Executive Summary

This case study examines Singapore’s response to inflammatory social media content posted by Zulfikar Mohamad Shariff, a former Singaporean citizen now residing in Australia. The case demonstrates Singapore’s multi-layered approach to combating online threats to social cohesion through legal frameworks including the Online Criminal Harms Act (OCHA) and the Maintenance of Religious Harmony Act (MRHA).


Case Background

The Individual

  • Name: Zulfikar Mohamad Shariff, 54 years old
  • Status: Former Singaporean, now Australian citizen
  • History: Detained under Internal Security Act (ISA) in 2016 for promoting terrorism and glorifying ISIS
  • Current Activity: Operating from Australia, making social media posts targeting Singapore’s racial and religious harmony

The Content

Zulfikar’s posts included:

  1. False discrimination claims (June 19, 2025, TikTok): Alleged Malay Muslims were forced to abandon Islam and assimilate into Chinese community
  2. Colonial settler narrative (July 18, 2025, Facebook): Claimed Chinese in Singapore were colonial settlers who oppressed Malays
  3. Election interference (April 24, 2025, Facebook): Posted under username “Zai Nal” criticizing Malay-Muslim MPs and attempting to influence voting patterns during 2025 General Election

Government Response

  • Account Restriction Direction issued to TikTok
  • Disabling Direction issued to Meta (Facebook)
  • Ongoing investigation of content on other platforms including X (Twitter)
  • Assessment: Content violates Maintenance of Religious Harmony Act

Problem Analysis

Core Issues

1. Transnational Digital Threats

  • Foreign actors operating beyond Singapore’s territorial jurisdiction
  • Use of multiple platforms to amplify divisive messaging
  • Exploitation of diaspora networks to influence domestic affairs

2. Racial and Religious Vulnerability

  • Singapore’s multi-ethnic society (Chinese 74%, Malay 14%, Indian 9%, Others 3%)
  • Historical sensitivities from 1964 and 1969 racial riots
  • Deliberate targeting of fault lines between communities

3. Platform Governance Challenges

  • Varying cooperation levels from social media companies
  • Content spreads faster than regulatory responses
  • Platform algorithms may amplify inflammatory content

4. Electoral Interference

  • Foreign actors attempting to manipulate democratic processes
  • Identity politics weaponized to suppress voter participation
  • Undermining trust in elected representatives

Risk Factors

Immediate Risks:

  • Erosion of trust between racial and religious communities
  • Potential for copycat behavior by other actors
  • Undermining confidence in government institutions

Long-term Risks:

  • Normalization of hate speech in online discourse
  • Radicalization of vulnerable individuals
  • Permanent damage to Singapore’s social fabric

Legal Framework and Impact

Primary Legislation Applied

1. Online Criminal Harms Act (OCHA) – Enacted February 2024

Purpose: Address criminal activities on online platforms affecting Singapore users

Key Provisions:

  • Authority to issue Account Restriction Directions
  • Authority to issue Disabling Directions
  • Requirement for platform compliance within specified timeframes
  • Penalties: Up to $1 million for non-compliance

Application in This Case:

  • First use against content threatening racial harmony
  • Demonstrates expanded scope beyond scams and fraud
  • Tests cross-border enforcement capabilities

2. Maintenance of Religious Harmony Act (MRHA)

Purpose: Prevent actions that promote feelings of enmity, hatred, ill-will or hostility between different religious or racial groups

Assessment:

  • Zulfikar’s content determined to incite hatred and ill-will
  • Applies even to foreign nationals targeting Singapore
  • Enables criminal investigation and prosecution

3. Internal Security Act (ISA)

Historical Context:

  • Previously used to detain Zulfikar in 2016 for terrorism-related activities
  • Demonstrates pattern of extremist behavior
  • Informs current risk assessment

Legal Impact and Precedents

Jurisdictional Expansion

  • Establishes Singapore’s willingness to pursue transnational actors
  • Sets precedent for holding platforms accountable for foreign-origin content
  • Signals to other potential bad actors operating offshore

Platform Accountability

  • Requires social media companies to act on government directions
  • Creates compliance obligations regardless of where content originates
  • May influence platform policies beyond Singapore

Electoral Protection

  • Demonstrates government will protect electoral integrity
  • Deters future foreign interference attempts
  • Provides template for action against election manipulation

