Governance of a City-State
What good consultation leaves behind

At an appreciation event in September for people who had contributed to Singapore’s Online Safety (Relief and Accountability) Act (OSRAA), Minister for Law Edwin Tong began by acknowledging the victims who had come forward and told their stories.

Their experiences, he said, gave policymakers greater conviction that something had to be done, and that they had to get the response right.

Later, he made another point that interested me. The Online Safety Commission (OSC) established under OSRAA had received more than 500 reports in its first two months, with more than 90 per cent of eligible cases resolved. But success, he said, should not be measured by cases processed. “We should want people to rely on or need the OSC less and less, not more and more.”

The first point is about how policy gets built through listening. The second is about what happens after the policy is implemented. Together, they raise a larger question: what should good consultation leave behind?

Public consultation is often measured by its activities: how many sessions were held or how many people participated. A more useful test is what happens afterwards. Can people see their concerns reflected in the policy that emerged? And do the people who helped still have a stake in what happens once a policy is implemented?

When consultation is sustained

The new Act is an interesting case because the consultation unfolded over several years.

In developing the legislation, the Government engaged more than 100 stakeholders, including community partners, academics and industry, alongside a public consultation. The process continued as the proposals became more concrete. At the appreciation event, Mr Tong described consulting and reconsulting, drafting and redrafting, with decisions continuing to change close to the Bill’s introduction in Parliament.

That continuity made a difference, even if it took time.

The early work involved a fair amount of sense-making. What were victims actually experiencing? Where did existing remedies fall short?

As the policy took shape, those questions became much more concrete.

Someone whose intimate image is circulating online does not experience the problem as a regulatory gap. They want the image down. Now.

Someone being attacked from behind an anonymous account may want to know who is doing it.

Someone who has just realised that what is happening to them amounts to an online harm may simply be trying to work out what to do next.

Many of these realities are reflected in the design of the relief system.

There is no single route into the OSC for every harm. Someone experiencing online harassment or stalking generally reports the content to the platform first. If the platform does not respond adequately within 24 hours, the victim can turn to the OSC.

For intimate image abuse, image-based child abuse and doxxing, victims can approach the OSC directly. This can sound like a small administrative distinction. But for someone whose intimate image is spreading, every hour spent working out whom to approach is another hour in which it circulates.

The legislation also tackles anonymity. The OSC can, in specified circumstances, require platforms to provide identifying information, and victims can apply for that information to pursue claims under the new statutory torts.

These provisions answer quite basic questions: Can the harm be stopped quickly? Can I find out who is doing this? What can I do about it?

That, to me, is where the consultation shows. People were asked what was happening to them. Some of what was learnt survived the long journey into the design of the law.

The people around the problem learn too

Sustained engagement can build capability around a problem as well.

There is an old newsroom aphorism: “If it bleeds, it leads.”

Online harms are particularly susceptible to that pull. There is no shortage of horrible material: sexual images shared without consent, stalking, threats, humiliation.

The horror is real and sometimes it has to be reported. As a researcher working on online harms since the Sunlight Alliance for Action to Tackle Online Harms in 2021, however, I have been struck by how carefully many journalists covering this beat have handled these stories from early on.

Survivors who agree to tell their stories have already taken a considerable risk. Reporters have had to think about anonymity, how much detail is actually necessary, and whether the telling of the story itself could cause further distress.

They have also learnt the terrain. They increasingly know where victims can seek help, why somebody may hesitate to report, what platforms can do and where the gaps remain.

Reporting what happened is still important. But so is what happened afterwards.

Was the material removed? Did the platform respond? Did the victim know where to go? Was there any way to identify the person responsible?

The story of online harm should not end at the worst thing that happened to someone.

There is a practical reason for that. In our 2025 IPS working paper, Online Harms in Singapore: From Evidence to Action, we found that users can struggle to access meaningful recourse. Some are unaware of the support available or feel that taking action would have little effect. One of our recommendations was to make the reporting process easier to understand, including what steps people should take, what they can expect and where support can be found.

In this light, what journalists record after the harm matters too.

I am not asking for reassuring coverage. If a remedy fails, that is a story. If a platform does not respond, that is a story too.

But journalists also chronicle how a society responds to harm. Showing what happens when someone seeks help, including where relief exists, whether it works and where it still falls short, gives the next person a fuller picture of what they can do.

For somebody staring at their phone and wondering what on earth to do next, that can be useful information

Keeping a stake in what happens next

There is another thing sustained consultation can leave behind.

Over time, a community has formed around online safety in Singapore, bringing together people who came to the issue from very different directions and at different times: people supporting victims, lawyers, researchers, journalists, technology companies, civil society organisations and public officers.

Nobody assembled everyone at the beginning and handed out their scripts in some grand plan.

Yet repeated engagement over several years meant that people could see where their own contribution fitted into the eventual response. More importantly, they still had a stake in whether that response worked.

That continuing sense of stake matters now because the initial consultation could never have answered every question in advance.

The OSC currently handles five of the 13 categories of harm covered by OSRAA. The remaining eight will be progressively implemented. The first cases are already raising questions about harms moving across accounts and platforms, repeated offending, and what AI may enable perpetrators to do.

That suggests a natural next phase for consultation.

Frontline social service agencies can see where victims still struggle and what wraparound support is needed even when a formal avenue of relief exists. Researchers can look across individual cases for patterns, gaps and unintended effects that are harder to see one case at a time.

They do not all need to be brought back into every conversation.

But it would be a mistake to treat the opening of the OSC as the point at which everybody else hands the problem over to the new institution.

That instinct is also consistent with what we found in our IPS research. Singaporeans placed responsibility for online safety across a wide range of actors — not only government and technology companies, but users, parents, schools and social service agencies. The public already appears to understand that online safety is shared work.

The value of consultation lies in the people who remain invested enough to keep testing, questioning and improving the response. Singapore need not assemble from scratch the people who understand different parts of the problem each time the harms changes.

Many of them are already here. Good consultation has left them with a stake in what happens next.

Dr Chew Han Ei is an adjunct senior research fellow at the Institute of Policy Studies, National University of Singapore, and a board member of SG Her Empowerment.

Top Image from Pexels.

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