Singapore: Regulatory action taken for posting AI-generated fake reviews

In brief

On 3 July 2025, the Competition and Consumer Commission of Singapore (CCCS) announced that it had taken regulatory action against Quantum Globe Pte. Ltd. ("Quantum Globe") for posting fake five-star reviews for its "Lambency Detailing" brand on its Sgcarmart.com business page over a two-year period. This is the first regulatory enforcement case in Singapore involving the use of AI to create fake reviews, as the reviews were generated using ChatGPT and submitted using customers' information without their knowledge or consent.


Contents

In more detail

In January 2025, following a complaint from a customer who discovered unauthorised reviews posted under her name, the CCCS launched its investigation and confirmed with seven other customers that fake reviews had been submitted using their names, vehicle registration numbers and photographs — without their knowledge or consent.

Quantum Globe's actions were classified as unfair trade practices under the Consumer Protection (Fair Trading) Act 2003 (CPFTA) as they misled consumers by creating a false impression of customer satisfaction, potentially influencing purchase decisions.

Quantum Globe admitted to engaging in such unfair trade practices. To address the CCCS’ concerns, Quantum Globe undertook to:

  • Stop posting fake reviews.
  • Set up a feedback channel for a six-month period to allow customers to report any fake reviews on Sgcarmart.
  • Notify customers whose details were used to post fake reviews between October 2024 and January 2025 and invite them to report any fake reviews through the feedback channel.
  • For a period of six months, publish notices on Sgcarmart and any online platforms used for marketing Lambency. Detailing's brand or services to inform customers that it had posted fake reviews, and alert them of the feedback channel.
  • Remove reviews verified to be fake from Sgcarmart within eight working days, including the seven reviews identified by CCCS.

Mr. Matthew Lim Jun Ho, Quantum Globe's director, also gave a personal undertaking not to engage in any unfair trade practice or facilitate any business under his control to do so.

Key takeaways

This case is the second fake review case that CCCS has uncovered.

Businesses should take note of the increased regulatory scrutiny on deceptive digital trade and marketing practices such as dark patterns and ensure that their marketing practices remain transparent and compliant with the CPFTA. This case is also a timely reminder for platforms to implement safeguards to preserve the authenticity of user-generated content and audit the use of AI in customer engagement and marketing on their platforms.

For CPFTA violations, the CCCS can seek declarations and court injunctions against errant businesses. The court may also issue accompanying orders, such as requiring the business to notify its consumers about the declaration or injunction before entering into contracts with its consumers and to include a statement about the declaration or injunction in every invoice or receipt. Failure to comply with the court's order may result in an offence of contempt of court.

* * * * *

LOGO_Wong&Leow_Singapore

© 2025 Baker & McKenzie. Wong & Leow. All rights reserved. Baker & McKenzie. Wong & Leow is incorporated with limited liability and is a member firm of Baker & McKenzie International, a global law firm with member law firms around the world. In accordance with the common terminology used in professional service organizations, reference to a "principal" means a person who is a partner, or equivalent, in such a law firm. Similarly, reference to an "office" means an office of any such law firm. This may qualify as "Attorney Advertising" requiring notice in some jurisdictions. Prior results do not guarantee a similar outcome.


Copyright © 2025 Baker & McKenzie. All rights reserved. Ownership: This documentation and content (Content) is a proprietary resource owned exclusively by Baker McKenzie (meaning Baker & McKenzie International and its member firms). The Content is protected under international copyright conventions. Use of this Content does not of itself create a contractual relationship, nor any attorney/client relationship, between Baker McKenzie and any person. Non-reliance and exclusion: All Content is for informational purposes only and may not reflect the most current legal and regulatory developments. All summaries of the laws, regulations and practice are subject to change. The Content is not offered as legal or professional advice for any specific matter. It is not intended to be a substitute for reference to (and compliance with) the detailed provisions of applicable laws, rules, regulations or forms. Legal advice should always be sought before taking any action or refraining from taking any action based on any Content. Baker McKenzie and the editors and the contributing authors do not guarantee the accuracy of the Content and expressly disclaim any and all liability to any person in respect of the consequences of anything done or permitted to be done or omitted to be done wholly or partly in reliance upon the whole or any part of the Content. The Content may contain links to external websites and external websites may link to the Content. Baker McKenzie is not responsible for the content or operation of any such external sites and disclaims all liability, howsoever occurring, in respect of the content or operation of any such external websites. Attorney Advertising: This Content may qualify as “Attorney Advertising” requiring notice in some jurisdictions. To the extent that this Content may qualify as Attorney Advertising, PRIOR RESULTS DO NOT GUARANTEE A SIMILAR OUTCOME. Reproduction: Reproduction of reasonable portions of the Content is permitted provided that (i) such reproductions are made available free of charge and for non-commercial purposes, (ii) such reproductions are properly attributed to Baker McKenzie, (iii) the portion of the Content being reproduced is not altered or made available in a manner that modifies the Content or presents the Content being reproduced in a false light and (iv) notice is made to the disclaimers included on the Content. The permission to re-copy does not allow for incorporation of any substantial portion of the Content in any work or publication, whether in hard copy, electronic or any other form or for commercial purposes.