Free Speech Boundaries

  • Reinforces that Singapore prioritizes social harmony over absolute free speech
  • Clarifies that foreign nationality does not provide immunity
  • Distinguishes between legitimate criticism and incitement

Enforcement Challenges

Technical Issues:

  • Content can be reposted on unregulated platforms
  • VPNs and proxy services can circumvent blocks
  • New accounts can be created after takedowns

International Dimensions:

  • Limited ability to prosecute individuals in foreign jurisdictions
  • Dependence on platform cooperation
  • Variation in international norms on speech regulation

Operational Gaps:

  • X (Twitter) not issued directions despite similar content
  • Time lag between posting and takedown
  • Difficulty monitoring private messaging channels

Outlook and Future Trajectory

Short-term (6-12 months)

Expected Developments:

  1. Expanded Platform Coverage: Likely issuance of directions to X and other platforms where Zulfikar maintains presence
  2. Increased Monitoring: Enhanced surveillance of foreign actors attempting to influence Singapore’s social discourse
  3. Public Awareness Campaigns: Government messaging to inoculate population against divisive narratives
  4. Legal Refinements: Potential amendments to OCHA based on lessons from early implementation

Potential Challenges:

  • Zulfikar may shift to encrypted platforms or alternative channels
  • International criticism regarding censorship and free speech
  • Resource strain on enforcement agencies
  • Copycat actors testing boundaries

Medium-term (1-3 years)

Strategic Shifts:

  1. Regional Cooperation: Partnerships with ASEAN nations on cross-border content regulation
  2. Platform Regulation Evolution: More comprehensive frameworks requiring proactive content moderation
  3. AI and Technology Integration: Automated detection systems for inflammatory content
  4. Civil Society Engagement: Empowering community organizations to counter divisive narratives

Emerging Trends:

  • Increased sophistication of bad actors using AI-generated content
  • Greater use of local proxies to avoid foreign actor designation
  • Potential for coordinated campaigns by multiple foreign entities
  • Evolution of tactics to exploit new platforms and technologies

Long-term (3-5 years)

Systemic Evolution:

  1. Comprehensive Digital Governance: Integrated framework covering all online harms with tiered response mechanisms
  2. International Norms Development: Singapore potentially leading regional standards for content regulation
  3. Enhanced Resilience: Population-level digital literacy and critical thinking capabilities
  4. Technology Solutions: Advanced AI systems for early detection and rapid response

Strategic Questions:

  • How to balance security with openness as an international hub?
  • Can Singapore influence global platform policies through regulatory leadership?
  • What role for civil society versus state action in maintaining harmony?
  • How to address increasingly sophisticated foreign influence operations?

Recommended Solutions

Immediate Actions (0-6 months)

1. Complete Platform Coverage

  • Issue directions to all platforms where Zulfikar maintains presence
  • Establish rapid-response protocols for new accounts
  • Coordinate with platforms for cross-platform tracking

2. Enhanced Public Communication

  • Launch targeted campaigns explaining dangers of racial/religious incitement
  • Provide factual counter-narratives to specific false claims
  • Empower community leaders as trusted messengers

3. International Engagement

  • Engage Australian authorities regarding individual residing in their jurisdiction
  • Explore extradition or prosecution options through mutual legal assistance
  • Build diplomatic pressure for action against transnational instigators

4. Victim Support

  • Provide resources for communities targeted by hate speech
  • Create channels for reporting and rapid response
  • Offer counseling and support services where needed

Medium-term Initiatives (6-18 months)

1. Legislative Enhancement

  • Review OCHA effectiveness and close loopholes
  • Consider penalties for individuals, not just platforms
  • Explore civil liability mechanisms for platform negligence

2. Technology Investment

  • Deploy AI-powered monitoring of public social media content
  • Develop natural language processing for Malay, Chinese, Tamil content
  • Create automated alert systems for potential violations

3. Platform Partnership Program

  • Establish formal cooperation agreements with major platforms
  • Create joint working groups on content moderation standards
  • Develop shared intelligence on bad actors

4. Education and Resilience Building

  • Integrate digital literacy into school curricula
  • Train civil servants and community leaders in recognizing manipulation
  • Support independent fact-checking organizations

5. Regional Coordination

  • Establish ASEAN working group on transnational online threats
  • Share intelligence on foreign actors targeting multiple countries
  • Develop mutual assistance protocols for enforcement

