Electricity Retailer Marketing in Singapore: The EMA Code of Conduct Rules for Selling Power Plans

Last updated 9 October 2026 — by Adrian Tan, SDM. Marketing guidance, not legal advice. Clause numbers refer to Version 8 of EMA’s Code of Conduct for Retail Electricity Licensees (19 June 2026) and section numbers to the Electricity Act 2001 as shown on Singapore Statutes Online, as at October 2026. Check with EMA or a lawyer before relying on any point.

Singapore’s Open Electricity Market lets households and businesses buy electricity from a retailer instead of paying SP Group’s regulated tariff. For retailers it is a pure marketing contest: the electricity is identical, so plans are sold on price, contract terms, bundles and, increasingly, green credentials. That makes it a category where performance marketing, comparison claims and sales channels all matter.

It is also one of the most tightly controlled sales environments in Singapore. Retailers hold licences under the Electricity Act, and their licences require them to follow EMA’s Code of Conduct for Retail Electricity Licensees. EMA issued Version 8 of the Code on 19 June 2026. It bans door-to-door selling to homes outright, bans marketing at void decks and lift lobbies, requires consent before any residential telemarketing call, and sets detailed rules on savings comparisons, salesperson identification and contract renewal.

This guide is for retailers’ marketing teams and the agencies, call centres and sales partners who work for them. It explains what the Code requires of each channel, where general consumer law adds to it, and how to write plan advertising that holds up.

The rules at a glance

How the rules fit together

The licence and the Electricity Act

Retailing electricity without a licence or exemption is an offence under section 6 of the Electricity Act 2001, with a fine of up to S$500,000 and up to S$12,500 a day for a continuing offence. EMA grants retail licences under s 9 and can require licensees to comply with codes of practice; s 18 makes compliance a duty. Under s 14, if a licensee breaches a licence condition or a code of practice, EMA can give directions, require a performance bond, or impose a financial penalty of up to 10% of the licensed business’s annual turnover or S$1 million, whichever is higher. Under s 13 it can also suspend or revoke the licence.

That is the important point for marketers: the Code of Conduct is not a voluntary industry guideline. It applies as a condition of the retailer’s licence (cl 1.2.1), and breaches are enforced against the licence.

Retailers are responsible for their salespeople and agents

Clauses 1.5.5 to 1.5.7 require the retailer to make its directors, staff and salespersons comply with the Code, and to do the same for agents authorised to make or accept offers on its behalf. Any act or omission by those people counts as the retailer’s own breach. So an outsourced telemarketing vendor, a roadshow agency or a digital agency writing ads is working under the retailer’s licence.

What counts as marketing

The Code’s rules on selling bite on an “offer to sell”, defined as an offer made through any marketing activity, “such as door-to-door selling, telemarketing, online marketing, direct mail selling or a salesperson interacting directly with the consumer”. Brand or corporate advertising that only describes the retailer falls outside that definition, although it is still covered by general consumer protection law. A plan ad with a price, a landing page with a sign-up button or a sales call is an offer to sell.

The Code also says expressly (cl 2.2.1) that it does not affect a retailer’s obligations under the Consumer Protection (Fair Trading) Act and the Personal Data Protection Act. Both apply in full alongside it.

Channel by channel: where retailers may sell

Door-to-door and “near home” marketing: banned for households

Clause 3.5.1(b) prohibits door-to-door marketing at residential premises, and 3.5.1(c) prohibits marketing aimed at residents “near or at residential premises (including but not limited to void decks, lift lobbies and corridors)”. That rules out the HDB-block canvassing and void-deck booths that featured in the market’s early years. A booth in a shopping mall is not near residential premises in the same sense, but it still has to follow the identification and fair-marketing rules below.

Telemarketing: consent first, record everything

Clause 3.5.1(a) bans telemarketing to residential consumers without their consent. This is stricter than the Do Not Call rules in Part 9 of the PDPA, which only require a check that a number is not on the DNC register (s 43) unless there is clear consent. Under the Code, a cold call to a household is not allowed even to a number that is not on the register. Where calls are allowed, the retailer must have a recording system and record the whole call (2.2.3), and the Fact Sheet and Consumer Advisory must be explained on the call (3.7.8, 3.8.6). Business customers are covered by a separate do-not-contact list that retailers must honour within 30 days of notice (2.13).

EMA’s consumer site tells households they should get no unsolicited calls, messages or visits from retailers and invites them to report any. Our guide to telemarketing rules in Singapore covers the DNC regime in detail.

Salespeople must identify themselves fully

Under clause 2.3, the retailer must use its licensed name, and any salesperson named in promotional material must appear alongside the retailer’s identity. The consumer must be given the retailer’s licensed name, licence number, a business-hours phone number, an email address, the salesperson’s name and a photograph of the salesperson (2.3.2). Retailers must keep a list of their salespersons and give it to EMA on request (2.5.1).

