Singapore: Updated copyright regulations on circumvention of access controls

In brief

The Ministry of Law and the Intellectual Property Office of Singapore conducted a public consultation between 22 April and 21 June 2024 (see our earlier update here) on exceptions allowing users to bypass digital access control measures (ACMs) for lawful, non-infringing use. The consultation drew 19 responses from both rights holders and users, including industry bodies and public agencies. As a result of this review, key changes have been implemented via new subsidiary legislation, the Copyright (Access Control Measures – Prescribed Exceptions) Regulations, effective from 1 January 2025. The summary of key changes can be found here.


Contents

Key updates

Only one existing exception (Regulation 95, relating to assistive technologies) has been retained, with its scope now narrowed to uses that fall under permitted uses for persons with print disabilities.

All other previous exceptions (Regulations 93, 94, and 96-100) have been allowed to lapse due to insufficient evidence supporting their renewal.

One exception for libraries, museums, and archives to preserve or replace works in public collections, and one exception for administrative uses of such materials by public institutions, have been introduced.

No exception for AI and data mining

Despite proposals by tech companies, the government decided not to introduce a new exception to allow circumvention of ACMs for computational data analysis. The rationale is that such circumvention would undermine the lawful access safeguards embedded in the Copyright Act 2021, which remain essential to protecting rights owners' interests and fostering licensing models for AI training datasets.

Key takeaways

These developments reflect Singapore's continued effort to strike a balance between protecting IP rights and allowing reasonable, socially beneficial uses of content. Businesses and institutions that deal with digital content or rely on AI training data should review how these changes affect their operations.  

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