Online Safety Commission begins operations as OSRAA remedies take effect

DISCLAIMER: This update is intended for your general information only. It is not intended to be, nor should it be, regarded as or relied upon as legal advice. Court decisions referred to herein may be subject to further appeal at the time of publication, and subsequent developments in the law, including new legislation, amendments, court decisions or practice directions, may affect the accuracy or relevance of the matters discussed. We are under no duty to update this publication to reflect any such changes in the law. You should consult a qualified legal professional before taking any action or omitting to take action in relation to matters discussed herein.

WongPartnership LLP (UEN: T08LL0003B) is a limited liability law partnership registered in Singapore under the Limited Liability Partnerships

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Online Safety Commission Begins Operations as

OSRAA Remedies Take Effect

On 28 June 2026, the Online Safety Commission (OSC), Ministry of Digital Development and Information

The OSC is established to support the office of the Commissioner of Online Safety (Commissioner)

created by the Online Safety (Relief and Accountability) Act 2025 (OSRAA). Specified provisions on the statutory torts under OSRAA, covering the following five online harms, also came into effect on 29 June 2026: (a) online harassment (including online sexual harassment); (b) doxxing; (c) online stalking; (d)

intimate image abuse; and (e) image-based child abuse (Initial Five Online Harms). Our earlier updates on the OSRAA and the OSC are available here and here.

More Support for Five Online Harms in First Phase of Operations

In its first phase of operations, the OSC supports victims affected by the Initial Five Online Harms, which are among the most prevalent and severe online harms faced by Singapore citizens and residents. The remaining eight categories of online harms under OSRAA will be progressively implemented.

Those who have experienced online harassment or online stalking should first report the harmful content to the platform on which it appears. If the platform fails to respond promptly or provides an inadequate response within 24 hours, victims may then file a report with the OSC.

For cases involving intimate image abuse, image-based child abuse and doxxing, victims may report directly to the OSC through its website at https://www.osc.gov.sg.

Parents and guardians may file reports on behalf of victims who are under 18 years of age. A report may also be submitted by another individual on behalf of a victim, with the victim’s written authorisation. There is no fee required to make a report to the OSC.

Victims making reports via the OSC’s website will be guided through the reporting process and should be prepared to provide information on the online harm, which may include a description of what happened and supporting information such as URLs, screenshots, images and videos.

Directions, Prescribed Providers and Support Beyond Content Removal

Once a victim (or another person on the victim’s behalf) has filed a report with the OSC, the OSC will assess it. If there is reason to suspect that online harm has occurred, the Commissioner may issue directions to stop or limit the harm. These directions may be issued to the person who posted the harmful content, the administrator of the online group or page where the harmful content appears, or the platform hosting the content.

Online Safety

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DISCLAIMER: This update is intended for your general information only. It is not intended to be, nor should it be, regarded as or relied upon as legal advice. Court decisions referred to herein may be subject to further appeal at the time of publication, and subsequent developments in the law, including new legislation, amendments, court decisions or practice directions, may affect the accuracy or relevance of the matters discussed. We are under no duty to update this publication to reflect any such changes in the law. You should consult a qualified legal professional before taking any action or omitting to take action in relation to matters discussed herein.

WongPartnership LLP (UEN: T08LL0003B) is a limited liability law partnership registered in Singapore under the Limited Liability Partnerships

Act 2005.

The Commissioner may direct that access to the harmful content be disabled, or that the perpetrator’s account be restricted. Non-compliance with a direction is a criminal offence. The OSC may, as from 29

June 2026, also issue the following directions and orders to different actors in the online ecosystem as shown in the table below.

Actor

Directions / Orders the OSC May Issue

Communicator

Stop Communication Direction (including for a class of material); Restraining

Direction to refrain from engaging in similar online harms

Administrator

Stop Communication Direction (may also require suspending or shutting down the online location); Restraining Direction; Labelling Direction to post a notice of past online harms; Account Restriction (Administrator) Direction to restrict access by a

Singapore account or new accounts

Platform

Access Disabling Direction; Account Restriction (Online Service) Direction to restrict interactions or ban a Singapore account

Internet Access Service Provider

Access Blocking Order, where an Administrator or Platform fails to comply with OSC directions

App Distribution Service Provider

App Removal Order, where a Platform fails to comply with OSC directions

The following six prescribed online service providers (POSPs) have additional obligations under the

OSRAA for the purposes of the OSC, reflecting a higher level of responsibility to ensure a safe online space for Singapore users:

(a)

Meta Platforms, Inc. in respect of Facebook and Instagram;

(b)

Google LLC in respect of YouTube;

(c)

X Corp. in respect of X;

(d)

TikTok Pte. Ltd.; and

(e)

SPH Media Limited in respect of HardwareZone Forums.

All platforms, including non-POSPs, may receive an Access Disabling Direction, an Account Restriction

(Online Service) Direction or a notice to provide any information or document within their knowledge, custody or control. POSPs may receive additional directions and notices, including directions to disable identical copies or future communications of material, directions to disable a class of online material, directions to restrict or disable future accounts created by a perpetrator of online harm, Engagement

Reduction Directions and notices to collect information of an end-user that may identify or lead to the identification of that end-user, which the POSP might not already possess.

© WongPartnership LLP

DISCLAIMER: This update is intended for your general information only. It is not intended to be, nor should it be, regarded as or relied upon as legal advice. Court decisions referred to herein may be subject to further appeal at the time of publication, and subsequent developments in the law, including new legislation, amendments, court decisions or practice directions, may affect the accuracy or relevance of the matters discussed. We are under no duty to update this publication to reflect any such changes in the law. You should consult a qualified legal professional before taking any action or omitting to take action in relation to matters discussed herein.