Online and direct mail

Digital channels are not restricted in the same way, but every online offer must meet the fair-marketing rules, and sign-up flows must meet the Fact Sheet and acknowledgement rules covered below.

The fair-marketing rules for plan advertising

Clause 2.2.2 is the core of the Code for anyone writing ads. When selling, a retailer must:

• identify itself immediately and truthfully (a), and make clear the offer is not from SP (b);
• not confuse consumers about its identity, promotions or trade marks, or those of other retailers (c);
• not exert undue pressure (d), and give consumers enough time to read without harassment (f);
• explain all key information and terms simply and clearly, verbally where practicable (e);
• make no false or likely-misleading representation (g), and give “only accurate, verifiable and truthful comparisons” (h);
• make no oral representation that is not in the written offer (i), and keep all promotional material truthful and accurate (j);
• not use print whose size or appearance materially impairs legibility (k);
• not discourage participation in demand-response or energy-efficiency programmes (l).

The “SP” problem

Because SP Group bills every household, confusion about who is selling is the market’s oldest compliance risk. In EMA’s first published enforcement action, in December 2016, Red Dot Power was penalised S$10,000 after a salesperson described it as a “new SP Services Retailer”. Avoid any copy, imagery or call script that borrows SP’s name or suggests a connection, and state the retailer’s licensed name prominently.

Savings claims must use the current tariff

The same 2016 action shows how savings claims go wrong. An agent emailed consumers promising “up to 25% savings”, calculated against the Q2 2016 regulated tariff of S$0.1768 per kWh when the Q3 tariff of S$0.1927 already applied. EMA treated that as misleading and imposed a further S$5,000 penalty. EMA weighed in mitigation that the salespersons involved were terminated and a compliance manager was appointed.

The tariff changes every quarter, so savings claims need a refresh cycle. For 1 October to 31 December 2026, the SP tariff is 28.59 cents per kWh before GST (31.16 cents with GST), down 10.4% from 31.91 cents in the previous quarter. A fixed-price plan that looked cheap in Q3 may not beat the tariff in Q4, and a “discount off the regulated tariff” plan’s cash value moves with it.

Practical rules for savings advertising:

• State the tariff quarter and figure the comparison uses, and whether figures include GST.
• Update or pull comparison creative when SP announces the next quarter’s tariff (usually at the end of the preceding quarter).
• Show “up to” savings only if typical customers can realistically achieve them, and explain the assumptions in the ad, not only in linked terms.
• Do not compare against another retailer’s plan without checking its current published terms (2.2.2(h)).

Worked example: rewriting a plan ad

The fixed price in the “better” example is a placeholder for the retailer’s real rate; the structure is the point.

Price comparison, Fact Sheets and sign-up flows

Every standard offer for residential customers, and for non-residential customers using 2,000 kWh a month or less, must be published in full on EMA’s price comparison website (2.4.1). The information must be accurate and complete (2.4.2), and the retailer is bound by what it publishes (2.4.3). The two standard plan types are a fixed price plan and a discount off the regulated tariff plan; non-standard plans can carry rates that change or are not all-inclusive, and may have recurring fees. If your ad and the comparison site disagree, consumers and EMA will both notice.

For residential offers, the retailer must publish a Fact Sheet (3.7.1), show it to the customer before signing, make sure the customer reads and acknowledges it (3.7.4, 3.7.5), and use no pre-ticked boxes (3.7.6). The same pattern applies to the Consumer Advisory (3.8). For digital teams this has direct design consequences:

• The Fact Sheet step cannot be skipped or hidden behind a collapsed link.
• Acknowledgement checkboxes must start unticked.
• Only the SP account holder, or someone authorised on EMA’s prescribed form, may sign (3.9.3), so the form should confirm this.
• There is no sale without a signed or accepted contract (2.5.2), and the customer must get a copy promptly (2.5.3).

Bundles need extra care. Where a plan includes non-electricity items, such as a smart device, broadband or a gift, the contract must break down prices, deposits, early termination charges and other charges between the electricity and non-electricity parts (2.7.2).

Contract terms that marketing must not obscure

Several Code rules on contracts change what ads may promise:

• Deposits for residential customers are capped at twice average monthly charges (3.2), and deposits and credit balances must be refunded within one month of the final bill being paid (2.10.16).
• Early termination charges may be imposed only if the retailer terminates for the customer’s breach or the customer leaves at their own convenience, and must be reasonable (2.10.12-2.10.14). If the retailer breaches or exits, it must pay the customer at least the charge it would have imposed (2.10.15).
• Auto-renewal: the renewed rate must be strictly better than the prevailing regulated tariff, other terms must be the same or better, and the term the same length (2.10.4). Residential customers can terminate within 60 days of renewal without charge (3.10.1), and must receive notices through at least two channels, including mail and mobile (3.10.3).
• Prepaid plans need EMA’s written consent (3.4.1). See our guide to prepaid package marketing for the wider rules on prepayment.

