Singapore's AI frameworks guide AI ethical and governance principles, with existing sector-specific regulations addressing AI risks.

Laws/Regulations directly regulating AI (the “AI Regulations”)

Currently, there are no specific laws, statutory rules, or regulations in Singapore that directly regulate AI.

To strike a balance between allowing innovation in AI to develop, and safeguarding public interest in AI ethics and governance, the Singapore government has developed various frameworks and tools to guide AI deployment and promote the responsible use of AI, including:

• The Model AI Governance Framework¹ (2019, updated in 2020) (2020 Framework), which provides detailed guidance to private sector organizations to address key ethical and governance issues when deploying AI solutions
• AI Verify², an AI governance testing framework and toolkit designed to help organizations validate the performance of their AI systems against AI ethics principles through standardized tests. AI Verify was developed by the Infocomm Media Development Authority of Singapore (IMDA) in consultation with private sector organizations. IMDA has also set up the AI Verify Foundation (AIVF), a not-for-profit foundation to crowd in expertise from private sector organizations and the global open-source community to develop AI testing frameworks, standards and best practices
• The National Artificial Intelligence Strategy 2.0³ (first launched in 2019, updated in 2023) (NAIS 2.0), which outlines Singapore’s ambition and commitment to building a trusted and responsible AI ecosystem, driving innovation and growth through AI, and empowering its people and businesses to understand and engage with AI

In light of recent advances in generative AI, the AIVF and IMDA have also developed a draft Model AI Governance Framework for Generative AI⁴ (2024 Framework), which seeks to expand on the 2020 Framework by addressing new issues that have emerged from Generative AI and providing guidance on suggested practices for safety evaluation of Generative AI models. The 2024 Framework is currently undergoing public consultation and will be finalized within 2024.

Status of the AI Regulations

As noted above, there are currently no specific laws or regulations in Singapore that directly regulate AI.

Other laws affecting AI

There are various laws that do not directly seek to regulate AI but may affect the development or use of AI in Singapore. A non-exhaustive list of key examples includes:

• The Road Traffic Act 1961, which was amended in 2017 to allow for the testing and use of autonomous motor vehicles⁵
• The Health Products Act 2007, which requires medical devices that incorporate AI technology to be registered before they are used⁶

In addition, various Singapore regulatory agencies have adopted soft-law approaches by issuing guidelines on the responsible use of AI. A non-exhaustive list of key examples includes:

• The Personal Data Protection Commission of Singapore issued the Advisory Guidelines on Use of Personal Data in AI Recommendation and Decision Systems⁷ in 2024 to provide organizations with certainty on when they can use personal data to develop and deploy systems that embed machine-learning models
• The Monetary Authority of Singapore issued the Principles to Promote Fairness, Ethics, Accountability and Transparency (FEAT) in the Use of Artificial Intelligence and Data Analytics in Singapore’s Financial Sector⁸ in 2018 (updated in 2019) to provide a set of foundational principles for firms to consider when using AI in decision-making in the provision of financial products and services
• The Ministry of Health, Health Sciences Authority and Integrated Health Information Systems jointly issued the Artificial Intelligence in Healthcare Guidelines⁹ in 2021 to improve the understanding, codify good practice and support the safe growth of AI in healthcare

Definition of “AI”

As noted above, there are currently no specific laws or regulations in Singapore that directly regulate AI. Accordingly, no clear definition of AI is currently recognized in Singapore’s national legislation.

However, the 2020 Framework defines AI as “a set of technologies that seek to simulate human traits such as knowledge, reasoning, problem solving, perception, learning and planning, and, depending on the AI model, produce an output or decision (such as a prediction, recommendation and/or classification).”¹⁰

The 2024 Framework defines Generative AI as “AI models capable of generating text, images or other media. They learn the patterns and structure of their input training data and generate new data with similar characteristics. Advances in transformer-based deep neural networks enable Generative AI to accept natural language prompts as input, including large language models”.¹¹

Territorial scope

As noted above, there are currently no specific laws or regulations in Singapore that directly regulate AI. Accordingly, there is no specific territorial scope at this stage.

