A closer look at the Online Safety Commission and the Online Safety (Relief and Accountability) Act 2025

The Online Safety Commission ("OSC") commenced operations on 29 June 2026, along with key provisions of the Online Safety (Relief and Accountability) Act 2025 ("OSRAA") coming into force. 

In its first weeks of operation, the OSC has already been called upon to address a number of complaints involving allegedly harmful online content. While it remains early days, these actions offer some insight into how the OSC may approach the exercise of its powers. This article reviews the key features of the OSRAA, examines the OSC's initial interventions, and considers several legal questions that may emerge as the regime develops.

The OSRAA at a glance

The OSRAA was introduced to provide stronger protections and faster avenues of relief for victims of online harms. It addresses 13 categories of harm: online harassment, doxxing, online stalking, intimate image abuse, image-based child abuse, online impersonation, inauthentic material abuse, online instigation of disproportionate harm, incitement of violence, incitement of enmity, publication of false material, publication of a statement harmful to reputation, and non-consensual disclosure of private information.

There are two pathways of recourse: 

1. The OSC has the power to issue directions to stop harm. Such directions may be issued to perpetrators, group administrators or platforms.
2. Victims may also commence civil proceedings in court to seek damages or injunctions.

On the first pathway, the OSC is focusing on five categories of online harms in its initial phase of operations: (a) intimate image abuse; (b) image-based child abuse; (c) doxxing; (d) online harassment, including sexual harassment; and (e) online stalking. Where the OSC is satisfied that harmful activity has occurred, Part 5 of the OSRAA empowers it to issue directions, including directions compelling the takedown of offending content, restricting the perpetrator's account, or requiring the posting of a right of reply. Directions are subject to reconsideration by the Commissioner and, beyond that, appeal to the Online Safety Appeal Panel.

The second pathway is a particularly novel feature of the OSRAA – with no direct equivalent under comparable UK or Australian online safety legislation. Parts 10 to 12 create statutory torts to allow victims to bring proceedings directly against perpetrators, group administrators or platforms in respect of certain harms. In addition to the civil measure of damages, the OSRAA also provides for a minimum quantum of damages (S$5,000 for each recording or image constituting intimate image abuse or image-based child abuse¹); and the possibility of enhanced damages where a respondent fails to reasonably address harmful conduct after being notified of it. 

Overall, the OSRAA adopts a victim-centric approach to regulating online harms. Take online harassment, doxxing and stalking, for instance. Traditionally, victims would have had recourse against perpetrators under the Protection from Harassment Act 2014 ("POHA"). The OSRAA extends the regulation of these harms by imposing new statutory duties on administrators and platforms, who fall outside POHA's reach. This helps to address some of the practical challenges faced by victims: perpetrators may not always be readily identifiable, may be located outside the jurisdiction, or may have concealed their identities through VPNs or other means of masking their IP addresses. By looking to other actors in the chain, the OSRAA reflects what many victims want most: for the harm to stop, quickly.

Case studies – the OSC in action

The OSC's early enforcement activity provides an opportunity to see how these powers may operate as the OSRAA regime matures. Two recent instances illustrate the range of the OSC's toolkit.

The first involved a case of misleading identification. The OSC directed that a post be taken down after a TikTok post wrongly linked a fitness instructor to the resignation of former Senior Minister of State Faishal Ibrahim. While the exact harm and direction issued have not been publicly reported, it is not difficult to appreciate why the OSC acted in this instance.

The second case, however, moves into a grey area. A content creator took to YouTube to discuss her former partner's alleged infidelity. A report was filed and, after assessing the report, the OSC issued a letter to the content creator explaining that it considered parts of the video to constitute online harmful activity. The OSC gave the content creator an opportunity to address its concerns without issuing any formal direction. The content creator removed the video the same day, and the OSC publicly acknowledged that she had done so proactively.

These instances suggest that the OSC is adopting a calibrated approach to addressing complaints. Depending on the apparent severity and urgency of the harm, as well as the circumstances of each case (such as whether the harm is clear-cut), a formal direction may not be the first port of call. 

Looking ahead – areas for development

Although the OSRAA significantly expands the legal tools available to victims of online harms, several aspects of the new regime remain untested. As the legislation is still in its infancy, courts and regulators will likely be called upon to address questions of interpretation and scope. We highlight two issues that may warrant particular attention in future disputes.

First, does the OSRAA cover corporate victims? On its face, the OSRAA is primarily designed as a personal remedy for individuals, but consider the tort of online instigation of disproportionate harm under section 87: 

“A person (X) must not communicate online material that contains or consists of a statement where the following requirements are met … the statement tends to instigate the public or a section of the public to act or omit to act in response to an alleged speech or conduct of a person (called in this section the victim) ….”

This was conceived to address cancel-culture mob behaviour targeting individuals. That said, a victim is defined as a “person”, which under the Interpretation Act 1965 leaves open the question of whether corporate victims are covered. If a coordinated online campaign were mounted calling for a boycott of a business, could the company bring a claim? A cogent argument could be made in favour of corporate victims. The requisite harm need not be emotional, and the provision expressly contemplates “loss and damage suffered by the victim”.

Second, section 101 of the OSRAA establishes that a tort under the OSRAA is treated as occurring in Singapore if any element was initiated or occurred in or from Singapore, was perceived in Singapore, or caused damage suffered in Singapore. In internet defamation, courts have long wrestled with where a tort "occurs": is it the place of publication, the place of receipt, or somewhere else? On one understanding, virtually any harmful online content accessible in Singapore could ground jurisdiction here, regardless of where the poster and the victim are located. Given the borderless nature of online harm, and given that Singapore law currently regards the place of the tort as the prima facie natural forum for determining a claim, section 101 could also be relevant to whether Singapore is the appropriate forum to hear a dispute.

Conclusion

The establishment of the OSC and the commencement of the OSRAA mark a significant development in Singapore's approach to addressing online harms. Together, they provide victims with both rapid administrative remedies and new civil causes of action, extending responsibility beyond individual perpetrators to other actors in the online ecosystem. 

For now, the early signs suggest that the OSRAA has equipped victims with a broader and more practical suite of remedies, while giving the OSC a flexible range of tools to address online harms. As the regime matures, it will be interesting to see how the courts interpret some of the legislation's more novel provisions, including its territorial reach and the scope of the statutory torts.

_{¹ Section 5 of the Online Safety (Relief and Accountability) (Damages in Court Proceedings) Regulations 2026.}