This article is part of a five-part series co-sponsored by OneTrust. The full series can be accessed here.
Published: February 2024
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Though Singapore does not have any regulations specific to the governance of AI, nor a dedicated agency for AI governance, it does have a variety of relevant sectoral and voluntary frameworks as well as binding regulation in other domains — such as data protection and online safety. Moreover, the development, integration and responsible governance of AI is a strategic priority across Singaporean policymaking, putting into action the country's motto: onward Singapore.
History and context
Singapore is a country located at the southern tip of the Malay Peninsula. Frequently appearing on maps as a mere red dot, its land area is smaller than New York City's, and it has few natural resources. In order to grow and thrive, Singapore has to attract investments. It has done this by offering a pro-innovation and pro-business environment, strong digital infrastructure, and a highly skilled talent pool.
Tortoise Media's June 2023 Global AI Index, which benchmarks nations on their level of investment, innovation and implementation of AI, ranks Singapore at third place, below the U.S. and China. Tortoise Media commented that Singapore had made "huge advancements through explicit government efforts aimed at boosting AI across innovation, research, and human capital." Further growth in AI is expected following the Singapore government's 16 Feb. announcement that it will invest over SGD1 billion over the next five years into AI compute, talent and industry development.
In 2019, the Singapore government published its first National AI Strategy, outlining plans to drive AI innovation and adoption across the economy and to deliver strong social and economic impact for Singapore. An updated strategy, NAIS 2.0, was launched December 2023 to address recent challenges and uplift Singapore's economic and social potential over the next three to five years. Both strategies were designed and overseen by the Smart Nation and Digital Government Group, which is part of the prime minister's office and is administered by the Ministry of Communications and Information.
NAIS 2.0 seeks to achieve two goals: to advance the field of AI and maximize value creation, and to empower individuals, businesses and communities to use AI with confidence, discernment and trust. It says the Singapore government will support experimentation and innovation while ensuring AI is developed and used responsibly, in line with the rule of law and existing safeguards. Under Action 13, Singapore will regularly review and adjust frameworks to reflect emerging principles, concerns and technological developments, and consider updates to broader standards and laws to support effective AI use.
To achieve these goals, the Singapore government has committed to fifteen actions:
- Anchor new AI Centres of Excellence in Singapore-based companies to conduct value creation activities across the AI stack and explore establishing sectoral AI CoEs to drive sophisticated AI value creation and usage in key sectors.
- Strengthen Singapore's AI startup ecosystem, including attracting AI-focused accelerator programs to spur rapid AI experimentation.
- Accelerate public sector adoption of AI to unlock new value propositions for citizens.
- Update national AI research and development plans to sustain leadership in select research areas, e.g., expanding international research collaboration in areas aligned with Singapore's research priorities.
- Attract world-class AI creators to work from and with Singapore.
- Boost the AI practitioner pool to 15,000.
- Intensify enterprise AI adoption for industry transformation by promoting baseline digital adoption for enterprises and providing tailored support for AI-enabled business transformation.
- Upskill the workforce through sector-specific AI training programs.
- Establish a dedicated physical place for AI to co-locate AI creators and practitioners and to nurture the AI community in Singapore.
- Significantly increase high-performance compute available in Singapore.
- Build capabilities in data services and privacy-enhancing technologies.
- Unlock government data for use cases that serve the public good.
- Maintain a pro-innovation regulatory environment for AI while ensuring appropriate guardrails.
- Raise the security and resilience baseline for all system owners using AI.
- Establish Singapore as an ambitious and pragmatic international partner on AI innovation and governance.
Singapore's approach to AI governance regulation
Singapore appears to be taking a sectoral approach toward AI governance regulation. The regulatory agencies that have made moves so far have all adopted soft-law approaches, preferring to issue nonbinding guidelines and recommendations.
Financial services
The Monetary Authority of Singapore, Singapore's central bank and integrated financial regulator, was the first sectoral regulator to take action on AI governance regulation. In 2018, MAS and the financial industry created a set of principles focusing on fairness, ethics, accountability and transparency to guide the responsible use of AI.
