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On the CEA Code of Ethics:
You are correct that Singapore property agents are governed by the Council for Estate Agencies (CEA) and are bound by the Code of Ethics and Professional Client Care (CEPCC). This is the equivalent of your professional body's code of conduct — breach of which can result in disciplinary action, fines, suspension or loss of licence.
On Duty of Care — Who Does the Agent Actually Serve:
This is the nuanced heart of your question. In Singapore's agency framework:

An agent formally represents and owes primary fiduciary duty to their client — the party who engaged and is paying them
In a typical leasing transaction the landlord engages and pays the landlord's agent — so the landlord's agent's primary duty is to the landlord
The tenant's agent if separately engaged owes duty to the tenant

However the CEPCC goes beyond just the contracting party:
The code explicitly requires agents to:

Act with honesty and integrity toward ALL parties — not just their client. This means an agent cannot actively deceive or mislead a tenant even though the tenant is not their client
Not make false or misleading representations — to any party in the transaction including tenants
Disclose material facts — agents are required to disclose known material facts about a property that could affect a tenant's decision, regardless of which party they represent
Not engage in conduct that brings the profession into disrepute — this covers behaviour toward any party including tenants

The Practical Distinction:
Think of it this way — similar to how an auditor owes primary duty to shareholders but still has obligations not to deceive other stakeholders:

Landlord's agent must — negotiate best terms for landlord, market property effectively, act in landlord's best interest
Landlord's agent must NOT — lie to tenant about property condition, conceal known defects, harass or intimidate tenant, make fraudulent representations

On Your Point About Regulatory Protections:
You are astute in noting that Singapore's framework is largely contractual rather than statutory for tenants. Unlike countries with dedicated residential tenancy legislation — such as Australia's Residential Tenancies Act or the UK's Housing Act — Singapore has no equivalent standalone tenant protection statute. Read More

At the end of the day, an agent's responsibility ends after the handover of apartment to the tenant in terms of the assignment.

There is no requirement for follow ups, therefore if any agent does follow up on the tenancy matters without being paid a management fees, this is good news to the landlord and/or tenant.

I have come across landlords and tenants who want to have no form of contacts from each other as well as those on the other spectrum where they want to be put into a WhatsApp group chat to communicate freely. This can also be part of the agent's management, where they may not want both parties to be in contact from each other.

For me, this is part and parcel of what we do as realtors. If you suspect any wrongdoing on the part of the agent, you have the option to report or complain to the authority, in this case the Council Of Estate Agencies or even raise a legal action against the agent.

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I have been in the real estate business since 2009, with more than 15 years of experience serving the Singapore real estate market. Check out the EdgeProp featured article on myself recently at https://www.edgeprop.sg/property-news/geryl-lim-leading-landed-real-estate-heart-hustle-and-harmony

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(✔1) CEA Code of Ethics and Professional Client Care (CEPCC) applies to all clients
Agents in Singapore must act honestly, fairly, and professionally toward both clients and customers.
Client usually refers to the landlord who engages them, while tenant is treated as a customer.

(✔2) Duty of fairness exists, but fiduciary duty is mainly to the client
Agents must not mislead tenants and must provide accurate information.
However, their primary loyalty is to the party who appointed them, typically the landlord.

(✔3) What protection tenants actually have under CEPCC
Agents must

* Provide truthful information
* Disclose known material facts
* Avoid unethical or discriminatory conduct
* Act professionally in all dealings

They are not required to act in the tenant’s best interest as an advocate.

(✔4) Reality in practice
Singapore operates mainly on a contract-based system

* Tenancy agreement defines most rights and obligations

* CEA regulates agent conduct, not landlord-tenant disputes

* Disputes are usually resolved through contract law or Small Claims Tribunal

(✔5) Bottom line
Agents owe tenants a duty of honesty and fair conduct, but their main legal duty remains to their appointed client.

“Ethics is knowing the difference between what you have a right to do and what is right to do.” — Potter Stewart

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There is indeed duty of care as you have pointed out, to all parties involved in the transaction.

How that eventually plays out depends on the specific situation especially on matters of opinion of what is fair on unfair, ethical or unethical. This is even more so when it comes to written contractual terms.

Part of the agent's duty is to ensure both parties understand all terms before signing, and also not provide any false information.

However, if there are terms that one party feels is 'unethical', the best approach is to work with all parties to amend the clauses before signing, or avoid signing the contract altogether.
- After signing, it would indeed come down to the contractual terms agreed by both parties.
- It would not be reasonable to first sign the contract, and then backtrack to attempt voiding a particular clause you feel is unfair only halfway through the lease period.
- Agents play a different role compared to lawyers, so if there are any contractual disputes after lease signing, the recommended course of action could be to involve a lawyer at that point

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It sounds like you are about to enter a tenancy agreement without the help of a tenant agent on your side, and might be worried that the landlord/ landlord agent would take advantage of you.

The duty of the landlord agent is exactly to work towards the benefit of the landlord, so it is natural that the landlord agent may insert perfectly legal/ ethical but tenant-disadvantageous clauses in the tenancy agreement while removing tenant-advantageous clauses, which a normal renter may be unaware of.

This is exactly where it might be helpful to bring an experienced tenant agent on your side to help you in finding a place, looking through the tenancy agreement, negotiate away disadvantageous clauses and adding certain tenant protection clauses to put you in the best position throughout the lease period.

If that is something you would value, feel free to reach out and I can help.

Kay Cloud
The Harvard Educated Agent
Propnex Realty Pte Ltd
cloud@propnex.com
Tel: (+6.5.) 8.5.6.7.4.5.8.5
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