In March 2026, a vocal critic of the Singapore government became the first person to face criminal prosecution under the Protection from Online Falsehoods and Manipulation Act, known as POFMA, the law that Singapore introduced in 2019 as the region’s most technically rigorous anti-disinformation framework. The charges were not brought against a troll farm, a state-sponsored influence operation, nor a coordinated network of inauthentic accounts. They were brought against Jay Ish’haq Rajoo, a private citizen, for TikTok videos that criticized government policies on race and leadership.
Several months later in August 2026, academics and journalists were urging Philippine legislators to reject House Bill 9465, which is a proposed anti-fake news law on the grounds that it replicates precisely the same design flaws that have produced similar outcomes across the region. Their concerns were borne out by the regional evidence on two fronts.
First, that disinformation has not receded in the countries that enacted these laws. The legislative momentum behind anti-disinformation laws in Southeast Asia was not without precedent. Within the four cases this article examines, there is genuine and documented exposure to coordinated information operations that have distorted electoral outcomes, amplified fake news environments, and systematically suppressed accountability journalism.
A 2024 to 2025 study by the RAIDAR project at Chulalongkorn University, drawing on research across Malaysia, Indonesia, Thailand, and the Philippines found that influence operations across the region are not only continuing but evolving, with coordinated campaigns spreading ant-Rohingyan sentiment in Indonesia as recently as 2023, while in Thailand and the Philippines, political fandoms surrounding candidates became increasingly important vehicles for amplifying fake political narratives through social media platforms during the their most recent election cycles. This is further reflected in a 2025 survey of disinformation experts, who reported that the problem is becoming more severe rather than receding, with respondents pointing to the growing sophistication of the role of digital platforms in amplifying false and harmful narratives, and the difficulty of countering them through existing frameworks.
Second, researchers documenting what they term “Anti-Fake News Lawfare” recorded at least 239 instances across Southeast Asia between 2018 and 2024, in which anti-disinformation laws were deployed against civil society actors, journalists, and political opponents, rather than the networks producing coordinated false content. Accumulated across more than half a decade of anti-disinformation legislation points in a consistent direction: the laws designed to protect public discourse from manipulation increasingly indicate a greater capacity to suppress the critics of power than to dismantle the infrastructure of disinformation itself.
The question, then, is not whether disinformation is a problem worth addressing through policy. It is whether the laws that have been passed are actually solving that problem. This article examines that question across four national cases: Singapore, Malaysia, the Philippines, and Vietnam, while also considering the European Union’s Digital Services Act (DSA) as a comparative reference point for an alternative regulatory approach.
Singapore’s POFMA and its limits
Singapore’s POFMA is routinely cited as the region’s most technically sophisticated anti-disinformation framework. Its architecture is genuinely more elaborate than most comparable laws: ministers issue “correction directions” requiring recipients to post government clarifications alongside disputed content rather than simply removing material. It distinguishes between false statements of fact and opinions, and it provides appeal mechanisms through the courts.
A 2023 study by researchers at the S. Rajaratnam School of International Studies found that over half of Singaporean respondents agreed that POFMA was effective in preventing the spread of online falsehoods, and that the law had been frequently deployed during the COVID-19 pandemic to correct health misinformation. On its own terms, as a tool for correcting specific false claims in a specific informational context, POFMA has demonstrated some utility.
But the structural problem is embedded in its design. Under POFMA, it is ministers, elected politicians with obvious interests in how political information circulates, who hold the authority to determine what constitutes a “false statement of fact” and to issue correction directions accordingly. Since POFMA came into force, the pattern of its application has been revealing. For instance, opposition Kenneth Jeyaretnam received at least 10 correction directions; the Transformative Justice Collective, which campaigns against death penalty, received multiple correction directions in 2024 alone; Australia-based academic publication East Asia Forum was blocked entirely in January 2025 after failing to comply with a correction direction about an article analyzing Singapore’s new prime minister. In November 2025, the website MalaysiaNow was blocked for content related to the execution of a Malaysian National.
By March 2026, FORUM-ASIA, Amnesty International, Human Rights Watch, and CIVICUS had jointly called on Singapore to drop the charges against Rajoo and repeal POFMA, characterizing the law as incompatible with international human rights standards on freedom of expression. The government maintained its position.