Long-term Strategic Framework (18 months – 5 years)

1. Comprehensive Online Safety Architecture

Legal Layer:

  • Unified legislation covering all online harms with proportionate responses
  • Clear definitions and bright-line rules for platform obligations
  • Swift administrative processes with judicial oversight

Technical Layer:

  • National content monitoring capability with privacy protections
  • Integration with international databases of known bad actors
  • Real-time detection and response systems

Social Layer:

  • Whole-of-society approach to maintaining racial and religious harmony
  • Empowered civil society organizations as first line of defense
  • Regular dialogue forums across communities

2. International Leadership Position

  • Position Singapore as thought leader in balanced online regulation
  • Host international conferences on digital governance
  • Develop model legislation for adoption by like-minded countries

3. Innovation in Governance

  • Regular review cycles for legislative frameworks
  • Experimentation with regulatory sandboxes
  • Evidence-based policymaking using data analytics

4. Sustainable Ecosystem

  • Support for local digital platforms adhering to high standards
  • Incentives for responsible platform behavior
  • Market access contingent on compliance with societal values

Key Success Factors

Critical Enablers

1. Political Will: Sustained commitment across government to prioritize social cohesion 2. Resource Allocation: Adequate funding for enforcement, technology, and education 3. Public Support: Maintaining legitimacy through transparent and proportionate action 4. Platform Cooperation: Constructive engagement with major social media companies 5. International Partnerships: Building coalitions with like-minded democracies 6. Adaptability: Remaining flexible as threats and technologies evolve

Performance Indicators

Effectiveness Metrics:

  • Time from violation to platform action (target: <24 hours)
  • Reduction in reports of inflammatory content
  • Public perception surveys on racial/religious harmony
  • Recidivism rates among violators
  • Platform compliance rates with government directions

Impact Metrics:

  • Number of individuals radicalized or influenced by online content
  • Cross-community trust indicators
  • Electoral participation rates in targeted communities
  • Media coverage sentiment analysis

Conclusion

The Zulfikar case represents a critical test of Singapore’s evolving digital governance framework. It demonstrates both the capabilities and limitations of current legal tools while highlighting the complex challenges of regulating transnational actors in an interconnected digital environment.

Success requires a multi-faceted approach combining:

  • Robust legal frameworks with clear enforcement mechanisms
  • Strategic platform partnerships based on shared responsibility
  • Proactive community engagement to build resilience
  • International cooperation to address cross-border dimensions
  • Continuous adaptation to emerging threats and technologies

Singapore’s response will likely influence regional approaches to online content regulation and may contribute to evolving international norms on balancing free expression with protection of social cohesion. The case underscores that in multiracial, multireligious societies, maintaining harmony in the digital age requires vigilance, innovation, and unwavering commitment to foundational values of mutual respect and understanding.

The ultimate measure of success will not be the number of accounts disabled or directions issued, but whether Singapore maintains its distinctive model of racial and religious harmony in an era of global digital connectivity and unprecedented information flows.


References

  • Online Criminal Harms Act 2024
  • Maintenance of Religious Harmony Act
  • Ministry of Home Affairs Public Statement, November 26, 2025
  • The Straits Times, “Police order TikTok, Facebook to disable ex-ISA detainee’s accounts over inflammatory posts,” November 26, 2025

POFMA and Censorship: Balancing Truth and Freedom in Singapore’s Digital Ecosystem

Executive Summary

The Protection from Online Falsehoods and Manipulation Act (POFMA), enacted in October 2019, represents Singapore’s legislative response to online misinformation. While positioned as a tool to combat fake news and protect public interest, POFMA has sparked intense debate about censorship, free speech boundaries, and democratic governance. This analysis examines POFMA’s relevance to the Zulfikar case, its role as a censorship mechanism, and the broader implications for Singapore’s information landscape.


Understanding POFMA: Framework and Function

Legislative Architecture

Enactment Timeline:

  • April 2017: Minister K. Shanmugam calls for review of fake news laws
  • January 2018: Parliament establishes Select Committee on Deliberate Online Falsehoods
  • May 8, 2019: POFMA passed with 72 votes (opposed by opposition parties)
  • October 2, 2019: Act comes into force
  • As of June 2024: 66 cases handled, 114 correction directions issued

Core Objectives: POFMA aims to protect the Singapore public against online harm by countering the proliferation of online falsehoods, while maintaining that original content remains accessible alongside government corrections.

