Announced in August, the $1.43 billion SIMBA–M1 deal set the market buzzing. Today, we can share our role: TSMP is Singapore counsel to SIMBA on its proposed acquisition of 100 per cent of M1 Limited (excluding the ICT business) — Singapore’s first telco consolidation.
TSMP Advises SIMBA on Landmark SIMBA–M1 Deal as Regulator Invites Public Feedback
Features June Ho, Heather Chong Si-Ying
This update comes as IMDA opened public consultation on 1 Oct, a formal step inviting industry and public feedback before any decision. In short, the transaction isn’t completed; it has entered the competition and public-interest review phase.
Under this mandate, a cross-disciplinary TSMP team led by Partner June Ho — comprising Associate Director Heather Chong, Senior Associates Lyn Toh and Chow Jian Hui, and Associate Benjiro Tan — is conducting Singapore due diligence, advising on the sale and purchase agreement, and guiding the Long-Form Consolidation Application to IMDA, subject to approval.
From Monopoly to a Competitive Market
Singapore’s telecoms sector was liberalised from the mid-1990s after Singtel’s monopoly ended (mobile from 1997, other services such as fixed line and IDD by 2007). M1 entered in April 1997, reaching around 10% market share (about 35,000 subscribers) in its first month with consumer-friendly plans, while StarHub launched in April 2000 with innovations such as free incoming calls and per-second billing, surpassing 200,000 subscribers by November 2000.
Liberalisation lowered IDD and mobile prices and pushed mobile penetration from 13.6 per cent (Jan 1992) to over 100 per cent by 2006. To further spur competition, SIMBA launched commercially in 2020 with a market-shaping $10 SIM-only 50GB plan. In parallel, MVNOs (e.g., Circles.Life, Gomo, Maxx) entered from 2016, leasing capacity from network operators and intensifying price competition.
Regulatory Process and Public Consultation
In line with the Telecommunications Act and the Code of Practice for Competition in the Provision of Telecommunication and Media Services, IMDA is conducting a public consultation on the proposed consolidation. Transactions involving Designated Telecommunication Licensees (DTLs) require IMDA approval where they amount to a “Consolidation” (including acquisitions conferring at least 30 per cent control or Effective Control).
Applicants’ position and commitments (as submitted to IMDA):
Competition: SIMBA and M1 submit that neither has Significant Market Power and that the transaction will not substantially lessen competition.
Consumer safeguards (two years post-completion):
- No price increases for current customers with active services/contracts.
- Continued offering of mass-market $10 and $12 mobile plans.
- MVNO protections: honour all existing MVNO contracts with no change to commercial terms or service levels, and support new MVNO entrants under IMDA’s Wholesale Framework.
Submissions on competition and public-interest considerations are invited by 31 October 2025, 9.00am (SGT) to consultation@imda.gov.sg with the header “Proposed Consolidation between SIMBA and M1”. Respondents may request confidential treatment for sensitive material, accompanied by a corresponding public, redacted version.
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