Vertical separation is not a de-facto requirement under the Telecom Competition Code 2012, unless it is imposed as a requirement by IMDA as a result of M&A or anti-competitive assessment. Currently, accounting separation (least extensive type of vertical separation) is only required for dominant licensees and affiliates of dominant licensees. As the fixed retail market is deemed to be competitive, no Dominant Licensees have been designated. See also: IMDA official website, Full Competition in Singapore's Telecommunication Sector, last updated on 03 Jun 2019, https://www.imda.gov.sg/regulations-and-licensing-listing/competition-management/full-competition-in-singapores-telecommunication-sector