Key Mechanisms

1. Correction Directions POFMA’s primary tools are correction directions which do not require the online falsehood to be removed. Instead, they mandate that a correction notice be displayed alongside the original post, allowing readers to view both versions.

Technical Process:

  • Minister identifies false statement of fact
  • POFMA Office issues correction direction
  • Recipient must post correction notice with link to government clarification
  • Original content remains visible but flagged
  • Failure to comply: Access blocking orders, fines, criminal penalties

2. More Severe Measures For serious cases, additional tools include:

  • Stop Communication Directions: Prevent further dissemination
  • Disabling Directions: Shut down accounts or pages
  • Access Blocking Orders: Block Singapore users from accessing non-compliant sites
  • Account Restriction Directions: Target fake accounts and bots

3. Criminal Penalties

  • Knowingly communicating falsehoods: Up to $50,000 fine and/or 5 years imprisonment
  • Using bots or fake accounts: Penalties doubled to $100,000 and/or 10 years
  • Creating bots for falsehoods: Up to $30,000 and/or 3 years imprisonment
  • Platform non-compliance: Up to $1 million fine

Public Interest Criteria

POFMA applies when false statements affect public interest in six areas:

  1. National security
  2. Public health and safety
  3. Financial integrity
  4. Foreign relations
  5. Election interference
  6. Inciting social tensions
  7. Diminishing public confidence in government

POFMA vs. OCHA: Complementary Frameworks in the Zulfikar Case

Why POFMA Was Not Used for Zulfikar

POFMA’s Limitations: While POFMA could theoretically apply to Zulfikar’s false claims (e.g., that Malay Muslims were forced to assimilate), the case reveals why OCHA was the more appropriate tool:

1. Nature of Content

  • POFMA focus: Individual false statements of fact that can be corrected
  • Zulfikar’s content: Systematic campaign of hate speech and incitement
  • Key difference: POFMA corrects; OCHA disables accounts for criminal harm

2. Severity of Threat

  • POFMA typically issues correction notices for misinformation
  • Zulfikar’s posts constituted criminal incitement under Maintenance of Religious Harmony Act
  • Pattern of extremist behavior (prior ISA detention) warranted stronger action

3. Operational Approach

  • POFMA allows content to remain visible with corrections
  • Zulfikar’s inflammatory rhetoric required complete removal due to harm potential
  • Foreign actor status with no intention to comply necessitated disabling rather than correcting

Strategic Complementarity

The Singapore government’s regulatory toolkit now includes:

FrameworkPrimary PurposeTypical ApplicationAction TypePOFMACombat false informationMisinformation, election claims, pandemic falsehoodsCorrection noticesOCHAAddress criminal online harmsScams, hate speech, serious threatsAccount restrictions, disablingMRHAMaintain religious harmonyReligious/racial incitementCriminal investigation

Why This Matters: The Zulfikar case demonstrates that Singapore views different online threats through different legal lenses. False information that misleads (POFMA territory) is treated differently from speech that incites hatred and threatens social cohesion (OCHA/MRHA territory).


The Censorship Debate: Examining the Criticisms

Core Criticisms

1. Ministerial Discretion and Arbitrary Power

Critics argue that the definitions of “fact” and “public interest” in POFMA are unclear or too all-encompassing and give far too broad a discretion to the Minister.

The Concern:

  • Any minister can unilaterally declare content false
  • No independent oversight before issuance
  • When it comes to legislation that allows the government to decide what is or isn’t a “false statement of fact”, there are few restraints on power
  • Appeals process exists but requires going to court after compliance

Pattern of Use: The first four applications of POFMA, all in November 2019, were targeted at opposition politicians and parties, leading to accusations of political targeting despite government claims of “unfortunate coincidence.”

2. Chilling Effect and Self-Censorship

It is argued that this would cause a “chilling-effect” on free speech in Singapore.

Manifestations:

  • Citizens may avoid political commentary for fear of POFMA action
  • Media outlets may self-censor to avoid correction notices
  • Difficulty distinguishing fact from opinion creates uncertainty
  • Satire and commentary become legally risky

Counter-Evidence: Anecdotally and based on the available statistics, it does not appear that the “chilling effect” to free speech predicted by critics has materialised. However, self-censorship is inherently difficult to measure.