Sectoral scope

As noted above, there are currently no specific laws or regulations in Singapore that directly regulate AI. Accordingly, there is no specific sectoral scope at this stage. Nevertheless, there are certain sector-specific laws and guidelines that have been implemented in Singapore to regulate the use of AI, examples of which have been listed in section 3 above.

Compliance roles

As noted above, there are currently no specific laws or regulations in Singapore that directly regulate AI. Accordingly, there are currently no specific or unique obligations imposed on developers, users, operators and/or deployers of AI systems.

Core issues that the AI Regulations seek to address

As noted above, there are currently no specific laws or regulations in Singapore that directly regulate AI. Nevertheless, the 2024 Framework proposes nine dimensions to be looked at in totality to foster a trusted ecosystem¹²:

1. Accountability – allocation of responsibility to players along the AI development chain
2. Data – ensuring quality of data fed to AI models through the use of trusted data sources
3. Trusted development and deployment – encouraging transparency and disclosure to enhance broader awareness and safety
4. Incident reporting – establishing incident-management structures and processes for timely notification and remediation
5. Testing and assurance – adopting third-party testing against common AI testing standards to demonstrate trust to end-users
6. Security – addressing risks of new threat vectors being injected through AI models
7. Content provenance – developing technologies to enhance transparency about where and how content is generated
8. Safety and alignment research & development – accelerating investment in research & development to improve model alignment with human intention and values
9. AI for public good – harnessing AI to benefit the public by democratizing access, improving public sector adoption, upskilling workers and developing AI systems sustainably

The NAIS 2.0 also sets out Singapore’s long-term visions and goals with regard to AI, which includes working towards three systems through a series of “enablers”: “Activity Drivers (Enablers: Industry, Government, Research)”, “People & Communities (Enablers: Talent, Capabilities, Placemaking)”, and “Infrastructure & Environment (Enablers: Compute, Data, Trusted Environment, Leader in Thought and Action).”¹³

Risk categorization

As noted above, there are currently no specific laws or regulations in Singapore that directly regulate AI. The relevant frameworks and guidelines also do not set out an AI-related risk categorization. However, the 2024 Framework mentions that reporting of incidents should be proportionate and calibrated for practicality, and cites the EU AI Act as a potential reference point, which adopts risk categorization with regard to incident reporting.¹⁴

Key compliance requirements

As noted above, there are currently no specific laws or regulations in Singapore that directly regulate AI. However, there are certain compliance requirements for the use of AI in certain sectors, such as health and transport, as explained in section 3 above.

Regulators

Singapore does not currently have a specific designated regulator for AI, as the use of AI is currently governed by existing sectoral laws. However, the IMDA oversees the responsible adoption of AI across both public and private sectors, primarily through the aforementioned frameworks and guidelines. In addition, the Smart Nation and Digital Government Office, along with the Ministry of Communication and Information, issued the NAIS 2.0 and are responsible for implementing the national strategy for AI.

Enforcement powers and penalties

As noted above, there are currently no specific laws or regulations in Singapore that directly regulate AI. As such, enforcement and penalties relating to the creation, dissemination and/or use of AI are governed by related violations in non-AI legislation.

1 The Model AI Governance Framework is available here.
2 Details of AI Verify are available here.
3 The National Artificial Intelligence Strategy 2.0 is available here.
4 The draft Model AI Governance Framework for Generative AI is available here.
5 The Road Traffic Act is available here, see Articles 6C and 6E.
6 The Health Products Act is available here.
7 The Advisory Guidelines on Use of Personal Data in AI Recommendation and Decision Systems are available here.
8 The Principles to Promote Fairness, Ethics, Accountability and Transparency (FEAT) in the Use of Artificial Intelligence and Data Analytics in Singapore’s Financial Sector are available here.
9 The Artificial Intelligence in Healthcare Guidelines are available here.
10 Please see the Model AI Governance Framework available here, page 18.
11 Please see the draft Model AI Governance Framework for Generative AI available here, page 3.
12 Please see the draft Model AI Governance Framework for Generative AI available here.
13 Please see the National Artificial Intelligence Strategy 2.0 available here, page 14.
14 Please see the draft Model AI Governance Framework for Generative AI available here, page 14.

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