensing requirements, contracting terms, internal compliance policies, and how parties document the basis of the appointment or supply arrangement.
From an enforcement perspective, the exemptions are conditional. The “public agency” definition and the “purpose” limitation (functions of the public agency or functions under written law administered by the public agency) are likely to be the focal points in any dispute about whether an exemption applies. Accordingly, practitioners should ensure that contracts, appointment instruments, and scope-of-work documents clearly reflect the statutory or functional connection to the public agency’s discharge of duties.
Related Legislation
- Private Security Industry Act 2007 (PSIA) — including Sections 5 (definition of private investigator), 6, 7, 8 (provisions referenced by the Exemptions Order), and Section 37 (authorising power for the Minister).
- Private Security Industry (Exemptions) Order 2009 (G.N. No. S 172/2009) — specifically paragraph 3(1)(a) and paragraph 4(a), which are preserved by Section 6(b) of the 2025 Order.
Source Documents
This article provides an overview of the Private Security Industry (Exemptions) Order 2025 for legal research and educational purposes. It does not constitute legal advice. Readers should consult the official text for authoritative provisions.