In 2019, MAS announced it was working with financial industry partners to create the Veritas framework to provide financial institutions with a verifiable way to incorporate the FEAT principles into their AI and data analytics-driven solutions.
The FEAT principles and Veritas are part of Singapore's National AI Strategy, designed to help build a progressive and trusted environment for AI adoption within the financial sector.
Info-communications and media sectors
The Info-communications Media Development Authority and Personal Data Protection Commission have been the most active regulators in AI governance regulation, launching guidelines or initiatives every year since 2019. The IMDA is a statutory board that develops and regulates the info-communications and media sectors. The PDPC is Singapore's main authority in matters relating to personal data protection.
In 2019, the IMDA and the PDPC launched the first edition of the Model AI Governance Framework at the World Economic Forum Annual Meeting in Davos. The Model Framework aims to provide private sector organizations with readily implementable guidance on key ethical and governance issues when deploying AI solutions.
Just a year later, in 2020, the IMDA and PDPC updated the Model Framework, launching the second edition together with an Implementation and Self-Assessment Guide for Organisations, which aims to help organizations assess the alignment of their AI governance practices with the Model Framework, and a Compendium of Use Cases, which illustrates how organizations implemented accountable AI governance practices, and aligned AI governance practices with the Model Framework.
In 2022, the IMDA launched AI Verify, an AI governance testing framework and software toolkit that validates the performance of AI systems against a set of internationally recognized principles through standardized tests.
In mid-2023, Singapore's Minister for Communications and Information announced the launch of the AI Verify Foundation to support the development and use of AI Verify. Around the same time, an IMDA director said the authority was not looking at regulating AI then, but might introduce regulation later.
Health sector
In October 2021, the Ministry of Health published the AI in Healthcare Guidelines to support patient safety and improve trust in the use of AI in health care. These guidelines were co-developed with the Health Sciences Authority and the Integrated Health Information Systems, now known as Synapxe, and complemented HSA's regulations of AI medical devices.
Although Singapore does not have binding regulations specific to AI, there are numerous laws of relevance and application to various elements of the AI governance lifecycle.
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Data protection
The Personal Data Protection Act governs the collection, use, disclosure and care of personal data in Singapore. It provides a baseline standard of protection for personal data and complementing sector-specific regulatory provisions, such as those found in the Banking Act and Insurance Act. In 2023, the PDPC released draft advisory guidelines on the use of personal data in AI recommendation and decision systems for public consultation. The advisory guidelines provide guidance on how the PDPC will interpret the PDPA, so even though they are not legally binding, organizations view them as instruments that should be complied with. It is anticipated the finalized advisory guidelines will be issued in the first half of 2024.
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Copyright
The Copyright Act protects the expression of ideas in tangible form, so long as the work is original, i.e., not copied. Similar to the U.S., and unlike the U.K., the work must also have been created by an identifiable human author. Copyright infringement occurs when a copyright owner's rights are violated, which can occur when copyrighted work is copied, distributed, performed or displayed without the copyright owner’s permission. An exception, known as "fair dealing," permits the use of nonsubstantial parts of copyrighted work for study or research. The wilful infringement of copyright is also a criminal offense if it is significant and the infringer commits the infringement to obtain a commercial advantage. Regarding AI specifically, source codes, AI algorithms and data compilations including databases, may be protected by copyright. At this point it is unclear if the fair dealing exception can apply to the use of copyrighted works for training AI models.
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Online safety
In 2022, the Online Safety (Miscellaneous Amendments) Bill was passed to enhance online safety for Singapore users. Providers of "online communication services," i.e., electronic services that allow Singapore users to access or communicate content via the internet with significant reach or impact, must comply with the Codes of Practice issued by IMDA. So far, this new rule only covers social media services, and IMDA has issued one Code of Practice for online safety. The amendments also empower IMDA to issue directions to deal with specified "egregious content" that can be accessed by Singapore users.
The Online Criminal Harms Act, passed in 2023, enables the Singapore government to deal more effectively with online activities that are criminal in nature.