Retrospectively, POFMA’s trajectory reveals a structural ceiling that technical sophistication alone cannot overcome. When the state is simultaneously the aggrieved party, the prosecutor, and the arbiter of truth, the correction mechanism becomes indistinguishable from censorship, regardless of how carefully the law is drafted.
Vietnam and the law of disinformation
Vietnam’s approach to online speech regulation represents the starkest version of the dynamic POFMA exemplifies. The 2018 Cybersecurity Law, updated through Decree 147 in December 2024 and replaced by an entirely new Cybersecurity Law passed in December 2025, and effective July 2026, has constructed what critics describe as a “comprehensive architecture of digital repression.”
The law requires social media platforms to remove content the government deems “toxic” within 24 hours, mandates the storage and handover of user data to authorities on demand, and requires real-name verification for accounts, effectively eliminating anonymous speech. In 2024 alone, Vietnamese courts convicted at least 36 critics under laws nominally targeting fake news and anti-state content; Freedom House rated Vietnam as a country with no internet freedom that year. The new 2025 law expands prohibited acts to include content “causing division among people” and “hindering the policy of international solidarity,” categories broad enough to encompass virtually any form of political opposition.
As one analysis observed, the allegation of “fake news” has become the “latest rhetorical explanation to justify suppression” of dissent in Vietnam: not a genuine effort to distinguish false information from fact, but a legal vocabulary available to any government that needs it. This distinction matters analytically, as Vietnam’s cybersecurity framework was never primarily a disinformation law. For many, it was always considered a speech control law that adopted disinformation as its justification.
Malaysia and its reform path
Malaysia offers the region’s most instructive counter-trajectory. Its 2018 Anti-Fake News Act, passed under then-Prime Minister Najib Razak and widely criticized as an instrument to suppress coverage of the 1MDB scandal was repealed the same year after opposition forces won the general election. The repeal demonstrated the law’s political character to which it had been enacted to serve a specific administration’s interests, and dissolved when those interests changed.
However, in early 2025, Malaysia’s lower house passed the Malaysian Media Council Bill, establishing an independent co-regulatory body of 21 representatives drawn from media companies, media associations, and civil society stakeholders, institutionally insulated from direct government control. The Council is expected to recommend reforms to legacy laws, such as the Printing Presses and Publications Act and the Official Secrets Act, both long criticized as obstacles to investigative journalism, and to support the passage of a Freedom of Information Act. In 2025, Malaysia jumped 19 places in the World Press Freedom Index, landing at 88th globally.
Malaysia’s trajectory is not without complications. A fact-checking culture has not yet been widely embraced among the public; TikTok and Facebook are simultaneously the country’s fastest-growing news sources, and the platforms its government identifies as the primary vectors of mis- and disinformation. Hence, the Malaysian Media Council’s independence will be tested by its first significant cases. Yet, the directional shift, from state arbitration of truth toward independent multi-stakeholder governance represents the most substantive reform the region has produced.
The Philippines: At the decision point
The Philippines occupies a different position from its neighbors. Surprisingly, it has not yet passed a dedicated anti-fake news law, and the debate over whether to do so is live, contentious, and consequential.
House Bill 9465, currently before the Philippine legislature, seeks to criminalize the creation and dissemination of content deemed false by authorities, imposing fines and possible imprisonment for violations. As Ong writes, the “vagueness is built into the measure to grant political authorities the power to act as ‘primary arbiters of truth’ who could label dissent as disinformation and activism as troll behavior.”
The bill’s fundamental premise, that disinformation originates with ordinary citizens sharing false content, misreads a decade of Philippine disinformation research. Ong’s own work, “Architects of Networked Disinformation,” documented that political disinformation in the Philippines flows from the top down. Ong asserts that mis- and disinformation is funded by political elites, produced by professional networks, and amplified through coordinated inauthentic behavior.
The timing compounds this concern. With the 2028 national elections approaching, and the Marcos-Duterte political fallout reshaping the information environment, the passage of HB 9465 would hand whichever administration holds power in 2027 a legal mechanism to characterize electoral opposition as disinformation. Thai political scientist Janjira Sombatpoonsiri has described this regional pattern as “weaponized warfare,” where autocratic and autocratizing governments learning from each other how to combine legal mechanisms with online influence operations to consolidate control. Given the preceding, the Philippines would not be inventing something new. It would be adopting a regional template whose outcomes are already documented.
