There has been an increasing regulatory focus on bid-rigging, particularly in the construction sector, across the Asia-Pacific region.
On 23 June 2025, the Competition Commission (the “Commission”) attended Hong Kong's first Building Management Summit hosted by the Independent Commission Against Corruption (the “ICAC”).[1] The Summit provided a platform for exchanging information on tackling building maintenance issues. The Commission's participation underscores its sharpened focus on combating bid-rigging, particularly through strengthened inter-agency cooperation with the ICAC.
On 20 December 2024, Singapore's Competition and Consumer Commission (the “CCCS”) imposed a record penalty on contractors specialising in non-residential interior fit-out tenders for bid-rigging,[2] followed by a May 2025 infringement decision against contractors for rigging bids in public sector tenders.[3]
South Korea's Fair Trade Commission (the “KFTC”) has targeted bid-rigging in the interior construction sector for apartment housing, fining 20 furniture firms and issuing corrective orders on 12 February 2025, while referring four for criminal prosecution.[4] Recently, it has shifted focus to mid-sized construction firms. In June 2025, it investigated five construction companies over alleged bid-rigging in public housing projects.[5]
This article examines recent enforcement actions by competition authorities in Hong Kong, Singapore and South Korea, highlighting intensified regulatory scrutiny of the construction sector across APAC.
(B) Hong Kong: Targeting Syndicated Corruption and Bid-Rigging
Bid-Rigging over Building Maintenance as an Enforcement Priority
Speaking at the Summit, ICAC Commissioner Mr Woo Ying-ming emphasized that building management was a core issue affecting the livelihoods of numerous households, while building maintenance was a perpetual hot topic in the society. Private buildings aged 30 must undergo mandatory inspection and repair. By the end of 2023, more than 28,000 private buildings in Hong Kong aged 30 years or above, accounting for 60% of all private buildings in the city. Further, around 7,700 private buildings will be required to undergo examination under Mandatory Building Inspection Scheme within the next decade.[6]
As outlined in the Report on the Work of the Competition Commission dated 3 June 2025,[7] the Commission prioritizes investigations and enforcement actions which offer the greatest overall benefit to competition and consumers. One key focus is anti-competitive conduct concerning livelihood issues. As such, bid-rigging in building maintenance is an enforcement priority.
Bid-rigging in Hong Kong's building maintenance sector has distinctive characteristics. It is rarely isolated. It usually involves complex syndicates comprising consultants, contractors, property management companies, and incorporated owners. Parties seeking contracts collude and offer bribes to secure favourable treatment, violating both the Competition Ordinance (Cap. 619) and the Prevention of Bribery Ordinance (Cap. 201).
Strengthened Inter-Agency Cooperation
Given the complexity of such cases, the Commission has strengthened inter-agency cooperation, particularly with the ICAC. This cooperation was demonstrated by two joint operations conducted in April 2024[8] and August 2024[9], the signing of a Memorandum of Understanding in December 2024[10] as well as the joint participation in the Summit in June 2025.[11]
The April 2024 and August 2024 joint operations focused on renovation projects across 38 residential and industrial buildings in Hong Kong Island, Kowloon, and the New Territories. Targeting a newly emerged syndicate manipulating tenders through bribery and bid-rigging, the agencies executed search warrants at approximately 60 premises. [12] The total value of the contracts over HK$1 billion, with the single largest contract valued at HK$260 million. [13]
(C) Singapore: Record Penalties
Bid-rigging has been the top enforcement priority for the CCCS. The CCCS views that bid-rigging is one of the most serious infringements of competition law globally and in Singapore,[14] as it eliminates competitive pressure between the parties to submit their best offers to potential customers, preventing customers from receiving genuinely competitive offers and potentially leading to overpayment.[15]
Infringement Decision against Contractors Specialising in Non-Residential Interior Fit-Out Tenders for Bid-Rigging
On 20 December 2024, the CCCS issued an Infringement Decision against contractors Flex Connect Pte Ltd (“FL”) and Tarkus Interiors Pte Ltd (“Tarkus”), for engaging in bid-rigging conduct (the “December 2024 Infringement Decision”).[16] They are among a limited number of firms capable of undertaking high-value interior decoration and finishing works contracts.
