On 23 July 2025, The Online Citizen (TOC) sent a formal email to Minister for Communications and Information Josephine Teo, seeking clarification on why its Instagram account had been declared a Declared Online Location (DOL) under the Protection from Online Falsehoods and Manipulation Act (POFMA).
The declaration, issued on 11 June 2025 by Teo, cited a Correction Direction (CD) served to TOC on 23 December 2024.
The CD concerned TOC posts that reported on the use of trusts and limited disclosures in Singapore’s Good Class Bungalow (GCB) market, highlighting transactions involving ministers Tan See Leng and K. Shanmugam.
Specifically, the post referenced a reported S$27.3 million GCB purchase by Tan and the S$88 million transfer of a Queen Astrid Park property by Shanmugam via a trust.
The authorities deemed several statements in the post false or misleading, including the implication that Tan’s transaction was unrecorded in public databases, and that Shanmugam’s sale involved undisclosed beneficiaries. TOC, however, cited Bloomberg’s reporting and publicly available property market trends in its post.
The same CD was also issued to Bloomberg and The Edge Singapore, which had covered similar topics relating to GCB transactions and ministerial involvement. Despite this, neither of those platforms — including their Facebook accounts — were declared as DOLs.
In his email, TOC’s Editor-in-Chief Terry Xu pointed out that TOC’s Instagram post did not reproduce the statement in question, nor did it include a functioning link to the article. Under Section 32 of POFMA, the legal threshold for a DOL designation requires that false statements must have been “communicated” on the platform itself.
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The email asked the Ministry to explain:
- What specific statements on TOC’s Instagram and Facebook pages were considered to have “communicated” the falsehood from the 23 December CD;
- Whether merely linking to an article — without restating the alleged falsehood — constitutes “communication” under Section 32;
- Why Bloomberg and The Edge, despite receiving the same CD, were not subjected to the same DOL designation.
Xu emphasised that this was not an appeal against the DOL order, but a formal request for transparency on the application of POFMA powers and the consistency of enforcement.
MDDI’s response offered no substantive explanation
In a brief reply issued on 4 August 2025, the Ministry of Digital Development and Information (MDDI) responded on behalf of Minister Teo to TOC’s email sent on 23 July.
The Ministry stated that the social media posts “communicated the statements” by making them available to users in Singapore through links to the article containing the alleged falsehood.
It also noted that under the law, websites and pages may be designated as DOLs if they “put out falsehoods repeatedly”.
The email referred TOC to an earlier press release, but did not address the central issue: why Bloomberg and The Edge, having received the same CD, were not similarly designated.
Follow-up questions ignored by MDDI and Minister Teo
Later on the same day, Xu sent a follow-up email restating the key concerns and highlighting what had been left unanswered.
He reiterated that the TOC Instagram post did not contain a clickable link or the statement itself, and questioned how it could therefore be considered to have “communicated” the falsehood under the meaning of Section 32.
He also repeated the request for clarification on the different treatment of other publications issued the same CD — a matter not addressed in MDDI’s earlier reply.
As of 23 October 2025, more than two months later, neither MDDI nor Minister Teo has responded to this follow-up.
Selective enforcement and silence over TOC’s DOL raises concerns of political targeting
What this episode demonstrates is how the legal framework for Declared Online Locations under POFMA is structurally stacked against smaller publishers — especially when applied without clear consistency.
Under Section 32 of POFMA, an online platform can be designated a DOL if three or more different false statements are alleged to have been communicated on that platform within a six-month period.
In the case of TOC’s Instagram account, this threshold was reportedly met — not through multiple Correction Directions, but through three separate statements of falsehood identified under a single Correction Direction.
While many mistakenly assume that a DOL requires “three strikes” or three separate directions, POFMA only requires three distinct falsehoods to be alleged — even if all are contained within one direction.
But the standard is not consistently applied.
Bloomberg and The Edge Singapore were both issued Correction Directions in December 2024 relating to the same alleged falsehood as TOC, and reportedly for more than three statements of falsehood — yet none of their platforms, including Instagram or Facebook, have been designated as DOLs. The basis for this disparate treatment remains unexplained, even after TOC formally sought clarification.
The law, in its current form, enables the government to unilaterally impose a DOL once the threshold is met, without public disclosure of the criteria applied to assess intent, reach, or editorial context. Once a DOL is in place, the consequences are not symbolic — they are financially crippling.
Despite repeated ministerial assurances that a Correction Direction does not censor the original content — allowing it to remain accessible — this view omits a critical point: a DOL designation criminalises any attempt by the publication to monetise its work.
Under Sections 36 and 37 of POFMA, the operator of a DOL is prohibited from receiving advertising revenue, subscriptions, or other financial support, unless explicitly authorised by the Minister.
This provision is existential. TOC, a small, independent publisher, has been forced to cut costs drastically and rely almost entirely on volunteers and community goodwill to continue operating.
The same restrictions, if imposed on a major publication like Bloomberg, would be unthinkable. Can anyone reasonably imagine Bloomberg continuing operations if it were suddenly barred from collecting subscription revenue in Singapore — simply because the government alleged that some posts contained falsehoods?
That is the practical effect of the DOL regime: it does not merely correct or clarify information, as the government often claims. It punishes the act of publishing, financially disabling those who are designated.
And when this mechanism is applied selectively — shielding powerful global media outlets while bringing down the full weight of the law on smaller, independent ones — it raises legitimate concerns that POFMA is not merely a tool to manage misinformation, but a political instrument to suppress dissent.
If POFMA were truly content-neutral, it would not matter who the publisher is — only what was published. But the continued silence in response to TOC’s formal queries only deepens the sense that the law is not being enforced equally, and that editorial independence in Singapore remains vulnerable to discretionary power.
Editor’s note:
Due to the financial restrictions imposed under the Declared Online Location (DOL) framework of POFMA — which criminalises the monetisation of platforms designated under the Act — The Online Citizen is no longer able to sustain its operations through traditional funding models.
As a result, we have been compelled to establish alternative publications, including Heidoh, to continue our work in a manner that allows for lawful monetisation and long-term viability. These platforms are necessary not only for operational survival, but also to uphold the principles of independent journalism in an increasingly restrictive media environment.
It is important to remember that we operate without the financial security or institutional support enjoyed by state-funded media — entities sustained by taxpayer resources. This disparity makes it exceedingly difficult for independent platforms like ours to compete on equal footing, particularly when burdened with legal and financial constraints imposed under POFMA.
Despite these challenges, we remain committed to delivering factual, critical reporting that holds power to account. If you value independent journalism and believe in the importance of media plurality, we ask for your support — whether through readership, sharing our work, or contributing to the sustainability of new platforms like Heidoh.
Your engagement helps keep independent journalism alive — even as we navigate a system that appears designed less to correct falsehoods than to silence dissent.
The post Josephine Teo remains silent on unequal DOL treatment of TOC’s Instagram account appeared first on The Online Citizen.
