Singapore Geoblock
Metadata (Normative)
| Title: | Singapore Geoblock |
| Author: | Ralph B. Holland |
| version: | 1..0.0 |
| Affiliation: | Arising Technology Systems Pty Ltd |
| Contact: | ralph.b.holland [at] arising.com.au |
| Publication Date: | 2025-06-19-20:21Z |
| Status: | date when extracted from Main_Page. |
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Singapore
Singapore has one of the clearest statutory exceptions for AI training and text/data mining in the world. The relevant law is the Copyright Act 2021, particularly Part 5, Division 8 (Computational Data Analysis) and the anti-contract-override provisions in Section 187. I decided to geoblock SG. You will notice this block in the later part of the agent/region projection in the 3D graphs.
Official statute
Singapore Statutes Online – Copyright Act 2021
1. Computational Data Analysis (CDA) Exception
- Section 243
- Definition of Computational Data Analysis
Section 243 defines "computational data analysis" broadly. It includes:
- identifying, extracting, and analysing information using computer programs;
- using copyrighted works as examples to improve computer programs.
The Act gives an explicit AI-related example:
- using images to train a computer program to recognise images.
This is significant because the statute itself contemplates machine-learning training as a form of computational data analysis.
- Section 244
- Copying or Communicating for Computational Data Analysis
Section 244 creates the operative exception.
If certain conditions are met, a person may:
- make copies of copyrighted works;
- store or retain those copies;
- communicate copies used for verification or collaborative research purposes.
The key conditions include:
- The copying must be for computational data analysis or preparation for it.
- The user must have lawful access to the source material.
- The copies cannot be used for unrelated purposes.
- Distribution of the copies is restricted to verification and collaborative research contexts.
The statute expressly says that "making a copy" includes storing or retaining the copy, which is important for AI training pipelines and dataset creation.
What counts as lawful access?
The Act gives examples:
- Circumventing paywalls is not lawful access.
- Accessing material in breach of database terms is not lawful access, subject to Section 187's contract-override rules.
In practice, this generally means:
- publicly available webpages;
- subscription content obtained through valid subscriptions;
- licensed databases accessed according to lawful credentials;
are more likely to satisfy the access requirement than hacked, pirated, or bypassed content.
2. Prohibition on Contract Override
- Section 187
- Permitted Uses That May Not Be Excluded or Restricted
This is one of the most unusual provisions.
Section 187 states that contract terms are void to the extent they attempt to exclude or restrict statutory computational data analysis rights under Division 8.
The provision applies to terms that directly or indirectly prevent:
- making copies;
- supplying copies;
- performing works;
where those acts would otherwise qualify as a permitted CDA use.
Why this matters for AI and web data Many websites publish terms such as:
- "No AI training"
or
- "No text and data mining"
Singapore's Section 187 potentially limits the effectiveness of such contractual restrictions where the activity otherwise falls within the statutory computational data analysis exception. The statute specifically identifies Division 8 (computational data analysis) as a category whose permitted uses cannot be contracted away.
The Act also contains an anti-evasion rule in Section 188, which can invalidate contractual choice-of-law clauses if they are used to circumvent Singapore's permitted-use protections.
3. Fair Use Singapore also has a general fair use provision.
- Section 190
- Fair Use
Section 190 provides that:
- fair use of a copyrighted work is a permitted use;
- fair use of protected performances is also a permitted use.
The fair-use analysis is flexible and considers factors such as:
- purpose and character of the use;
- nature of the work;
- amount used;
- effect on the market.
Unlike the CDA exception, fair use is not AI-specific. It functions as a broader safety valve for activities that may not fit neatly within another statutory exception.
4. Why Singapore Is Viewed as AI-Friendly
For AI developers, the combination of:
- Section 243 (broad CDA definition),
- Section 244 (copying for computational data analysis),
- Section 187 (anti-contract-override protection),
- Section 188 (anti-evasion through foreign-law clauses), and
- Section 190 (general fair use),
creates one of the world's most permissive legal environments for training AI systems on lawfully accessed data. Commentators frequently compare it to Japan's similarly broad text-and-data-mining regime.
Practical summary for AI use of web data
Under the Singapore regime, the strongest argument for permissive AI training is:
- Publicly accessible or otherwise lawfully accessed web content may be copied and processed for computational data analysis.
AI training can fall within the statutory definition of computational data analysis.
Contract terms attempting to prohibit otherwise-permitted computational data analysis may be void under Section 187.
Separate questions may still arise regarding unlawful access, database rights, privacy law, confidential information, output infringement, or other non-copyright claims.
So the key statutory provisions are:
- Section Subject Relevance to AI
- 243 Definition of Computational Data Analysis Explicitly includes machine-learning style training examples
- 244 Copying or Communicating for CDA Allows copying and retention for AI/data-mining purposes when conditions are met
- 187 Permitted Uses That May Not Be Contractually Restricted Prevents contractual override of CDA rights
- 188 Choice-of-Law Evasion Rule Prevents contractual circumvention of permitted-use protections
- 190 Fair Use Additional flexible defense for transformative uses
Official source:
- Singapore Copyright Act 2021 (Singapore Statutes Online)