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Shared Mobility Enterprises (Control and Licensing) (Temporary Exemption) Order 2020

Overview of the Shared Mobility Enterprises (Control and Licensing) (Temporary Exemption) Order 2020, Singapore sl.

Statute Details

  • Title: Shared Mobility Enterprises (Control and Licensing) (Temporary Exemption) Order 2020
  • Act Code: SMECLA2020-OR1
  • Legislation Type: Subsidiary legislation (Order)
  • Authorising Act: Shared Mobility Enterprises (Control and Licensing) Act 2020 (Section 47)
  • Current Version: Current version as at 27 Mar 2026
  • Key Provisions (from extract): Sections 2–4 (definitions and temporary exemptions)
  • Legislative History (high level): Made on 22 Jul 2020 (SL 568/2020); amended by S 321/2021 on 17 May 2021; revised edition on 2 Jun 2025 (2025 RevEd)

What Is This Legislation About?

The Shared Mobility Enterprises (Control and Licensing) (Temporary Exemption) Order 2020 (“the Order”) is a regulatory “carve-out” from parts of Singapore’s shared mobility licensing regime. In plain terms, it temporarily exempts certain business activities—specifically, providing docked vehicles for hire and facilitating bookings for on-demand vehicle hire—from the licensing/control requirements that would otherwise apply under the Shared Mobility Enterprises (Control and Licensing) Act 2020 (“the Act”).

The Act is designed to regulate shared mobility enterprises to ensure safety, accountability, and appropriate oversight of services that enable members of the public to hire mobility vehicles. However, the legislature recognised that some operational models (particularly those involving docked bicycles or docked personal mobility devices, and booking facilitation for on-demand hire) may have been in transition—whether due to technology, market development, or implementation timelines. The Order addresses that by granting targeted exemptions, rather than leaving the market entirely unregulated or forcing immediate compliance for all models.

Accordingly, the Order does not repeal the Act. Instead, it narrows the circumstances in which certain sections of the Act apply. The practical effect is that qualifying providers and booking-facilitators may continue operating without being subject to the specific requirements contained in Sections 8 and 9 of the Act, provided they fall squarely within the defined activities and vehicle categories described in the Order.

What Are the Key Provisions?

1. Definitions (Section 2)
Section 2 sets out key terms used throughout the Order. The definitions are important because the exemptions depend heavily on the type of vehicle and the operational mode (docked vs undocked, on-demand vs docked hire). The Order defines:

  • “motorised personal mobility device” as a personal mobility device other than a non-motorised personal mobility device;
  • “non-motorised personal mobility device” as a personal mobility device designed to be propelled by human power only;
  • “power-assisted bicycle” as a bicycle equipped with an electric motor, which may be propelled by human power, the electric motor, or both; and
  • “vehicle” as a bicycle, personal mobility device, power-assisted bicycle or mobility vehicle.

From a practitioner’s perspective, these definitions are the gateway to eligibility. If the service involves a vehicle that does not fall within the Order’s definition, the exemption will not apply. Similarly, if the device is mischaracterised (for example, whether it is motorised vs non-motorised, or whether it is a bicycle vs a personal mobility device), the exemption may be lost.

2. Exemption for providing docked vehicles for hire (Section 3)
Section 3 is the first substantive exemption. It provides that Sections 8 and 9 of the Act do not apply to a person who, in the course of business, provides a service using specified vehicles under which an individual can:

  • (a) hire a docked bicycle, docked non-motorised personal mobility device, or docked mobility vehicle to ride on wholly or partly in a public place; and
  • (b) end the hiring of the vehicle docked in or at any place, whether or not a public place.

The structure of Section 3 is significant. It is not enough that the vehicles are “for hire” or that riding occurs in public. The exemption is tied to a specific operational pattern:

  • The vehicle must be docked at the time of hire; and
  • The customer must be able to end the hiring by docking the vehicle in or at any place (including non-public locations).

In other words, the exemption is designed for dock-based systems where the end-of-trip action involves returning the vehicle to a docking arrangement. For counsel advising shared mobility operators, this provision is likely to be most relevant to docked bicycle or docked non-motorised personal mobility device schemes, where the docking infrastructure and end-of-hire mechanics are central to the business model.

3. Exemption for facilitating bookings (Section 4)
Section 4 provides a second category of exemption: it applies to a person who, in the course of business, provides a service that involves facilitating the making and taking of bookings by an individual. Again, it states that Sections 8 and 9 of the Act do not apply, but only where the booking facilitation is linked to specific hiring patterns.

Section 4 sets out three scenarios (a)–(c). Each scenario is carefully drafted to cover different combinations of:

  • on-demand hire vs other forms of hire;
  • the vehicle being undocked or docked at the time it is hired;
  • whether the vehicle is ridden wholly or partly in a public place;
  • and where the hiring is ended (docked or undocked, and whether in a public place or any place).

Scenario (a): on-demand hire of undocked vehicles for hire in a public place
Under Section 4(a), the exemption applies where the individual can hire on-demand a vehicle that is standing or exposed undocked in a public place for hire by the general public, to:

  • ride on wholly or partly in a public place; and
  • end the hiring of the vehicle undocked in or at any public place.