A Centre for Advanced Technologies in Online Safety was established in April 2023 by the Agency for Science, Technology and Research to host research on technological capabilities to combat online harm, including tools and measures to detect deepfakes and nonfactual claims, inject watermarks, trace the origin of digital content, and help vulnerable groups verify information they encounter online.
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Antidiscrimination
All employers in Singapore are expected to adhere to the Tripartite Guidelines on Fair Employment Practices, which contain principles of fair employment practices, for example, that employers must recruit and select employees on the basis of merit, such as skills, experience or ability to perform the job, and regardless of age, race, gender, religion, marital status and family responsibilities, or disability.
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International cooperation on AI
Under NAIS 2.0, as part of establishing Singapore as an international partner for AI innovation and governance, the Singapore government wants to continue growing its international networks with key partner countries and leading AI companies.
So far, half of Singapore's digital economy agreements contain AI modules promoting the adoption of ethical governance frameworks for AI and, where appropriate, the alignment of governance and regulatory frameworks. The intention is to align with foreign partners on a common set of AI governance and ethics principles so compliance by organizations is more easily achievable and less burdensome.
The U.S. National Institute of Standards and Technology and IMDA published a crosswalk in October 2023, mapping the NIST's AI Risk Management Framework 1.0 to AI Verify. IMDA said this joint effort signaled both parties' common goal of balancing AI innovation and maximizing the benefits of AI technology while mitigating technology risks.
In November 2023, Singapore's prime minister participated in the AI Safety Summit organized by the U.K. at Bletchley Park. Together with 28 other economies, Singapore signed the Bletchley Declaration, agreeing to work together to prevent "catastrophic harm, either deliberate or unintentional," which may arise from AI computer models and engines.
Singapore is not a member of the Organisation for Economic Co-operation and Development but was invited to take part in its Expert Group on AI. Singapore is a founding member of the Global Partnership on AI, an international initiative to promote responsible AI use that respects human rights and democratic values.
In January 2024, the IMDA issued the Proposed Model AI Governance Framework for Generative AI and launched the Generative AI Evaluation Sandbox with Enterprise Singapore, a government agency championing enterprise development, in early February.
The proposed framework was developed with the AI Verify Foundation. It "seeks to set forth a systemic and balanced approach to address generative AI concerns while continuing to facilitate innovation."
There are nine dimensions in the proposed framework that IMDA says must be looked at in totality to foster a trusted ecosystem:
- Accountability.
- Quality data and addressing potentially contentious training data in a pragmatic way.
- Trusted development and deployment by enhancing transparency and disclosure.
- An incident-management system for timely notification and remediation.
- Third-party testing against common AI testing standards.
- Security.
- Transparency about where content is from.
- Global cooperation among AI safety research and development institutes.
- "AI for Public Good," i.e., harnessing AI to benefit the public by democratizing access, improving public sector adoption, upskilling workers and developing AI systems sustainably.
Though ostensibly targeted at generative AI, the nine dimensions in the proposed framework will be of interest to those following and tracking:
- The implementation of NAIS 2.0 regarding AI governance regulation. For instance, dimension nine adopts part of NAIS 2.0's vision to "achieve AI for the Public Good, for Singapore and the World."
- The development of the broader AI governance ecosystem in Singapore. The nine dimensions could just as easily apply to AI in general, raising the question of what kind of impact or relationship the proposed framework will have on future AI governance regulation.
The Generative AI Evaluation Sandbox is not directly linked to the proposed framework but is an initiative that the IMDA launched with EnterpriseSG to support companies in gaining hands-on experience with generative AI solutions. How it works: 13 generative AI solutions will be onboarded to the sandbox by the end of February 2024. Local small- and medium-sized enterprises selected to participate in the sandbox will receive grant support to trial a solution of their choice for three months. When the sandbox concludes, IMDA and EnterpriseSG will review the SMEs' feedback to evaluate the solutions and consider scaling the adoption of generative AI applications across local SMEs.
Additional resources
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General AI resources
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Privacy and AI governance resources
Global AI Governance Law and Policy: Jurisdiction Overviews
The overview page for this series can be accessed here. The full series is additionally available here in PDF format.