Statute Details
- Title: Residential Property (GLG Properties Pte. Ltd. — Exemption) Notification 2021
- Act Code: RPA1976-S603-2021
- Type: Subsidiary Legislation (Notification)
- Authorising Act: Residential Property Act (Cap. 274), specifically section 32(1)
- Notification Number: S 603/2021
- Date Made: 11 August 2021
- Commencement: 13 August 2021
- Status: Current version as at 27 March 2026
- Key Provisions: Sections 1 to 6; exemptions from approvals under sections 9, 28, 28A, and 31 of the Residential Property Act; conditions in the Schedule
- Entity Benefiting from Exemption: GLG Properties Pte. Ltd. (the “relevant company”)
What Is This Legislation About?
The Residential Property (GLG Properties Pte. Ltd. — Exemption) Notification 2021 is a targeted exemption instrument made under the Residential Property Act (Cap. 274). In plain terms, it allows a specific company—GLG Properties Pte. Ltd.—to carry out certain residential property-related transactions and development plans without first obtaining approvals that would otherwise be required under the Residential Property Act.
Singapore’s Residential Property Act regulates the acquisition, conversion, and development of residential property, particularly where approvals are needed to manage policy objectives such as housing supply, ownership restrictions, and the proper use of residential land. However, the Act also empowers the Minister to grant exemptions in appropriate cases. This Notification is one such exemption: it waives approval requirements for specified activities, but only where the statutory criteria are met and subject to conditions set out in the Schedule.
Practically, the Notification is designed to facilitate a development and sale/disposal business model. The exemptions are framed around the company’s intention to develop residential property and ultimately sell or dispose of the residential units “for profit” after conversion, change of use, or rezoning. The Notification therefore operates as a regulatory “permission” for a defined pathway of property development for the relevant company, reducing administrative friction while maintaining safeguards through conditions.
What Are the Key Provisions?
Section 1 (Citation and commencement) provides the legal identity and timing. The Notification is cited as the Residential Property (GLG Properties Pte. Ltd. — Exemption) Notification 2021 and comes into operation on 13 August 2021. For practitioners, this commencement date is critical because the exemptions in later provisions are tied to property being vested in, acquired by, or owned by the relevant company before or on/after 13 August 2021.
Section 2 (Exemption from need for approval to become converted entity) addresses the approval requirement in section 9 of the Residential Property Act. Section 2 states that section 9 does not apply to GLG Properties Pte. Ltd. in relation to any residential property that meets three cumulative conditions:
- (a) the property is not non-restricted residential property (i.e., it falls within the category of residential property that is subject to the Act’s approval regime, rather than being excluded by the “non-restricted” classification);
- (b) the property is vested in the relevant company immediately before its conversion into a converted entity, whether the conversion occurs before, on or after 13 August 2021; and
- (c) the property is intended for development as residential property, with the ultimate purpose of sale or disposal by the relevant company as residential property for profit after conversion.
In effect, Section 2 removes the need for the company to obtain approval under section 9 for the conversion-related step, provided the property and intended use align with the development-for-profit model described above.
Section 3 (Exemption from need for approval to change existing use) removes the application of section 28 of the Act. The exemption applies to land that the relevant company:
- (a) acquires, owns or purchases on or after 13 August 2021; and
- (b) intends to change in use to and develop as residential property, with the ultimate purpose of sale or disposal for profit.
This provision is important for developers who purchase land and plan to convert it into residential use. It clarifies that, for the relevant company, the statutory approval that would normally be required for change of use under section 28 is not required if the company’s acquisition and intended residential development satisfy the stated criteria.
Section 4 (Exemption from need for approval for rezoned land) deals with section 28A of the Act, which typically governs approvals relating to rezoning. The Notification exempts the relevant company from section 28A in relation to vacant land (whether or not there is a vacant or disused building or structure on it) if:
- (a) the land is owned by the relevant company on or after 13 August 2021; and
- (b) the land is intended for development as residential property, with the ultimate purpose of sale or disposal for profit.
For practitioners, the “vacant land” framing is a key drafting choice. It suggests that the exemption is not limited to bare land; it extends to vacant land even where there is a vacant or disused building/structure, provided the land is still treated as “vacant land” for the purposes of the Act’s rezoning regime.
