Historically, Singaporean law prohibited third party funding arrangements and outcome-related fee structures (ORFS) such as “No-Win, No-Fee” or “No-Win, Less-Fee”. However, other common law jurisdictions, such as England and Wales and Australia, have relaxed their equivalent laws and now permit some third party funding and ORFS to some extent. Singapore took its first steps towards levelling the playing field when it legalised third party funding for arbitration and the Singapore International Commercial Court (SICC) proceedings in 2017 and 2021 respectively. However, the prohibitions on ORFS remained.