SINGAPORE Law and Practice Contributed by: Azmul Haque, Ashley Chew, Hu Yutong and Aaron Leong, Collyer Law LLC
9. Looking Forward 9.1 Upcoming Legal Reforms Workplace Fairness Legislation
Data Intermediaries A data intermediary processing personal data for another organisation under a written contract is directly subject to selected PDPA obligations, includ - ing protection, retention and certain breach-notifica - tion obligations. The engaging organisation remains responsible for personal data processed on its behalf and should manage processing instructions, security controls and onward transfers contractually. 8.3 Role and Authority of the Data Protection Agency Regulator The Personal Data Protection Commission (PDPC) administers and enforces the PDPA. Its statutory func - tions include: • promoting awareness of data protection; • administering and enforcing the PDPA; • advising the government; • representing Singapore internationally on data protection matters; and • issuing advisory guidelines. The PDPC’s Role In practice, the PDPC: • issues policies, directives, advisory guidelines and guides; • promotes compliance; • reviews complaints and data breach notifications; • conducts investigations; • accepts voluntary undertakings; and • takes enforcement action where appropriate. The Infocomm Media Development Authority supports The PDPC may issue directions requiring an organi - sation to stop collecting, using or disclosing personal data, destroy personal data, comply with access or correction obligations, or pay a financial penalty. The maximum financial penalty is generally SGD1 million; for organisations with annual Singapore turnover exceeding SGD10 million, it is either SGD1 million or 10% of that organisation’s annual Singapore turnover, whichever is higher. the PDPC’s functions. Enforcement Powers
The Workplace Fairness Act 2025 is slated to take effect by the end of 2027 and will establish statutory protections against workplace discrimination and related employer obligations, while the Workplace Fairness (Dispute Resolution) Act 2025 establishes the dispute resolution framework. Employers should monitor commencement notifications and prepare policies, grievance processes, training and record- keeping practices in anticipation of the new regime. CPF Changes CPF contribution rates for older employees increased from 1 January 2026, with further senior worker adjustments expected from 1 January 2027. Employ - ers should update payroll systems, employment cost forecasts and employee communications. Corporate Governance and Anti-Money Laundering Singapore has continued to strengthen its anti-money laundering and corporate governance framework. Key changes under the Corporate and Accounting Laws (Amendment) Act 2025 commenced in April 2026, including a new director disqualification ground for persons convicted of specified money laundering offences.
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