CCCS’s investigations revealed that FL and Tarkus entered into anti-competitive agreements and/or concerted practices to engage in bid-rigging in relation to 12 tenders conducted in Singapore involving non-residential developments (the “Conduct”).[17] The Conduct took place over a period of five years with the first affected tender called in August 2016 and the last in August 2021.[18]
Their bid-rigging scheme typically operated as follows:[19] the parties would designate one firm as the intended winner. The designated winner would then share its bid pricing details with the other party, which would submit a higher-priced bid to improve the designated winner's chances of securing the tender.
CCCS rejected arguments by FL and Tarkus that declining to participate in tenders risked exclusion from future opportunities.[20]
As FL applied for and was granted leniency during the initial investigations, CCCS reduced its penalty by applying a leniency discount to its penalty.[21] The combined total penalties imposed on FL and Tarkus amounted to S$9,999,182 (i.e. FL: S$4,885,263; Tarkus: S$5,113,918).[22] This marks the highest financial penalty CCCS has imposed for bid-rigging to date.
In determining the penalties, CCCS applied the six-step approach set out in the CCCS Guidelines on the Appropriate Amount of Penalty (“CCCS Penalty Guidelines”) which considers the seriousness of the infringement, the turnover of the undertaking’s business in Singapore for the relevant product and relevant geographic markets affected by the infringement in its last business year, the duration of the infringement as well as relevant aggravating and mitigating factors.[23] In this case, the repeated nature of the conduct across discrete tenders was treated as an aggravating factor.[24]
Notably, regarding duration, CCCS considers the effects of bid-rigging are generally irreversible, cannot be easily rectified, and continue to be felt long after the duration where the infringing conduct occurred.[25] Therefore, CCCS generally does not set a duration of infringement that is less than one year in cases of bid-rigging infringements.[26] In this case, although the bid-rigging agreements/practices occurred repeatedly in discrete tenders from 2016 to 2021, each lasting a short time, CCCS viewed that the duration for the purpose of calculating penalties should be one full year for each separate incidence of infringement.[27]
Infringement Decision against Contractors for Rigging Bids in Public Sector Tenders
On 23 May 2025, CCCS issued an Infringement Decision against Trust-Build Engineering & Construction Pte Ltd. (“TB”) and Hunan Fengtian Construction Group Co., Ltd (“HNFT”) for engaging in bid-rigging conduct relating to three invitations to People's Association tenders (“PA Tenders”) for upgrading works at Community Clubs located at Bukit Batok, Cheng San, and Eunos (“May 2025 Infringement Decision”). [28]
CCCS’s investigations revealed that HNFT prepared TB's tender submissions and proposed TB's bid prices for all three PA Tenders.[29] Even when HNFT purported to compete against TB, it was aware of TB's likely bid prices and submission details.[30] Consequently, neither company independently determined their bids.[31]
Unlike the previous case, no PA tenders were awarded to either party as the PA detected potential bid-rigging before awarding the tenders, reported it to the CCCS, and subsequently excluded both TB and HNFT from the tender evaluation process.[32] However, the CCCS found that the parties' bid-rigging conduct eliminated competitive pressure between them and might create a false impression of competition.[33]
CCCS imposed total penalties of S$4,644,409 (i.e. HNFT: S$349,350; Tarkus: S$4,295,059). In determining the penalties, CCCS applied the six-step approach set out in the CCCS Penalty Guidelines. [34] Aggravating factors included the active roles of senior management at HNFT and TB in perpetrating the conduct, and the role of an undertaking as a leader or instigator of the infringement.[35]
In the Media Release of May 2025 Infringement Decision, Chief Executive of CCCS, Mr. Alvin Koh reiterated the CCCS’ position on bid-rigging:[36]
“CCCS
emphasizes that bid-rigging undermines fair competition, distorts the regular
operation of market forces, and prevents customers from obtaining genuine and
competitive offers. In the context of public procurement where public funds are
used, taxpayers are the ones who ultimately pay the price of such infringing
conduct. In line with our mission to make Singapore markets work well, we will
continue to take a more active enforcement stance, and take decisive and firm
action against businesses which are found to have engaged in anti-competitive
conduct.”