WongPartnership LLP (UEN: T08LL0003B) is a limited liability law partnership registered in Singapore under the Limited Liability Partnerships

Act 2005.

The OSC operates a no-wrong-door policy. Regardless of which government agency victims first approach, they will be guided to the appropriate help. Victims and their families are encouraged to seek help from the OSC’s current community partners, which can guide victims on how to make a report to the

OSC and provide other forms of assistance such as counselling. The OSC’s website also provides victims and the public with resources on online harms, including information on different types of online harms, what to do when such harms occur and how to keep safe online.

Further Review and Applications for End-User Identity (EUI) Information

OSRAA provides for a two-stage review mechanism for all reports filed with the OSC. Eligible persons may seek a reconsideration of the Commissioner’s decision if they disagree with it.

Parties who remain dissatisfied with the Commissioner’s decision after reconsideration may appeal to an

Online Safety Appeal Panel. The appeal panel acts independently of the OSC and can affirm, revoke, vary or substitute the Commissioner’s decision. The applicable deadlines and fees for each stage are set out below:

Stage

Who May Apply

Deadline

Fee

Reconsideration by the

Commissioner

Eligible persons who disagree with the decision

No later than 14 days after the initial

OSC decision is issued

No fee

Appeal to the Online Safety

Appeal Panel

Parties dissatisfied after reconsideration

No later than 14 days after the reconsidered decision is issued

$200

Victims who do not know who harmed them online may apply to the OSC for help identifying the person responsible, if they are thinking of commencing, or intend to commence, civil proceedings against such person. Applications for EUI information must be made within 12 months from when the online harm occurred or when the victim first became aware of it, whichever is later. If an application is successful, the disclosed information may only be used for its stated purposes and its disclosure will be subject to conditions.

New Legal Remedies Under OSRAA

Victims of online harms will also have additional rights under OSRAA to bring civil claims in Court. These rights are provided through new statutory torts, which cover the Initial Five Online Harms.

The statutory torts operate by setting out duties for different actors in the online ecosystem.

Communicators must not communicate or publish harmful material, or engage in harmful online conduct.

Administrators must not set up or run online groups, pages, forums or other online spaces in a way that facilitates online harm. They must also take reasonable steps to address such harm when properly notified. Platforms must take reasonable steps to address online harm when properly notified, and do so within a reasonable time.

The duty of an administrator or platform to respond reasonably when notified of harm is triggered upon the victim sending an Online Harm Notice to them in the prescribed form and manner. Victims may access the prescribed Online Harm Notice form on MinLaw’s Online Safety website; the form may also be hosted as a

© WongPartnership LLP

DISCLAIMER: This update is intended for your general information only. It is not intended to be, nor should it be, regarded as or relied upon as legal advice. Court decisions referred to herein may be subject to further appeal at the time of publication, and subsequent developments in the law, including new legislation, amendments, court decisions or practice directions, may affect the accuracy or relevance of the matters discussed. We are under no duty to update this publication to reflect any such changes in the law. You should consult a qualified legal professional before taking any action or omitting to take action in relation to matters discussed herein.

WongPartnership LLP (UEN: T08LL0003B) is a limited liability law partnership registered in Singapore under the Limited Liability Partnerships

Act 2005.

webform on a platform’s online service, in which case MinLaw’s Online Safety website will provide the relevant link.

12 platforms have been prescribed under OSRAA for the purposes of the statutory torts, with additional duties to respond to Online Harm Notices.1 These platforms must respond within the following specified timeframes, unless they show to the Court that it was not reasonable to do so within that time:

Type of Harm

Timeframe to Respond to Online Harm Notices

Intimate image abuse or image-based child abuse 24 hours

Cases depicting a person’s exposed genital or anal region, or breasts if the person is female 6 hours

All other harms 48 hours

For intimate image abuse and image-based child abuse, the Court will award at least $5,000 for each image or recording if the claim is made out. OSRAA’s court-based remedies complement existing remedies under the Protection from Harassment Act 2014 (POHA). Victims of online harassment, doxxing or stalking may continue to seek remedies against communicators under POHA, including

Protection Orders.

The operationalisation of OSRAA is part of the continuing efforts by the Singapore Government to ensure

Singaporeans are safe online. In the past two years, the Infocomm Media Development Authority (IMDA)

has issued the Code of Practice for Online Safety – App Distribution Services and published the Online

Safety Assessment Reports on Designated Social Media Services.

If you would like information and/or assistance on the above or any other area of law, you may wish to contact the Partner at WongPartnership whom you normally work with or any of the following Partners:

1

This is a separate and broader list than the six POSPs prescribed for the purposes of the OSC. The 12 prescribed platforms are

Google LLC in respect of YouTube; Google LLC in respect of Google Maps Reviews; Meta Platforms, Inc. in respect of

Facebook; Meta Platforms, Inc. in respect of Instagram; Meta Platforms, Inc. in respect of Threads; WhatsApp LLC in respect of

WhatsApp; X Corp. in respect of X; SPH Media Limited in respect of HardwareZone Forums; TikTok Pte. Ltd.; Reddit, Inc.;

Telegram Messenger Inc.; and WeChat International Pte. Ltd. in respect of WeChat.

LAM Chung Nian

Head – Intellectual Property,

Technology & Data

Kylie PEH

Partner – Intellectual Property,

Technology & Data

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