3. Fact vs. Opinion Distinction

The line between factual statements and opinions remains contested:

Government Position:

  • Only false statements of fact are targeted
  • Opinions remain protected
  • Courts provide clarity on borderline cases

Critics’ Position:

  • Many government “corrections” involve interpretations or policy debates
  • Statistics can be presented differently without being “false”
  • Political claims often blend fact and opinion inseparably

4. Disproportionate Political Use

A count of POFMA directions leading up to and during Singapore’s 2020 general election suggests that most directions relate to the sixth condition — diminution of public confidence in government.

Timing Concerns:

  • POFMA was most frequently used in July 2020 during Singapore’s general elections, largely against speech critical of the PAP
  • Long periods without use despite ongoing misinformation
  • Questions about whether normal press clarifications would suffice

5. Cross-Border Overreach

In September 2023, an access blocking order was imposed on East Asia Forum for non-compliance with a correction direction, in a concerning sign that the law’s impact extends beyond national borders.

International Implications:

  • Foreign publications blocked in Singapore for non-compliance
  • Raises questions about jurisdictional legitimacy
  • Sets precedent for other countries to follow similar approaches

Government’s Defense

1. Factual Accuracy Over Opinion

Far from being matters of “interpretation of statistics” or “opinion of facts”, the statements corrected were all demonstrably factually false, according to government responses.

2. Preservation of Original Content

Unlike traditional censorship:

  • Original posts remain accessible
  • Corrections are additions, not deletions
  • Public can read both versions and judge for themselves
  • The correction directions allow for the false statement or publication to remain accessible online, alongside the correction notice

3. Public Safety Imperative

When lives depend on accurate information that needs to be out there urgently, philosophical debates about free speech become secondary to practical necessity.

COVID-19 Context:

  • Rapid correction of pandemic misinformation
  • Prevention of panic and resource waste
  • Protection of public health measures

4. Judicial Review Available

Neither the SDP nor any of those who have received Pofma directions have appealed the notices or taken the matter to court, suggesting either acceptance or calculated avoidance.

5. Effectiveness Evidence

A study conducted in 2023 found that POFMA has been effective in mitigating the risks arising from the spread of online falsehoods, which can undermine social cohesion.


Is POFMA Censorship? A Nuanced Analysis

Defining Censorship

Traditional Censorship:

  • Prior restraint on publication
  • Content removal or suppression
  • Punishment for expression
  • No avenue for the censored to respond

POFMA’s Model:

  • No prior restraint (content published first)
  • Content remains visible with corrections
  • Punishment for non-compliance, not original expression
  • Appeals process available

The Spectrum of Information Control

Where POFMA Sits:

Complete Freedom ←――――――――――――――――――――――――→ Total Censorship
                    ↑
        Traditional         POFMA        Content        State Media
        Journalism        Corrections    Removal         Monopoly

Arguments That POFMA Is Censorship:

  1. Functional Equivalence: Correction notices stigmatize content, achieving suppression through alternative means
  2. Practical Impact: Fear of POFMA creates self-censorship even without formal removal
  3. Power Imbalance: Government controls truth determination without independent verification
  4. Downstream Effects: Access blocking for non-compliance is traditional censorship
  5. Selective Targeting: Disproportionate use against government critics suggests political motivation

Arguments That POFMA Is Not Censorship:

  1. Content Preservation: The nature of correction directions is less intrusive than other censorship laws because original content remains visible
  2. Counter-Speech Model: Adds government voice rather than silencing private voice
  3. Public Benefit: Provides citizens with more information, not less
  4. Targeted Scope: Only applies to demonstrably false factual claims
  5. Democratic Legitimacy: Elected ministers make determinations on behalf of public interest

The Reality: Hybrid Information Control

POFMA represents a third-way approach that doesn’t fit neatly into traditional censorship/free speech categories:

Innovative Aspects:

  • Recognizes danger of false information in digital age
  • Attempts to balance correction with preservation
  • Provides transparency through public correction notices
  • Maintains some accountability through appeal process

Concerning Aspects:

  • Over-reliance on POFMA affects the ability of Singaporean society to process information and believe that the government makes decisions with their interest in mind
  • Ministerial power without independent oversight
  • Potential for political abuse in competitive elections
  • Global precedent for authoritarian governments

POFMA’s Relevance to the Zulfikar Case

Why POFMA Was Not the Primary Tool

1. Nature of Violations

AspectPOFMA TerritoryZulfikar's ContentTypeFalse factual claimsSystematic hate speechIntentMisinformationDeliberate incitementLegal FrameworkPOFMAMRHA + OCHAAppropriate ResponseCorrectionAccount disabling

2. Historical Context

Zulfikar’s 2016 ISA detention for terrorism-related activities demonstrated he was not someone who would comply with correction notices or engage in good faith discourse.