The Code also requires a retailer that becomes aware of an impending market exit to stop all marketing immediately and notify EMA at least 22 business days ahead (2.9A.3). That rule followed the 2021 exits, when Ohm Energy, iSwitch and Best Electricity stopped operating and their customers were transferred to SP. EMA’s resulting reforms also require retailers to hold tangible net worth of at least S$1 million and hedge at least 80% of their exposure.

Green electricity claims

Many retailers now sell “green” or “100% renewable” plans backed by renewable energy certificates (RECs). The Code has no clause specific to green claims, so the general rules apply: claims must be truthful, accurate and verifiable (2.2.2(g), (j)), and false claims about a product’s qualities or benefits are unfair practices under the Consumer Protection (Fair Trading) Act.

Two reference points help. SS 673, the Singapore Standard code of practice for renewable energy certificates launched in October 2021 with EMA and NEA, recommends that claims state the origin and type of renewable energy, how it was procured and how the claim is verified, and treats certificates from the same market as best practice (one certificate equals 1 MWh). And the Competition and Consumer Commission’s Guide on Quality-Related Claims (6 October 2025) asks businesses to make claims that are true, clear, meaningful, accompanied by material information and supportable by evidence. A plan that is matched with overseas certificates should say so rather than imply the electricity itself comes from Singapore solar panels. Our guide to green claims in Singapore marketing covers substantiation in more depth.

Consumer protection law on top

The CPFTA’s Second Schedule lists practices that are unfair in any industry, and several map directly onto electricity sales: falsely claiming an affiliation (the “SP retailer” problem), claiming a price benefit that does not exist, using undue pressure, offering gifts that are not provided as described, false time-limited discounts, and using small print to hide a material fact. Personal data rules apply too: the Code bars using consumer information without written consent except in listed cases (2.8), and PDPA financial penalties reach 10% of Singapore turnover for larger organisations.

Checklist for retailers and their agencies

1. Name the retailer’s licensed name and licence number in every offer, and never suggest an SP connection.
2. Do not run door-to-door, void-deck, lift-lobby or corridor activity aimed at households.
3. Telemarket households only with recorded consent, and record every call in full.
4. Date every savings comparison to the tariff quarter, and refresh it when the tariff changes.
5. Keep the ad, the landing page and the price comparison listing consistent.
6. Build sign-up flows with an unskippable Fact Sheet and Consumer Advisory step and unticked boxes.
7. Show gift and bundle conditions in readable type next to the offer.
8. Substantiate green claims to SS 673 and the CCS guide.
9. Brief every agency, call centre and roadshow partner on the Code; their breaches are the retailer’s.

Conclusion

Selling electricity in Singapore is a marketing business with a regulator watching every channel. Version 8 of EMA’s Code of Conduct shuts the doorstep and the void deck, requires consent for household telemarketing, and holds retailers to accurate, verifiable comparisons, readable terms and transparent sign-up flows, backed by Electricity Act penalties of up to 10% of turnover. Within those limits there is plenty of room to compete: clear pricing, honest comparisons dated to the tariff quarter, well-built digital journeys and credible green products are exactly what the Code rewards.

If you market an electricity retailer or another regulated utility service and want campaigns that convert within those rules, our performance marketing team in Singapore can help; see our client case studies for results. Related guides cover energy label advertising rules, EV charger marketing and advertising by electricians and plumbers. For the bigger picture, start with our complete guide to performance marketing in Singapore.

Frequently asked questions

Can electricity retailers sell door to door in Singapore?

Not to households. Clause 3.5.1 of EMA’s Code of Conduct for Retail Electricity Licensees bans door-to-door marketing at residential premises and marketing near homes, including at void decks, lift lobbies and corridors.

Can an electricity retailer cold-call households?

No. The Code bans telemarketing to residential consumers without their consent, which is stricter than the PDPA’s Do Not Call rules. Where calls are allowed, the whole call must be recorded and the Fact Sheet explained.

What must a savings claim for an electricity plan include?

It must be accurate, verifiable and truthful under clause 2.2.2(h). In practice, state the regulated tariff and quarter used for the comparison and whether GST is included. EMA penalised a retailer in 2016 for savings calculated against an out-of-date tariff.

Who is responsible if a sales agent breaks the Code?

The retailer. The Code requires retailers to make their staff, salespersons and authorised agents comply, and treats their acts and omissions as the retailer’s own breach. EMA can impose penalties of up to 10% of turnover or S$1 million, whichever is higher.

What is the SP tariff for October to December 2026?

SP Group’s regulated tariff for 1 October to 31 December 2026 is 28.59 cents per kWh before GST, or 31.16 cents with GST, down 10.4% from the previous quarter. Savings comparisons in ads should be updated to it.

Can retailers advertise plans as 100% green?

Only if the claim is true and can be substantiated. The Code requires truthful, verifiable representations, and the CPFTA bans false claims. Follow the SS 673 code of practice on renewable energy certificates and disclose where the certificates come from.