Section 5 (Exemption from need for housing developer’s approval) addresses section 31 of the Residential Property Act, which concerns housing developer’s approval. The exemption is structured in three layers:
- Section 5(1): subject to sub-paragraph (2), section 31 does not apply to the relevant company.
- Section 5(2): despite the general exemption, section 31(1) and (4) continues to apply in relation to the retention of a dwelling-house that is a landed dwelling-house.
- Section 5(3): defines “landed dwelling-house” as a detached house, semi-detached house or terrace house (including a linked house or a townhouse), whether or not comprised within a strata title plan registered under the Land Titles (Strata) Act (Cap. 158).
This is a significant limitation. While the company is generally exempt from housing developer’s approval requirements, it remains subject to approval requirements for retaining certain landed dwelling-houses. The carve-out indicates that the policy concern is not merely development, but also the continued retention of landed housing stock, which may be more sensitive from a regulatory perspective.
Section 6 (Conditions of exemption) provides that all exemptions are subject to the conditions specified in the Schedule. Although the provided extract does not reproduce the Schedule’s text, the legal effect is clear: the exemptions are not absolute. Practitioners should treat the Schedule as integral to compliance and due diligence, because breach of conditions could undermine the exemption and expose the company to regulatory consequences.
How Is This Legislation Structured?
The Notification is concise and follows a standard structure for exemption instruments:
- Enacting Formula and Section 1: citation and commencement.
- Sections 2 to 5: substantive exemptions from specific approval requirements under the Residential Property Act (sections 9, 28, 28A, and 31).
- Section 6: a general “conditions” clause that ties the exemptions to the Schedule.
- THE SCHEDULE: sets out the conditions that must be satisfied for the exemptions to apply.
From a practitioner’s perspective, the structure means you should read the exemptions alongside the Schedule conditions, and also map each exemption to the relevant statutory approval it displaces. The Notification is not a standalone regulatory regime; it is an overlay that modifies how the Residential Property Act applies to the relevant company for specified property and intended development purposes.
Who Does This Legislation Apply To?
The Notification applies specifically to GLG Properties Pte. Ltd. It uses the term “the relevant company” to refer to that entity throughout the Notification. It does not create a general exemption for all developers or all companies; it is an entity-specific regulatory relief.
In addition, the exemptions apply only in relation to particular categories of property and particular intended uses. For example, Section 2 is tied to residential property vested immediately before conversion into a converted entity, while Sections 3 and 4 are tied to land acquired/owned on or after 13 August 2021 and intended for development as residential property for ultimate sale/disposal for profit. Section 5 contains a carve-out for retention of landed dwelling-houses. Therefore, even for the relevant company, the exemption is conditional and fact-specific.
Why Is This Legislation Important?
This Notification matters because it affects the development timeline, compliance workload, and risk profile for GLG Properties Pte. Ltd. By exempting the company from certain approval requirements under the Residential Property Act, it can reduce delays that would otherwise arise from seeking approvals for conversion, change of use, rezoning, and housing developer’s approval.
However, the exemptions are not a blanket waiver. They are tightly drafted around (i) the timing of vesting/acquisition/ownership relative to 13 August 2021, (ii) the intended development purpose (residential development with ultimate sale/disposal for profit), and (iii) the type of property involved (including the “vacant land” concept and the “landed dwelling-house” carve-out). These limitations are likely designed to ensure that the exemption supports legitimate development activity while preserving regulatory control where policy sensitivities remain.
For legal practitioners, the most practical takeaway is to treat the Notification as a compliance framework requiring careful documentation. The company should be able to evidence: when property was acquired/owned/vested; that the property is intended for residential development; that the ultimate purpose is sale/disposal for profit; and that any retention of landed dwelling-houses is handled consistently with the continuing application of section 31(1) and (4). Finally, because Section 6 makes the Schedule conditions decisive, counsel should obtain and review the Schedule text and ensure internal processes (planning, licensing, marketing/sales documentation, and property classification) align with those conditions.
Related Legislation
- Residential Property Act (Cap. 274) — particularly sections 9, 28, 28A, 31, and the Minister’s exemption power under section 32(1)
- Land Titles (Strata) Act (Cap. 158) — relevant to the definition of “landed dwelling-house” in the Notification
Source Documents
This article provides an overview of the Residential Property (GLG Properties Pte. Ltd. — Exemption) Notification 2021 for legal research and educational purposes. It does not constitute legal advice. Readers should consult the official text for authoritative provisions.