3. Foreign Actor Status

  • Operating from Australia with no intention to return to Singapore
  • No practical enforcement mechanism for correction compliance
  • Required platform-level intervention (disabling) rather than individual-level correction

4. Severity of Harm

Zulfikar’s posts incite feelings of enmity, hatred, ill-will and hostility between different racial and religious groups — this crosses from misinformation into criminal incitement.

What POFMA Could Have Addressed

Had the content been different, POFMA might have been appropriate for:

  • False statistical claims about discrimination
  • Misleading interpretation of government policies
  • Incorrect historical facts about Singapore’s founding

Example Scenario: If Zulfikar had simply posted: “85% of Malay Muslims in Singapore report experiencing discrimination” (a false statistic), POFMA would be ideal — a correction notice could provide accurate data while leaving the post visible.

Actual Content: “The Chinese in Singapore are colonial settlers who have oppressed Malays” — this is inflammatory rhetoric designed to incite ethnic hatred, not a factual error requiring correction.

OCHA as the Appropriate Tool

OCHA’s broader scope for “criminal online harms” provided:

  • Authority to disable accounts spreading hate speech
  • Recognition that some content is too dangerous for “correction plus preservation”
  • Alignment with MRHA’s criminal investigation framework
  • Platform accountability for hosting harmful content

Broader Implications: The Censorship Ecosystem

Singapore’s Layered Information Control

Legislative Framework:

  1. Sedition Act (1948): Criminalize speech causing ill-will between races
  2. Internal Security Act (1963): Detention for national security threats
  3. Maintenance of Religious Harmony Act (1990): Prevent religious/racial incitement
  4. Public Order Act (2009): Restrict assemblies including online organizing
  5. POFMA (2019): Combat online falsehoods
  6. OCHA (2024): Address criminal online harms

Cumulative Effect: Singapore is rated as ‘repressed’ by the CIVICUS Monitor with concerns about restrictive laws used to criminalize criticism.

International Precedent and Spillover

Countries Following Singapore’s Model:

Nigeria: Proposed nearly identical fake news legislation Philippines: Anti-False Content Bill bearing remarkable similarity to POFMA Regional Trend: With the rise of misinformation worldwide, the design and use of POFMA in Singapore has deep implications beyond its borders

Concern: Anxieties about disinformation and misinformation are going global, but so is the practice of capitalising on these anxieties to consolidate power.

Platform Cooperation and Resistance

Facebook/Meta’s Response:

  • Initially reluctant but ultimately complied
  • “Facebook is legally required to tell you that the Singapore government says that this post has false information” — language emphasized compulsion rather than agreement
  • Hoped for “measured and transparent approach”

Other Platforms:

  • Google, TikTok: Complied with directions
  • Twitter/X: Initially more resistant, now subject to various orders
  • Smaller platforms: Face access blocking for non-compliance

Asia Sentinel Case Study: The publication was blocked in Singapore after refusing to comply with correction direction, choosing to print both Singapore’s demand and their refusal rather than just the correction — demonstrating platform resistance and consequences.


Critical Assessment: Does POFMA Serve Its Purpose?

