After several other case studies on sovereignty protection in the UK or the EU, I will examine “the Lion City” also known as Singapore dealing with foreign interference. The city-state is a special case because, although it is no longer part of the British Empire, it is still greatly influenced by Anglo-Saxon legal culture and thinking. Despite this fact, in this occasion the Singaporean regulation was mostly affected by the US and Australian approach because the UK regulation was enacted later in 2023. In the following, I will describe how the Singaporean government acts against foreign influence.

A Brief History

The history of Singapore since its independence is often characterized as a “miracle” of rapid development, transitioning from a resource-poor island to a global financial hub within a single generation. This trajectory was defined by a strong central government, strategic economic planning, and a pragmatic approach to survival.

Singapore’s path to independence from the British was not a direct one. In 1963, it joined the Federation of Malaysia to gain independence from colonial rule. However, deep-seated political and racial tensions led to a painful expulsion. In 1965, Singapore became a sovereign nation.

Facing a lack of natural resources and a tiny domestic market, meanwhile the population was divided by language, culture and faith, the new country faced immediate threats to its economic viability and national security. Under the leadership of the People’s Action Party (PAP), Singapore adopted a unique economic model: inviting foreign direct investment (FDI) and multinational corporations (MNCs) to use the island as a manufacturing base. The Economic Development Board (EDB), established in 1961, became the engine of this growth. The government invested heavily in infrastructure and education to create a disciplined, English-speaking workforce.

By the 1970s, Singapore had solved its unemployment crisis and began shifting toward high-value industries like electronics. In 1990, Lee Kuan Yew stepped down, passing the premiership to Goh Chok Tong, who was later succeeded by Lee Hsien Loong in 2004. This era was marked by a shift from labour-intensive manufacturing to a knowledge-based economy. Singapore successfully navigated major global crises, including the 1997 Asian Financial Crisis and the 2008 Global Recession, by maintaining high fiscal reserves and a flexible labour market.

Today, Singapore is one of the wealthiest nations per capita, yet it faces 21st-century hurdles: an aging population, rising costs of living, and the complexities of maintaining neutrality in an era of US-China geopolitical tension, that is riddled with possibilities of foreign influence and interference on both sides of the conflict.

Foreign Influence in the 21st Century

In the digital age, new forms of foreign influence have emerged that aim to destabilize public opinion, elections, and state sovereignty. In response to this challenge, Singapore passed the Foreign Interference Countermeasures Act (FICA) in October 2021, which aims to curb foreign-led information campaigns and political influence. The law is particularly significant in a multi-ethnic city-state with an open economy such as Singapore, where foreign policy sensitivity and social cohesion are both values that need to be protected.

Political and Legal Foundations

The need to combat foreign influence first appeared in Singaporean political discourse in 2019, when the Ministry of Home Affairs (MHA) first raised concerns about online influence campaigns and covert foreign sources of political funding. The government cited the experiences of the United States, Australia, and other countries, where foreign actors attempted to influence political processes through covert funding, fake profiles, and digital platforms.

The bill was submitted to Parliament in September 2021 and passed on October 4, 2021. The most important provisions of the law came into force in 2022 and 2023. The Minister of Home Affairs, K. Shanmugam, argued that “Singapore’s internal affairs should be determined solely by Singaporeans,” and that the purpose of the law is to ensure this.

The Key Components of FICA

This legislation represents a significant pivot in Singapore’s legal landscape, aimed at preventing, detecting, and disrupting foreign entities’ attempts to influence domestic politics through “hostile information campaigns” (HICs).

FICA authorizes the Minister of Internal Affairs to impose various measures against campaigns conducted online and directed from abroad such as:

• Technical assistance instructions: digital platforms, internet service providers, and content providers may be required to hand over data (e.g., IP addresses, traffic data) or provide access to system information necessary for investigation.
• Content removal or blocking orders: allow the government to remove or block access to specific content.
• Suspension of user accounts: temporary or permanent suspension of accounts suspected of participating in foreign campaigns.

If a platform repeatedly fails to comply with these orders, it may be designated as a Proscribed Online Location (POL), and supporting, promoting, or financing it will be considered a criminal offense.

