In detail
Prohibition of deepfake content
The new law targets digitally generated or manipulated content that depicts a candidate saying or doing something they did not, and that is realistic enough to be reasonably believed by some members of the public. This includes content created using AI techniques such as deepfakes, as well as non-AI traditional editing methods, such as Photoshop, dubbing and splicing.
The law applies to online election advertising that can be reasonably regarded as intending to promote, procure or prejudice the electoral success or prospects of a political party or candidate.
Candidates can ask the returning officer (RO) to review content that has misrepresented them, and the RO can issue corrective directions to those who publish prohibited online election advertising content.
Individuals who publish, share or repost prohibited content may face fines of up to SGD 1,000 and/or imprisonment for up to 12 months. Social media platforms that fail to comply with the law may be fined up to SGD 1 million. To deter the abuse of the law, such as candidates requesting the removal of unfavorable content that is in fact true, there are also penalties if a candidate makes a false declaration to an RO.
The primary objective of this law is to uphold the integrity of Singapore's elections by preventing the spread of false information about candidates. By banning deepfakes and other digitally manipulated content, the government aims to ensure that voters receive accurate information about candidates' actions and statements.
Other prohibited election advertising activities
Other election advertising activities are also prohibited during the "cooling-off" period, which begins on the eve of Polling Day and ends at the close of Polling Day. We set out the key prohibitions below.
No fresh election advertising
During the cooling-off period, campaigning is banned and no fresh election advertising can be published or publicly displayed. This includes online election advertising (OEA) and traditional election advertising (TEA), e.g., banners, flags and posters. The rules apply to all persons, including candidates, election agents and authorized third parties.
Prohibited activities during the cooling-off period include the following (subject to certain exceptions):
- Publishing or publicly displaying, or causing to be published or publicly displayed, any election advertising, including OEA and TEA, that is not already lawfully published or displayed
- Sharing resharing/reposting/boosting OEA that was published before the cooling-off period
- Canvassing (such as through walkabouts, door-to-door visits, visiting homes and workplaces of voters for election purposes in connection with the election)
- Wearing, using, carrying or displaying campaign propaganda (though candidates are permitted to wear a replica of the symbol allotted to them or to the group of candidates to which they belong)
- Holding election meetings
OEA that was already lawfully published before the cooling-off period and remains unchanged after its publication does not need to be taken down. However, sharing, resharing, reposting or boosting existing OEA is considered to be publishing new OEA, and is also prohibited during the cooling-off period.
No publication of election surveys and exit polls
The publication of results of election surveys and exit polls is also prohibited during the cooling-off period in accordance with the Parliamentary Elections Act 1954.
For example, members of the public should not create survey polls on social media platforms, online forums, messaging services or websites where the results can be viewed. Reposting the results of an election survey is also prohibited.
An exit poll refers to any statement on how voters have voted during the election, or forecast on the result of the election, where the statement or forecast is (or might reasonably be taken to be) based on information from voters after they have voted.
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The above prohibitions during the cooling-off period are in addition to general prohibitions in campaigning, including: the prohibition against the use of films in campaigning under the Films Act 1981; the prohibitions against foreign interference and negative campaigning; and restrictions applicable to campaigning by political parties and civic organisations on candidates' behalf.
Key takeaways
The prohibitions in place during the cooling-off period are intended to give voters time to reflect rationally on issues raised during the election to facilitate the democratic process. Online platforms in particular should note these prohibitions to ensure they are well placed to provide support in the event of take-down requests or investigations.
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For further information and to discuss what this development might mean for you, please get in touch with your usual Baker McKenzie contact.
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