“CCCS advises businesses that might be asked
to participate in anti-competitive agreements to immediately decline to do so,
publicly distance themselves from such discussions, and report the matter to
CCCS. If you are currently involved in such conduct, CCCS offers a leniency
programme with an opportunity for such
businesses to come forward with information about anti-competitive agreements
and receive a full waiver or substantial reduction in financial penalties. For
individuals, those with information on cartel activity in Singapore can also
provide such information through CCCS’s reward/whistle-blowing scheme with
monetary rewards of up to $120,000.”
The December 2024 Infringement Decision and May 2025 Infringement Decision demonstrate CCCS’s heightened scrutiny of bid-rigging in the construction sector across both private and public sector tenders.
(D) South Korea: Crackdown on Apartment Interior Construction and Mid-Size Construction Companies
Sanctions Against Furniture Companies for System Furniture Bid-Rigging
The KFTC has intensified its crackdown on bid-rigging in the apartment interior construction. On 14 February 2025, the KFTC imposed corrective orders and a provisional fine of KRW 13.8 billion on 20 furniture companies that supplied system furniture for apartments.[37] It also referred 4 of these companies for criminal prosecution.[38] Those companies colluded in 190 system furniture bids ordered by 16 construction firms between February 2012 and November 2022 by pre-determining the winning bidders and bid prices.
Their bid-rigging scheme typically operated as follows: before the bidding, sales representatives determined designated winners through meetings or phone communications and agreed on bid prices. The companies also determined the order in which they would win bids. The designated winner sometimes promised to share profits by allocating a portion of the awarded project to the cover bidder or providing cash payments, with agreements documented in writing. Besides, the designated winner determined and communicated the bid prices for the cover bidder, who then submitted their bids accordingly.
This case marks the KFTC’s third sanction against bid-rigging in the apartment interior construction, following the cases involving built-in furniture in April 2024[39] and system bathroom in October 2024.[40] The KFTC highlighted the significance of exposing a decade-long malpractice in the system furniture bidding market.
Investigations into Mid-Size Construction Companies
Recently, the KFTC has shifted its focus to mid-size construction companies after detecting abnormal bid patterns, for example, an abnormal rise in the lowest bid rate and recurring instances of companies submitting identical prices.[41]
Following an investigation conducted on 22 May 2025 into four construction companies, in June 2025, KFTC conducted field investigations on five construction companies, including Dongbu Corporation and Ssangyong Engineering & Construction, in relation to allegations of bid rigging for Korea Land and Housing Corporation (“LH”) public housing projects.[42] It also seized internal documents related to LH public housing bid-rigging.
These investigations followed reports from LH and the Public Procurement Service (“PPS”), triggered by: (1) the PPS’s observations of identical bids in the “Goyang Changneung apartment construction project”; and (2) LH’s identification of suspicious patterns in 2024 civil engineering and rental housing remodeling projects, as well as the 2025 Suwon Dangsu public housing project.
(E) Key Takeaways
In conclusion, APAC competition authorities are escalating enforcement against construction-sector bid-rigging as illustrated by Hong Kong’s joint agency operations targeting corruption-competition syndicates, Singapore’s record penalties, and South Korea’s widening crackdowns.
Companies should focus on three pillars: “Prevention”, “Probe” and “Response”:
1. Prevention: They should expand bidding pools to include diverse suppliers, conduct due diligence on all bidders, use AI/data analytics to audit bid patterns for anomalies, as well as train staff and management regularly on competition laws and bid-rigging risks.
2. Probe: They should implement whistleblower systems with anonymous reporting channels and rewards.
3. Response: If collusion is suspected or detected, they should immediately seek leniency and fully cooperate with authorities.
