To secure compliance with the licence conditions, IPOS is empowered to investigate and take regulatory actions against CMOs and their officers for any breach of the licence conditions.
For the purposes of regulation, each CMO must submit to IPOS an email address at which IPOS may serve documents on it. All CMOs should submit this email address to IPOS via email to Copyright@ipos.gov.sg before 1 May 2024.
At first instance, members and users are empowered to hold CMOs to account for compliance with the licence conditions. IPOS will step in only if the parties are unable to resolve the matter through the CMO’s internal dispute resolution process.
A member or user (including an intending user) who is aware that a CMO has breached a licence condition, and has exhausted the CMO’s internal dispute resolution process, may submit a request for investigation to IPOS. Such requests must
identify the specific breach by the CMO, including the specific Regulation or Section of the Act, to be investigated.
The scheme does not intervene in fee-setting as CMOs remain free to determine the fees they charge for permission to use the works and performances they manage. Where a dispute on such fees arises, the Copyright Tribunals remain the appropriate forum for the resolution of such disputes.
The flowchart below sets out a quick overview of the process of regulatory action against a CMO. The process may vary depending on the subject matter involved or the outcome of each stage. For further details, please refer to Part D of the CMO Guide.
Any regulatory action taken by IPOS must be complied with, even if a reconsideration application or an appeal is pending. However, a person affected by the regulatory action may request that IPOS (in the case of a reconsideration application) or the Minister
(in the case of an appeal) suspend the regulatory action pending the relevant decision.
Please refer to the 
Compliance Checklist for CMOs in the CMO Guide for
a summary of the licence conditions CMOs must adhere to.
The forms relevant to the regulatory action will be made available before the regime takes effect on 1 May 2024.
The class licensing scheme contains a dual set of levers: licence conditions and
best practices. Licence conditions are mandatory. Failure to comply constitutes a breach that may attract regulatory action by IPOS, such as financial penalties. In contrast, best practices are not mandatory. They are resources that encourage and
assist CMOs to meet industry and international standards. If and when necessary and appropriate, certain best practices may be elevated to licence conditions subsequently.
IPOS will be working with the stakeholders of the collective rights management ecosystem to develop the best practices at a later stage. Please check back here later for the details on the public consultation exercise.