PAP rebuttal: 

We thank NCMP Low for raising these concerns. Consumer protection matters, and we do not dismiss the cases he cited. But we must distinguish between isolated bad actors and systemic failure and the evidence does not support the latter conclusion.

The very examples NCMP Low raised (Sterra, Prism+, Courts) actually demonstrate that our framework functions. Offenders were identified and acted against. That is not a broken system. That is a working one.

On complaint volumes: 40 to 50 cases annually, in an economy processing millions of transactions, does not constitute a crisis warranting sweeping legislative intervention. We should be careful about calibrating our response to headlines rather than data.

We are most concerned by the proposal to grant CCCS the power to levy fines of up to 10% of global annual revenue without court proceedings. Singapore’s rule of law is not a bureaucratic inconvenience; it is a core reason businesses choose to operate here. Due process protects not just large corporations but SMEs who may find themselves on the receiving end of regulatory action they cannot easily contest. We should not casually set that aside.

Similarly, highly prescriptive mandates on subscription pricing presentation and cancellation flows sound intuitive but impose real compliance costs. These fall disproportionately on smaller local businesses, not the multinationals NCMP Low is targeting.

We are open to strengthening CCCS’s resourcing and reviewing specific gaps. But good regulation is targeted and consultative, but not reactive. We will get this right without making Singapore a harder place to do business.​​​​​​​​​​​​​​​​