[1] https://www.icac.org.hk/en/p/press/index_id_2128.html
[2]
https://www.cccs.gov.sg/media-and-events/newsroom/announcements-and-media-releases/cccs-penalises-contractors-specialising-in-non-residential-interior-fit-out-tenders-for-bid-rigging-251
[3]
https://www.cccs.gov.sg/media-and-events/newsroom/announcements-and-media-releases/cccs-imposes-a-total-of--4-6m-penalties-on-contractors-for-rigging-bids-in-public-sector-tenders
[4]
https://www.ftc.go.kr/viewer/synap/skin/doc.html?fn=20250220041225285_oNYQt9IYOP.pdf&rs=/viewer/synap/preview/
[5]
https://biz.chosun.com/en/en-policy/2025/06/13/O4V6ZGF3XZFRTFDKTOWFS42INY/
[6] https://news.tvb.com/tc/pearlnews/685957c0c1c3b5eb960121bb/TVB-News-ICAC-hosts-the-citys-first-building-management-summit
[7] https://www.legco.gov.hk/yr2025/english/panels/edev/papers/edev20250603cb3-819-4-e.pdf
[8] https://www.compcomm.hk/en/media/press/files/Joint_operation_PR_EN.pdf
[9] https://www.compcomm.hk/en/media/press/files/PR_Joint_operation_AUG_EN.pdf
[10] https://www.compcomm.hk/en/media/press/files/CC_ICAC_MoU_PR_EN.pdf
[11] https://www.icac.org.hk/en/p/press/index_id_2128.html
[12] https://www.compcomm.hk/en/media/press/files/CC_ICAC_MoU_PR_EN.pdf
[13]
https://news.rthk.hk/rthk/en/component/k2/1767709-20240826.htm
[14]
https://www.cccs.gov.sg/media-and-events/newsroom/announcements-and-media-releases/cccs-penalises-contractors-specialising-in-non-residential-interior-fit-out-tenders-for-bid-rigging-251/
[15] https://www.cccs.gov.sg/media-and-events/newsroom/announcements-and-media-releases/cccs-penalises-contractors-specialising-in-non-residential-interior-fit-out-tenders-for-bid-rigging-251/;
https://www.cccs.gov.sg/media-and-events/newsroom/announcements-and-media-releases/cccs-imposes-a-total-of--4-6m-penalties-on-contractors-for-rigging-bids-in-public-sector-tenders
[16]
https://www.cccs.gov.sg/media-and-events/newsroom/announcements-and-media-releases/cccs-penalises-contractors-specialising-in-non-residential-interior-fit-out-tenders-for-bid-rigging-251
[17] Paragraph 3, page 3, December 2024 Infringement Decision
[18] Ibid.
[19] Page 26, paragraph 64, December 2024
Infringement Decision
[20]
https://www.cccs.gov.sg/media-and-events/newsroom/announcements-and-media-releases/cccs-penalises-contractors-specialising-in-non-residential-interior-fit-out-tenders-for-bid-rigging-251/
[21] Page 115, paragraph 313, December 2024
Infringement Decision
[22] Page 125, paragraph 343, December 2024 Infringement Decision
[23] Page 95, paragraph 246, December 2024 Infringement Decision
[24] Page 99, paragraph 258,
December 2024 Infringement Decision
[25] CCCS Penalty
Guidelines, paragraph 2.12
[26] CCCS Penalty
Guidelines, paragraph 2.12
[27] Page 99, paragraph 258, December 2024 Infringement Decision
[28] Paragraph 1, page 2,
May 2025 Infringement Decision
[29]
https://www.cccs.gov.sg/media-and-events/newsroom/announcements-and-media-releases/cccs-imposes-a-total-of--4-6m-penalties-on-contractors-for-rigging-bids-in-public-sector-tenders/
[30] Ibid.
[31] Ibid.
[32] Ibid.
[33] Ibid.
[34] Page 95, paragraph 246, December Infringement Decision
[35] Page 24, May 2025
Infringement Decision
[36]
https://www.cccs.gov.sg/media-and-events/newsroom/announcements-and-media-releases/cccs-imposes-a-total-of--4-6m-penalties-on-contractors-for-rigging-bids-in-public-sector-tenders
[37] https://www.ftc.go.kr/viewer/synap/skin/doc.html?fn=20250220041225285_oNYQt9IYOP.pdf&rs=/viewer/synap/preview/
[38] Ibid.
[39]
https://www.mlex.com/mlex/articles/2117712/south-korean-furniture-companies-fined-68-8-million-in-decade-long-bid-rigging-scandal
[40]
https://news.sbs.co.kr/news/endPage.do?news_id=N1007850390
[41]
https://biz.chosun.com/en/en-policy/2025/06/13/O4V6ZGF3XZFRTFDKTOWFS42INY/
[42]
Ibid.
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