Digital Markets, Human Consumers: Consumer Protection and Enforcement Developments in Singapore

ENFORCEMENT ON THE RISE

In the past few years, the Competition and Consumer Commission of Singapore (CCS) has taken an increasing amount of enforcement action against errant retailers for breaches of the Consumer Protection (Fair Trading) Act (CPFTA). From 2023 to 2025, the CCS reported 15 instances of enforcement action, as compared to 8 instances of enforcement action from 2020 to 2022.

The CCS has also showed that it is capable of using the full range of its enforcement powers in appropriate cases:

• In May 2025, the CCS obtained a three-month imprisonment sentence for contempt of court against a managing director whose businesses had engaged in unfair trade practices. The individual had failed to comply with earlier court orders that the CCS had obtained against him and his businesses. This was the first case in which the CCS had instituted contempt proceedings against an errant business and its manager for breaching court orders.

• In another landmark case in August 2025, the CCS obtained court orders against several immigration consultancy businesses that had engaged in unfair trade practices by misleading consumers that there was an urgent need to apply for Singapore Permanent Residency. These businesses were run by the same individual, who attempted to use new business entities to evade detection. The court ordered the individual and the businesses to cease the unfair practices and notify the CCS about any change to business structures or the individual's ownership of the businesses.

ENFORCEMENT TRENDS

The CCS's recent cases and publications have also provided an insight into its enforcement priorities, which include combating dark patterns in e-commerce and greenwashing.

Dark patterns in e-commerce

"Dark patterns" are deceptive techniques used by online platforms to trick users into doing certain things that they had not intended to do, such as purchasing additional products or signing up for subscriptions. The CCS has taken enforcement action against errant retailers for using dark patterns in several reported cases over the past year:

• In June 2025, the CCS raised concerns that an online travel agency had implemented certain design features on its website that could mislead consumers. These included presenting certain search results for accommodation as "Preferred" without disclosing that businesses had to pay more to the online travel agency for this ranking, and imposing a 5-minute countdown timer to complete accommodation booking which might pressure customers to quickly complete the booking.

• In July 2025, the CCS took action against an automotive detailing centre for publishing AI-generated fake reviews on an online car platform. The business had used their customers' information, including names, vehicle registration numbers and photographs, to post five-star reviews without their consent. This is an unfair trade practice, as it misleads consumers into thinking that the business' services are better than they actually are.

• In December 2025, two retailers were found to be using misleading website design features. The first retailer automatically added certain items into consumers' shopping carts without seeking their consent – colloquially known as "Sneak into Basket" – putting them at risk of purchasing unwanted products if they did not remove the items. The second retailer used problematic features such as fake countdown timers, misleading stock indicators, unsubstantiated shortage claims and inflated discounts to create a false sense of urgency when consumers made purchases.

In September 2025, the CCS also updated the Technical Reference 76 on Guidelines for electronic commerce transactions (TR 76). The TR 76 was first published in 2020, and provides e-commerce marketplaces and retailers with guidance on industry best practices for online transactions.

Updates to the TR 76 include:

• Enhancing consumer trust by providing guidance on fake reviews, misleading user interfaces, ensuring the accurate display of information in product listings, and making merchant terms and conditions more easily accessible by consumers.

• Promoting a competitive e-commerce market by providing guidance on fair dealings in e-marketplaces and e-retailers, facilitating the appropriate use of automated tools and artificial intelligence.

• Enhanced anti-scam measures, such as recommending e-commerce businesses to conduct due diligence on merchants to verify their identify, implement measures to protect customers upon detection of fraudulent activity, and facilitate investigations by the CCS.

GREENWASHING

Greenwashing refers to conduct that deceives or misleads consumers into believing that a supplier's practices or goods and services are more environmentally positive than they actually are.

Greenwashing has been on the CCS's radar for several years. In November 2023, the CCS conducted a study on greenwashing in online marketing which found that more than half of online product claims were vague with insufficient elaboration or details to support the claims. Certain websites were most likely to contain unsubstantiated environmental claims, in particular those relating to electronics and physical media, books and marketplaces.

In October 2025, the CCS published a guide on making claims relating to qualities, uses, or benefits associated with businesses and products (Quality-Related Claims). While the guide applies to all Quality-Related Claims, the CCS indicated that it was prompted to publish the guide by greenwashing concerns arising from its November 2023 market study, and the recent uptick in enforcement against misleading claims by businesses.

The CCS's guide sets out five key principles for businesses when making Quality-Related Claims. Such claims should be:

1. True and accurate;
2. Clear and easily understood;
3. Meaningful;
4. Accompanied by material information; and
5. Supportable by evidence

Recent enforcement action against greenwashing has been taken by other regulators which the CCS works closely with, such as the Advertising Standards Authority of Singapore (ASAS), which is the self-regulatory body of the advertising industry in Singapore. In December 2023, ASAS asked an electronics retailer to amend or remove an advertisement which claimed that using its air-conditioner model was the "best tip" to "save Earth", which ASAS considered to be misleading and in breach of the Singapore Code of Advertising Practice (Advertising Code). In January 2024, ASAS banned a "Green Friday" promotion by a budget airline which claimed that its "eco tickets" could "contribute to a greener future". ASAS found that these claims only applied to specific aircraft and engine combinations within the airline's fleet, and consumers could not be assured of realizing the claimed reductions in fuel consumption and emissions.

While the CCS itself has not published any reported cases concerning greenwashing, we expect to see a rise in enforcement action given the CCS's recent guidance on Quality-Related Claims. Businesses should therefore ensure that any claims about the quality of their products and services – in particular environmental claims – adhere to the five key principles set out in the CCS's guide.

Greenwashing enforcement also reflects the increasing convergence between consumer protection, ESG regulation and digital marketing practices in Singapore and globally. For more information about how these themes play out across various industries, please refer to our quarterly Green Claims round-up at this link.

With thanks to additional contributor Isabel Ang.