This scenario contemplates an undocked “pick-up” model in public, with an end-of-trip that still occurs in a public place (but without requiring docking).

Scenario (b): on-demand hire of undocked vehicles for hire generally (public or otherwise)
Section 4(b) expands the exemption to cases where the vehicle is standing or exposed undocked (whether or not in a public place) for hire by the general public or otherwise. The individual can then:

  • ride on wholly or partly in a public place; and
  • end the hiring either undocked or docked in or at any place, whether or not a public place.

This is broader than (a) because it allows end-of-hire in any place and permits either undocked or docked termination. For practitioners, this is a key drafting feature: it reduces the compliance burden where the booking-facilitator’s platform enables flexible end-of-trip behaviour.

Scenario (c): hiring a docked vehicle and ending either undocked or docked anywhere
Section 4(c) covers a hybrid model: the individual hires a docked vehicle to ride on wholly or partly in a public place, and can end the hiring either:

  • undocked or docked in or at any place, whether or not a public place.

Compared with Section 3, which requires docking to end the hiring, Section 4(c) allows ending in a more flexible manner. This reflects the fact that Section 4 is aimed at booking facilitation rather than the physical docking mechanics of the provider’s service.

4. The legal technique: “Sections 8 and 9 do not apply”
A recurring phrase in Sections 3 and 4 is that Sections 8 and 9 of the Act do not apply to qualifying persons. While the extract does not reproduce Sections 8 and 9, the drafting indicates that those sections contain the licensing/control obligations that would otherwise be triggered. The Order therefore operates as a targeted exemption from those obligations, not a general exemption from the entire Act.

For legal analysis, this means practitioners should not assume that all regulatory duties are removed. The exemption is limited to the specific Act provisions referenced. Any other obligations under the Act (or under other subsidiary legislation) would still need to be assessed separately.

How Is This Legislation Structured?

The Order is structured as a short instrument with a conventional layout:

  • Citation (Section 1): identifies the Order by name.
  • Definitions (Section 2): provides interpretive terms, especially around vehicle categories.
  • Providing docked vehicle for hire (Section 3): sets out the dock-based exemption for service providers.
  • Facilitating making and taking of bookings of vehicles for hire (Section 4): sets out the booking-facilitation exemption for platform or service operators, with three detailed scenarios.

Notably, the extract indicates that the Order is concise and focused: it does not create new licensing schemes or enforcement mechanisms. Instead, it functions as a temporary regulatory adjustment, likely intended to manage market transition and operational realities while the broader licensing framework takes effect.

Who Does This Legislation Apply To?

The Order applies to “a person who provides in the course of business” the relevant services described in Sections 3 and 4. This includes operators of shared mobility services and potentially booking-facilitators (such as platforms or intermediaries) that arrange for individuals to hire vehicles under the specified conditions.

Eligibility is activity-specific and vehicle-specific. For Section 3, the exemption is limited to services involving docked bicycles, docked non-motorised personal mobility devices, or docked mobility vehicles, with end-of-hire by docking “in or at any place”. For Section 4, the exemption is limited to services that facilitate bookings for on-demand hire or docked hire, with end-of-hire rules varying by scenario (a)–(c). If the service model falls outside these conditions—such as requiring end-of-hire in a way not contemplated, or involving vehicle types not covered by the definition of “vehicle”—the exemption may not apply.

Why Is This Legislation Important?

This Order is important because it clarifies when shared mobility operators and booking-facilitators can operate without being subject to the licensing/control provisions in Sections 8 and 9 of the Act. In practice, this can affect business continuity, compliance planning, and the design of customer-facing features (such as how trips start and end, and whether docking is required at termination).

For practitioners advising clients in the shared mobility sector, the Order provides a structured compliance pathway: map the client’s operational model to the statutory scenarios. If the client’s service enables hiring and trip termination in the ways described, the exemption may reduce regulatory friction. If not, counsel should expect licensing obligations to apply and should advise on the steps required to become compliant under the Act and any related subsidiary instruments.

Finally, the Order’s legislative history and revised edition status underscore that the exemption framework has been updated over time. Even though the extract labels the instrument as “Temporary Exemption”, practitioners should treat the current version as authoritative as at the relevant date and should verify whether further amendments or expiries exist in the full text or in the Act’s transitional provisions.

  • Shared Mobility Enterprises (Control and Licensing) Act 2020 (authorising Act; referenced Sections 8, 9, and Section 47)
  • Shared Mobility Enterprises (Control and Licensing) (Temporary Exemption) Order 2020 amendments: S 321/2021
  • Shared Mobility Enterprises (Control and Licensing) (Temporary Exemption) Order 2020 original subsidiary legislation: SL 568/2020
  • 2025 Revised Edition (2 June 2025)

Source Documents

This article provides an overview of the Shared Mobility Enterprises (Control and Licensing) (Temporary Exemption) Order 2020 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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