Evidence of Effectiveness

Positive Indicators:

  1. Social Cohesion Protection: POFMA has been effective in mitigating the risks arising from the spread of online falsehoods, which can undermine social cohesion
  2. COVID-19 Response: Rapid correction of pandemic misinformation helped maintain public health measures
  3. Election Integrity: Prevention of vote-rigging claims and false electoral information
  4. Documented Cases: 114 correction directions across 66 cases demonstrate active use

Concerning Indicators:

  1. Political Targeting: Disproportionate use against opposition politicians raises legitimacy questions
  2. Trust Erosion: The proliferation of POFMA directions might undermine confidence that the Singaporean government acts in the public’s best interest
  3. International Criticism: Access blocking of foreign publications damages Singapore’s reputation
  4. Lack of Appeals: No significant court challenges suggest either acceptance or fear of legal costs

Unintended Consequences

1. Normalization of Government Truth Determination

When government routinely declares what is true/false, citizens may:

  • Defer critical thinking to authorities
  • Become skeptical of all official information
  • Seek information from unregulated channels

2. Legitimizing Authoritarian Models

Singapore’s success with POFMA encourages less democratic governments to adopt similar tools without Singapore’s:

  • Relatively clean governance
  • Independent judiciary
  • Educated populace
  • Strong civil society (albeit constrained)

3. Creating Information Silos

Access blocking of non-compliant foreign sites:

  • Reduces exposure to diverse perspectives
  • Encourages VPN use and circumvention
  • Signals to international observers that Singapore fears open debate

4. Resource Allocation

Heavy reliance on top-down correction diverts resources from:

  • Media literacy education
  • Supporting independent fact-checking
  • Strengthening democratic institutions
  • Building resilient civil society

Alternative Models: Learning from Other Jurisdictions

The European Approach

Digital Services Act (EU):

  • Platform responsibility without government truth determination
  • Independent oversight boards
  • Transparency requirements
  • Due process protections

Advantages:

  • No single government actor as arbiter
  • Multi-stakeholder governance
  • Emphasizes platform accountability

Disadvantages:

  • Slower implementation
  • Resource-intensive
  • May not address urgent threats

The American Model

First Amendment Protections:

  • Minimal government intervention
  • Marketplace of ideas theory
  • Counter-speech rather than censorship

Advantages:

  • Robust free speech protection
  • Innovation-friendly
  • Democratic legitimacy

Disadvantages:

  • Slow response to urgent falsehoods
  • Vulnerable to coordinated disinformation
  • Relies on informed citizenry

Taiwan’s Approach

Collaborative Fact-Checking:

  • Government partnerships with civil society
  • Humor and creative counter-narratives
  • Digital literacy programs
  • Transparent government communication

Advantages:

  • Builds societal resilience
  • Maintains democratic values
  • Encourages civic participation

Disadvantages:

  • Requires high trust in institutions
  • Time and resource intensive
  • May not work in all cultural contexts

Singapore’s Distinctive Context

Why Singapore Differs:

  1. Size and Demographics: Small, densely populated, multi-ethnic society where rumors spread quickly
  2. Historical Trauma: 1964 and 1969 racial riots create existential sensitivity to communal tensions
  3. Political System: Single-party dominance since 1965 shapes governance expectations
  4. Cultural Factors: Greater acceptance of paternalistic government
  5. Geopolitical Position: Vulnerable to foreign interference as regional hub

Implications: Singapore’s model reflects local imperatives but may not translate well internationally. The question is whether POFMA represents:

  • Pragmatic adaptation to Singapore’s unique challenges, or
  • Convenient rationalization for authoritarian information control

Recommendations: Enhancing POFMA’s Legitimacy

Short-term Reforms (0-12 months)

1. Enhanced Transparency

  • Publish detailed criteria for each POFMA direction
  • Include clear explanation of public interest determination
  • Release quarterly reports with statistics and analysis
  • Make all correction notices and government clarifications searchable

2. Pre-Issuance Process

  • Increase reliance on first issuing letters to invite a removal or correction of the false online publication before formal directions
  • Provide 24-hour notice period for subjects to respond (except urgent cases)
  • Document reasons for skipping preliminary steps

3. Expedited Appeals

  • Streamline court procedures
  • Subsidize legal costs for genuine appeals
  • Publish all appeal outcomes
  • Allow interim suspension of corrections pending appeal

4. Independent Review

  • Establish advisory panel of retired judges, academics, media professionals
  • Panel reviews directions post-issuance
  • Publish non-binding recommendations
  • Annual report to Parliament

Medium-term Reforms (1-3 years)

1. Legislative Refinement

  • Narrow “public interest” definitions
  • Clarify fact/opinion distinction in statute
  • Establish clearer thresholds for severity
  • Create tiered response system

2. Institutional Separation

  • Move POFMA authority from individual ministers to independent commission
  • Require multi-member approval for directions
  • Include non-government members in commission
  • Maintain elected accountability through parliamentary oversight

