Consumer Protection Enforcement and Regulatory Updates in Singapore

Introduction

Singapore’s consumer protection watchdog, the Competition and Consumer Commission of Singapore (“CCCS“) is sticking to its guns and pursuing any and all forms of consumer protection violation under the Consumer Protection (Fair Trading) Act 2003 (“CPFTA“). It is a clear signal that CCCS will take a hard stance against unfair trade practices on both the digital front and face-to-face sales tactics. The difficulty for businesses which engage customers is understanding the scope of “unfair” – when is the line crossed?

Our March 2025 Legal Update titled “Consumer Protection in Singapore – Five Key Observations for Businesses in a Heightened Enforcement Climate” had highlighted five key observations with respect to consumer protection in Singapore. Since then, CCCS has publicised its findings against two businesses for unfair practices in the digital space, centred around the use of misleading web design features and the posting of fake customer reviews. Concurrently, CCCS continues to take action against physical hard selling tactics that target vulnerable consumers.

Beyond its concerted enforcement activity, CCCS has expanded its scope of regulatory oversight to include product safety and legal metrology compliance. Alongside being equipped with a broader set of tools to regulate market activity, CCCS is demonstrating its commitment to creating a robust regulatory environment through various court actions.

In this Update, we share recent cases which indicate a trend towards more stringent enforcement and highlight the significance of CCCS’ expanded scope of regulatory functions.

We will be hosting a client seminar in September 2025 to discuss these and other consumer protection developments. More details will be provided in due course. We hope you will be able to join us then.

Key Developments

1. Misleading Web Interface Features and “Dark Patterns“

CCCS has signalled a strong stance against the use of “dark patterns” in e-commerce, where online interface features are designed to mislead or unduly pressure consumers.

In a recent case involving an online travel agency (“OTA“), CCCS raised concerns over the OTA’s use of various design features on its Singapore website and mobile application, including:

1. “Preferred” listing badge: CCCS was concerned regarding the OTA’s use of a “Preferred” listing badge on certain property listings without clear disclosure on the criteria that businesses need to meet.

2. Criteria for search results rankings: CCCS noted that the ranking of accommodation search results could potentially lead consumers to believe that the listings were ordered solely based on their search parameters when, in fact, accommodation providers could boost their visibility on the search results by paying the OTA as part of a “Preferred Partner program” or by sponsoring their own listings.

3. Time limit to complete booking: CCCS was concerned that the initial time limit on the website’s countdown timer may not be adequate and might create a false sense of urgency for consumers to quickly complete the booking.

The OTA has since provided a voluntary undertaking and cooperated with CCCS to implement changes to provide clearer, more accurate information to consumers.

CCCS has reminded businesses to ensure that user interfaces present options neutrally, that material information is not hidden in fine print, and that all statements regarding the practices and policies of a business are clear and easily understood.

This case illustrates CCCS’ targeted efforts to improve the online commerce experience for consumers, and its strict position on what might constitute a misleading website user interface.

2. Posting Fake Reviews

Given the significant influence that online reviews have on consumer decision-making, this is a key area of focus for CCCS. Any manipulation of online reviews will see severe action being taken.

In July 2025, CCCS published its investigation into an automotive detailing company for the posting of fake reviews, including the unauthorised use of customer names and photographs. The company admitted to the practice, and that it had used ChatGPT to generate customised review content based on services provided to the customer. The company subsequently undertook to remove the fake reviews, established a feedback channel for reporting such reviews, and published corrective notices. The company’s director also provided an undertaking not to engage in unfair trade practices.

This is the second publicised fake review case uncovered by CCCS, and the first case that involves the use of artificial intelligence (“AI“) and a third-party platform to artificially boost a business’ perceived popularity and ratings. CCCS highlighted the use of AI in this case, and that such deceptive practices constituted an example of “dark patterns”.

This case underscores CCCS’ commitment to ensuring the authenticity of online reviews as well as its focus on enforcement against “dark patterns”. Businesses are reminded to ensure that all reviews are genuine and reflect the experiences of actual customers.

3. Targeting Vulnerable Consumers

Over the past few years, CCCS has investigated, and taken action against, various businesses for using hard selling tactics that target vulnerable consumers. As part of this continuing enforcement trend, CCCS had, on 4 June 2025, received an admission from various hair salon outlets operating under the same brand name and their directors that they had targeted elderly consumers.

