Singapore: Update on Online Safety Measures for App Stores
April 10, 2026
Singapore: Update on Online Safety Measures for App StoresApril 10, 2026 BackgroundProtecting children from harmful online content has been an ongoing regulatory focus for the Singapore Government. In 2023, the Infocomm Media Development Authority (IMDA) issued its Code of Practice for Online Safety targeting six designated Social Media Services ("SMS CoP") — Facebook, YouTube, Instagram, TikTok, X (formerly Twitter), and HardwareZone — imposing obligations around content moderation, user reporting, and annual reporting. IMDA issued a new Code of Practice for Online Safety for App Distribution Services (aka app stores) (the "ADS CoP") which took effect on 31 March 2025. Pursuant to the ADS CoP, with effect from 1 April 2026, designated app stores in Singapore must put in place age assurance measures to ensure that users under 18 are unable to access or download age-inappropriate applications. Whereas the SMS CoP targeted individual social media apps, the ADS CoP moves one level up — regulating the app stores themselves. Both Codes share the same objective: protecting users, especially children, from harmful content. Who Is Affected and Key ObligationsThe ADS CoP currently designates the following five app store operators:
Starting from 1 April 2026, these app store operators must put in place appropriate age assurance measures including:
The app stores must also implement content moderation measures and work with app providers to remove certain types of inappropriate content. Although not directly regulated by the ADS CoP, app developers and businesses must keep these requirements in mind since it is likely that the affected app stores will require them to implement these restrictions and measures in their apps before they can be made available to users in Singapore. A Continuing Regulatory TrendThe trajectory from the 2023 SMS CoP to the 2025 ADS CoP reflects a deliberate, layered regulatory strategy by the Singapore Government and enforcement of the Codes of Practice is keeping pace. In March 2026, IMDA issued Letters of Caution to X and TikTok under the SMS CoP, placing them under Enhanced Supervision after detecting serious weaknesses in their proactive detection of child sexual exploitation and abuse material and terrorism content. Looking ahead, IMDA has signalled that it plans to extend age assurance requirements to designated social media services as well. What Should Businesses Do?App providers and distribution services operating in Singapore should review the ADS CoP and assess whether their safety measures, age assurance systems, and reporting mechanisms meet the new standards. In particular, businesses should ensure their apps are correctly classified under the relevant app store's content rating systems and consider if updates to developer agreements are required. The ADS CoP is available here. Latest Insights
Latest News
Latest Events
client news June 02, 2026 Next stop, public ownership: Eversheds Sutherland advises DfT on GTR transi... firm news June 01, 2026 Eversheds Sutherland strengthens restructuring offering with senior partner... firm news June 01, 2026 Eversheds Sutherland strengthens Commercial Advisory practice with technolo... client news May 28, 2026 Eversheds Sutherland advises Schroders Greencoat on acquisition of Dutch bi... virtual Spanish employment law training June 02, 2026 2pm - 5pm (BST) Virtual virtual UK employment law training June 09, 2026 1pm - 4pm (BST) Virtual virtual Nordic (Denmark, Finland, Norway and Sweden) employment law training June 16, 2026 12.45pm - 4pm (BST) Virtual virtual Introduction to Swiss employment law June 23, 2026 2pm - 5pm (GMT) Virtual |