3. Digital Literacy Investment

  • Mandatory media literacy in schools
  • Public education campaigns on identifying falsehoods
  • Support for independent fact-checking organizations
  • Community-based verification networks

4. Platform Partnership

  • Formal agreements with major platforms
  • Joint working groups on definitions and standards
  • Shared responsibility for addressing falsehoods
  • Graduated escalation protocols

Long-term Vision (3-5 years)

1. Sunset and Review

  • Build in 5-year sunset clause requiring re-authorization
  • Comprehensive independent review before renewal
  • Public consultation process
  • Evidence-based assessment of effectiveness

2. Regional Harmonization

  • Work with ASEAN partners on common standards
  • Avoid regulatory arbitrage and race-to-bottom
  • Share best practices and lessons learned
  • Build regional consensus on information integrity

3. Cultural Shift

  • Move from government-as-arbiter to society-as-resilient
  • Emphasize citizen capability over state control
  • Support independent media ecosystem
  • Foster culture of evidence-based discourse

4. Democratic Strengthening

  • Ensure POFMA never substitutes for political accountability
  • Maintain space for robust policy criticism
  • Protect satire, commentary, and opinion
  • Recognize that healthy democracy includes uncomfortable speech

Conclusion: The Paradox of POFMA

POFMA embodies a fundamental paradox: it seeks to protect democratic discourse by giving government expansive powers over information flows. This creates inherent tensions:

The Case For POFMA

  • Real Threat: Online falsehoods genuinely threaten social cohesion, public health, and democratic integrity
  • Speed Imperative: Traditional responses too slow for viral misinformation
  • Balanced Design: Correction model more measured than outright censorship
  • Demonstrated Results: Evidence of effectiveness in maintaining social harmony

The Case Against POFMA

  • Power Concentration: Excessive ministerial discretion without independent oversight
  • Political Weaponization: Pattern of use against opposition and critics
  • Chilling Effects: Self-censorship and risk-aversion in public discourse
  • Authoritarian Precedent: Model adopted by less democratic regimes globally

The Zulfikar Connection

The Zulfikar case reveals POFMA’s limitations and the need for complementary tools:

  • POFMA appropriate for factual misinformation requiring correction
  • OCHA/MRHA necessary for criminal incitement and hate speech
  • Different online harms require different regulatory responses
  • One-size-fits-all approach insufficient for complex digital landscape

Final Assessment

More than suppressing free speech, POFMA affects the ability of Singaporean society to process information and believe that the government makes decisions with their interest in mind.

The Core Question: Is POFMA a necessary tool for protecting a vulnerable multiracial society from existential information threats, or does it represent an overcorrection that undermines the very democratic values it purports to protect?

The Uncomfortable Answer: Both may be true simultaneously. Singapore’s unique context may justify stronger information controls than many democracies would accept, but this doesn’t make POFMA immune from criticism or improvement.

Moving Forward:

The challenge is evolution, not elimination. POFMA must:

  1. Demonstrate Restraint: Use power judiciously, not maximally
  2. Build Trust: Through transparency, consistency, and accountability
  3. Enable Oversight: Accept independent review and genuine appeals
  4. Complement Society: Support rather than substitute for citizen resilience
  5. Adapt Continuously: Remain responsive to changing threats and technologies

Singapore’s information integrity framework, including POFMA and OCHA, will be judged not by the powers it contains but by the wisdom with which those powers are exercised. In the digital age, the line between protecting citizens from harm and protecting governments from criticism remains perilously thin.

The Zulfikar case shows that serious threats exist and demand serious responses. The POFMA debate shows that those responses must themselves be subject to scrutiny, refinement, and democratic accountability. Both truths must be held in tension as Singapore navigates an increasingly complex and contested information landscape.


References

  1. Protection from Online Falsehoods and Manipulation Act 2019
  2. Online Criminal Harms Act 2024
  3. POFMA Office, Singapore Government
  4. Centre of Excellence for National Security (CENS) POFMA Effectiveness Study, 2023
  5. CIVICUS Monitor Singapore Assessment
  6. Ministry of Home Affairs Public Statements on Zulfikar Case
  7. East Asia Forum, various articles on POFMA implementation
  8. Academic analyses from Democratic Erosion, RSIS, and Stanford WilMap databases