In this latest case, CCCS initiated investigations based on a referral from the Consumers Association of Singapore (“CASE“). Through various unannounced visits at these salon outlets, it was found that the businesses drew elderly consumers in by offering free or low-cost haircuts, and subsequently upsold unnecessary and expensive treatment packages through fear-based tactics and concealed pricing. The salons and their directors have since undertaken to cease such practices, to cooperate with CASE to resolve all complaints relating to unfair trade practices, and to provide a five-day cooling-off period for refunds. The companies have also made refunds to all affected customers, totalling approximately S$12,500.

Businesses are reminded to ensure that goods and services are recommended based on genuine consumer needs, and that all sales practices (especially those involving vulnerable groups) are transparent and fair. Notably, CCCS has put the onus on businesses, when dealing with vulnerable consumers which may include the elderly, to exercise extra care before completion of the sale. Businesses should therefore train consumer-facing employees to check that the consumer fully understands and agrees to what they are buying and the price that they are paying, particularly where additional services or packages are involved.

4. Criminal Penalties for Persistent Non-Compliance

In a significant development, CCCS has successfully defended the District Court’s prior decision to impose a jail sentence on the managing director of two nail salons for failing to comply with court orders in relation to various unfair practices under the CPFTA.

CCCS had earlier obtained court orders requiring the two salons to publish details of declarations and injunctions against them for engaging in unfair practices in four major Singapore newspapers, and to notify consumers and obtain their written acknowledgements of the court orders before entering into sales contracts with them. When the salons failed to do so, CCCS commenced contempt of court proceedings against the businesses and their managing director.

In upholding the imposition of a jail term (although the duration was reduced from four months to three months on account of the salons’ eventual compliance with the publication orders), the High Court stressed that a jail sentence was warranted in view of the persistent disregard of court orders by the businesses and their managing director, and the prejudice caused to customers.

This case demonstrates the real risk of criminal penalties for directors and businesses that repeatedly flout the CPFTA. As such, businesses should cooperate promptly with CCCS if an investigation is initiated and take all necessary steps to fully rectify any unfair trading practices.

5. Court Orders Obtained for Misleading Trade Practices across Affiliated Businesses 

Most recently, CCCS obtained court orders against three immigration consultancy firms, all directed by the same individual, for engaging in misleading trade practices. These firms used deceptive web features and misleading claims to persuade customers to use their services. The unfair trade practices involved misleading consumers on the urgent need to apply for Singapore Permanent Residency and guaranteeing the success of applications made through these firms.

CCCS commenced investigations against the first firm after CASE received multiple consumer complaints. The investigations revealed that the same individual had ceased operations of the first firm and resumed similar practices through two other entities to evade detection. He was found to have directed all three businesses, personally scripting sales pitches for staff, monitoring their sales tactics through closed-circuit television footage, and enforcing a punishment-and-reward system to ensure that staff complied with his methods.

This case marks CCCS’ first court action against a person who used new business entities to evade detection of unfair trade practices. Attempting to circumvent investigations by rebranding or restructuring will not shield individuals from accountability, as CCCS has shown it will pursue court action across related entities to stamp out such deceptive practices. 

6. Expanded Regulatory Scope for CCCS

Effective 1 July 2025, the consumer product safety and legal metrology functions previously administered by Enterprise Singapore have been transferred to CCCS. Following the transfer, the Consumer Product Safety Office and the Weights and Measures Office now operate under the purview of CCCS. This development significantly strengthens CCCS’ regulatory oversight over consumer protection matters.

This consolidation of consumer protection, legal metrology and competition functions under CCCS will serve to ensure that businesses operating in Singapore sell products that meet requisite safety standards, as well as adopt accurate measurements when dealing with consumers. The integration also provides a more comprehensive regulatory framework and equips CCCS with enhanced tools to continue to strengthen market integrity, to promote business innovation and to foster Singapore’s position as a leading business hub.

Businesses should note that all existing regulatory requirements, registrations, and certificates will remain valid and enforceable under CCCS’ authority. Businesses are advised to continue adhering to all applicable regulatory obligations during and after this transition to ensure ongoing compliance.

Conclusion

The CPFTA has bite for businesses and directors who perpetuate unfair trading practices, and active enforcement is here to stay. Such enforcement extends over the usual ploys in the brick-and-mortar world, as well as over digital marketing strategies, the use of persuasive web design features, and undue pressure sales tactics. Given the more comprehensive set of regulatory functions that CCCS now holds, it is all the more important for businesses to take stock of their trading practices to align with the CPFTA.

Therefore, we strongly encourage our clients to review their current compliance frameworks and consumer-facing practices in light of CCCS’ broadened regulatory scope and enforcement powers. 

If you have any questions about the issues raised in this Update or require tailored guidance and training sessions to navigate the increasingly complex regulatory landscape, please do not hesitate to reach out to our Team members set out on this page.