The DSA Model: A framework with caveats
Beyond ASEAN, the European Union’s Digital Services Act fully enforced since February 2024, offers a structurally different point of comparison. Rather than granting state actors the power to determine what is false, the DSA targets the platforms that amplify disinformation at scale. In the act, Very Large Online Platforms (VLOP) are required to conduct systemic risk assessments, submit independent audits, and maintain algorithmic transparency; the EU’s Code of Practice on Disinformation was formally integrated into the DSA Framework in February 2025, making it a binding benchmark for platform compliance.
The DSA places greater accountability on platforms rather than individual users, redirecting regulatory attention toward the actors with the greatest structural influence over online information environments. Investigations involving Meta, TikTok, and X have examined issues such as systemic risk management and advertising transparency, rather than focusing exclusively on the accuracy of individual posts. This approach is a meaningful reorientation, one which addresses the infrastructure through which disinformation spreads rather than merely its symptoms.
The DSA’s implementation record, however, counsels against treating it as a finished answer. Platforms reduced the measures they voluntarily pledged under the Code of Practice on Disinformation by 31 percent between 2022 and 2025; Microsoft and Google withdrew from their fact-checking commitments, and the Code’s integration into the DSA does not resolve its foundational definitional gap, since disinformation appears only in the law’s non-binding recitals rather than its operative provisions, leaving platforms and regulators to negotiate what “systemic risk” means without a settled legal reference point. Moreover, enforcement gaps across 27 member states with differing judicial traditions and regulatory capacities further illustrate that the distance between what the DSA promises, and what it consistently delivers remains significant, even within the EU’s relatively established institutional environment.
For Southeast Asia, these challenges compound considerably. The institutional preconditions the DSA assumes, including independent auditors, multi-stakeholder oversight bodies, and enforceable platform obligations, are precisely the capacities that anti-disinformation frameworks across the region have most consistently failed to build. The DSA’s core principle that effective disinformation governance should target the infrastructure that amplifies content rather than individual truth claims, offers a credible alternative to state-centric approaches. Yet, adapting this model to Southeast Asia would require confronting the institutional gaps that continue to constrain its implementation, even within the jurisdiction where it was developed.
Looking Ahead
Taken together, the four cases point to a coherent regional pattern. Governments across Southeast Asia have responded to genuine concerns about disinformation by adopting laws that give the state substantial authority to determine and regulate what constitutes false information. In practice, these powers have also been applied most reliably not against coordinated influence operations or their financiers, but against journalists who publish inconvenient truths, opposition politicians who challenge official narratives, civil society actors, and ordinary citizens whose posts attract the attention of public officials. These are the groups with the least institutional protection and, in many cases, the most to lose from broadly worded speech laws. There are also the people who have borne much of the cost at the heart of the question this article asks.
Albeit, the current issue is not whether disinformation poses a serious problem that warrants action. It does. The more difficult question, and one that the region has yet to fully resolve, is who should have the authority to determine what constitutes disinformation, and what protections exist for those who are on the receiving end of that definition. The four cases examined here suggest that the central risk lies not simply in giving governments the power to respond to disinformation, but in allowing the same political institutions that may benefit from controlling the information environment to determine what counts as false and what consequences follow. Malaysia’s trajectory and the DSA’s structural approach together suggest that durable answers lie not in concentrating that authority in the state, but in distributing it across independent institutions insulated from the political pressures that have, in every case surveyed here, bent anti-disinformation law toward the interests of whoever holds power. The question, then, is whether people and institutions can shape a system in which that authority is not only exercised, but also is constantly questioned, challenged, and held accountable.
This article reflects reporting and analysis made by The Southeast Asia Pacific Frontier. If you have additional context, a different take, or a perspective we’ve missed — whether you’re a researcher, a policy practitioner, or someone living with these realities on the ground — this is an evolving story and we’d like to hear from you. Drop a comment below or get in touch.
About Timothy John Santiago
Timothy John Santiago is a graduate of BA in Philosophy from the University of Santo Tomas. Professionally, he works in risk intelligence AI, leveraging DaaS and SaaS platforms alongside open-source intelligence to support data-driven research. He is also active in public service, serving in various youth and policy initiatives.




