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. Where a breach is found, IPOS may take 1 or more of the following regulatory actions:
- issue a regulatory direction to a CMO or its officers to remedy the breach;
- impose a financial penalty on a CMO or its officers; or
- make a cessation order, which requires the CMO to cease its CMO business either indefinitely or for a specified period.
IPOS has the discretion to decide not to pursue the investigation or suspend further investigation.
For compliance purposes, every CMO must submit an email address to IPOS via email (Copyright@ipos.gov.sg). Failure to do so constitutes a breach of the licence conditions. For a summary of this requirement and other licence conditions that CMOs must adhere to, please refer to the 
Compliance Checklist for CMOs (in the annex to the CMO Guide).
An overview of the regulatory process and timelines is set out in the flowchart below. This process may vary depending on the nature of the alleged breach or the outcome of each stage of the process.
As a first resort, a CMO is generally held accountable for complying with the licence conditions by its members and users via its internal dispute resolution process. If this process is exhausted but the CMO continues to breach the licence conditions, its member or user (including an intending user) may submit a request for investigation to IPOS.
For further details, please refer to Part D of the CMO Guide.
For information on the forms and fees for each stage of the regulatory action process and how to submit the forms, please refer to our Forms & Fees page here.
What IPOS will not investigate
Under the class licensing scheme, 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. IPOS will not take regulatory action against a CMO or its officer in respect of the fees (or other terms of a tariff scheme) set by the CMO and, accordingly, will not entertain any request for investigation that is submitted in relation to such disputes.
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.