Politically Significant Persons (PSPs)

The law classifies individuals and organizations that may have a significant influence on public opinion or political processes into separate categories. FICA defines two categories:

• Defined PSPs: for example, politicians, election candidates, campaign agents, party officials.
• Designated PSPs: individuals or organizations designated by a competent authority (appointed by the Minister for Home Affairs), at its discretion, as having significant influence on political discourse and not falling into the other category.

These PSPs must disclose their links to foreign entities and report any donations or “pro bono” services received from non-Singaporean sources. The countermeasures on defined and designated PSPs cover the following vectors of foreign interference – donations, volunteers, leadership, membership, and affiliations. If there are increased risks of foreign interference, the competent authority can issue stepped-up countermeasures to the defined or designated PSPs.

PSPs are subject to the following obligations:

• They must disclose foreign contributions if their value exceeds 10,000 Singaporean dollars.
• They must report foreign connections, including contributions, travel, and positions held.

Under FICA, PSPs must disclose their involvement in a public registration system. The Registrar of Foreign and Political Disclosures is supported by the Registry of Foreign and Political Disclosures (RFPD), which is part of the Ministry of Home Affairs. RFPD assists the Registrar to administer the reporting requirements under FICA for PSPs, except for election candidates and election agents. 

The competent authority for all FICA-PSP matters, except with respect to election candidates and election agents, is the Registrar of Foreign and Political Disclosures, Ministry of Home Affairs. The Registrar of Foreign and Political Donations is the competent authority that administers the reporting requirements under FICA for election candidates and election agents during Presidential or Parliamentary elections.

The law came into effect in Singapore in July 2022. Its first significant application took place in February 2024, when businessman Philip Chan was designated as a PSP because, according to the authorities, he could exert political influence through his connections with foreign actors.

Criticism

In July 2024, the government also issued account restriction orders against five platforms—Facebook, Instagram, TikTok, X (formerly Twitter), and YouTube—affecting 95 accounts. The authorities considered the individuals behind the accounts to be participants in foreign influence campaigns. In the face of these actions, opposition rose against the measures.

Opponents of FICA frequently argue that the law uses overly broad definitions, particularly of the terms “foreign principal” and “foreign influence”. Another concern is that under FICA, many ministerial decisions are not subject to standard judicial review. Instead, appeals are heard by an independent Reviewing Tribunal, chaired by a High Court Judge. Critics argue that this limits the role of the judiciary in checking executive power.

Human rights organizations such as Human Rights Watch and Amnesty International warn that the law could also be used to intimidate political opponents, journalists, and civil society organizations.

Conclusions

The primary driver for FICA was the vulnerability of a multi-ethnic, highly digitized city-state to external subversion. The Singaporean government argues that traditional laws are insufficient to tackle the speed and scale of modern disinformation.

FICA is definitely a ground-breaking regulation in the field of digital protection against foreign influence. There is no doubt that covert campaigns in the online space pose a real threat to state sovereignty, and other states are also seeking solutions to this problem. At the same time, the law’s broad scope for discretion, limited judicial control, and impact on civil liberties have sparked serious debate. The key question for the coming years will be how the law is implemented in practice: does it really serve to protect against influence, or does it act as a deterrent against critical voices?

Singapore’s regulations are also unique because, in addition to the registration requirement, they also regulate online political advertisements and content. Media platform regulation is also an important issue in the EU, but it is entrusted to bodies that are independent of the government or have a high degree of autonomy. The goal is clearly shared and justifiable, but the institutional implementation differs significantly between Anglo-Saxon countries and the EU.

Compared to Anglo-Saxon countries, Singaporean regulations show some similarities, in that political transparency is also the goal here, which is achieved through a registration system like that in the US or Australia. Both FARA and FITS influenced the FICA Act, based on its circumstances and wording. Singaporean regulations similarly impose severe penalties for failure to register, etc. The significant difference lies in how different the legal and political system of the ‘Lion City’ actually is, within which this system was created in the moment of awakening to new dangers. Singapore a highly centralized state with a different state structure than most Anglo-Saxon states, which is why there are more (but similar) concerns about this regulation and its practical implementation.

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Gergely Kerkovits is a law graduate and PhD student of the Péter Pázmány Catholic University in Budapest. He is writing his doctoral dissertation on the relationship between civil society organizations and the state. His research focuses on freedom of association, sovereignty protection, public consultation, fundamental rights protection in international organizations. He is also a junior researcher of the MCC Public Law Center and intern at the Constitutional Court of Hungary.