The Singapore law that writes half an email marketing scope, and which supplier type can sign it

Hire on three answers and the first one is legal rather than creative. Who writes and checks the compliance mechanics that Singapore statute requires on an unsolicited commercial message, because the Spam Control Act 2007 deems the business whose product is advertised to have authorised the sending unless it takes reasonable steps to stop it. Then, who owns the list and the sending domain, which is always you. Then, what arrives each month, counted in campaigns, flows and tests. Platform choice comes fourth, and it is the easiest of the four to change later.

This page quotes the statute as read, sets out the contract lines, and reports what two assistants named when a Singapore buyer asked this question. Nothing here is legal advice and a specific question about your own sending belongs with a Singapore lawyer. There is no search volume on this page and none exists for the question.

What the assistants named, and what they could not price

On 26 October 2026 we ran 64 blind pipelines across 32 batches on ChatGPT and Gemini with Singapore written into every prompt. In the batch carrying the email questions, HubSpot was named in the answer prose of both readings. Our own name appeared zero times across all 32 blind batches, and the brand batch that names us inside its own prompt is excluded from every count here.

So we read the named vendor's own page. On 27 October 2026 the HubSpot marketing pricing page returned HTTP 200 and carried no dollar, pound or Singapore dollar figure in its served document, because the ladder renders after a script runs. That is reported as it was read rather than filled in from memory. The cited sources in that batch also included localrank.sg, halotechmedia.sg, hashmeta.com, marketingagency.sg, techdirectory.sg and dupple.com on the supplier side, and www.omnisend.com, www.hubspot.com, help.zoho.com and www.pipedrive.com on the platform side. We requested hashmeta.com on 27 October 2026 and it returned HTTP 403, so no figure from that supplier appears anywhere on this page. That is a reading about our request rather than a statement about its prices.

The statute, quoted, because it decides the scope

Singapore Statutes Online records the Spam Control Act 2007 with its status as the current version as at 27 October 2026. Four provisions change what you should be buying.

• Your supplier's sending is treated as yours. Section 3(4) provides that, subject to subsection (5), "a person who knowingly allows the person's product or service to be advertised or promoted by a sender is deemed to have authorised the sending by the sender of any electronic message that advertises or promotes that person's product or service". Subsection (5) provides that a person who takes reasonable steps to stop such sending is deemed not to have authorised it. In plain terms, outsourcing the send does not outsource the position, and the reasonable steps are the thing to write into the contract.
• An unsubscribe facility is specified, not implied. The Second Schedule requires the message to carry an email address, internet location address, telephone number, fax number or postal address that the recipient may use to submit an unsubscribe request, together with a statement to that effect, and where the message is received by email it "must include an email address to which the recipient may submit an unsubscribe request".
• There is a labelling requirement. The same Schedule requires the letters ADV, printed there enclosed in angle brackets, to appear "with a space before the title in the subject field, or if there is no subject field, in the words first appearing in the message, to clearly identify that the message is an advertisement".
• The unsubscribe deadline is ten business days. Where a recipient submits an unsubscribe request using that facility, "no further unsolicited commercial electronic messages may be sent after the expiry of 10 business days after the day on which the unsubscribe request is submitted". The Act also defines bulk by three thresholds: more than 100 messages containing the same or similar subject matter in a 24 hour period, more than 1,000 in a 30 day period, or more than 10,000 in a one year period.

Read as a buyer, that is a specification. Somebody has to decide for each programme whether a send is unsolicited, apply the label where it is, keep the unsubscribe facility working, and honour requests inside ten business days. Ask which named person does each, and whether it is inside the fee.

Phone and SMS, where a second registry applies

If the programme includes calls or text messages to Singapore numbers, the Do Not Call Registry is the other half. Its own site states that, with effect from 2 January 2014, organisations must check with the registry to ensure that the Singapore telephone numbers they are sending telemarketing messages to are not listed, and that an organisation applies for a DNC Checking Account for that purpose. It also states that consumer registration is free and does not expire. Read on dnc.gov.sg on 27 October 2026.

Two practical consequences. The checking account should be in your company's name, so the check records are yours. And the check is an event with a date, so it belongs in the monthly report rather than in a reassurance.

The three things sold under this name

They suit different buyers and the generic breakdown, with the fee models and what each one quietly encourages, is in our page on what an email retainer covers and why the list and the platform matter more than the fee. In short, a lifecycle and retention programme is the strategic version, campaign production is hands rather than strategy, and deliverability work is a project bought after inbox placement collapses. A Singapore buyer should add a fourth question to that framework, which is who holds the compliance mechanics above.

The contract lines to require in Singapore

1. The list is yours and never moves. Including the suppression list, which is the record that proves unsubscribes were honoured.
2. The sending domain is yours. With authentication records in your DNS, so reputation stays with you when the supplier changes.
3. The platform account is in your company's name. The supplier is a user on it. The licence fee is a separate line from the fee for the work.
4. Named responsibility for the statutory mechanics. Who decides whether a send is unsolicited, who applies the label, who monitors the unsubscribe route and who confirms the ten business day cut off.
5. Consent and source records. For every segment, where the addresses came from and what the person was told at the point of collection.
6. Deliverables as counts. Campaigns built, flows maintained, tests run, segments created. A monthly figure with no counts cannot be enforced.
7. Return and deletion. What comes back, in what format, and what the supplier deletes afterwards, with written confirmation.

Winning back customers who stopped buying, without discounting

This is the request that usually prompts the hire, and the answer is a sequence rather than an offer. Segment by what the person actually did: bought once and never returned, bought repeatedly then stopped, or opened everything and never bought. The three need different mail. Then write from a person at your company rather than from a brand, ask a question that can be answered in one line, and make the reason to return informational rather than financial, such as what changed in the product, a restock of the thing they bought, or a service they never used. Keep the discount in reserve for the people who do not respond to any of that, because a discount offered first teaches the whole base to wait for one.

The compliance point applies here too. A win back send to somebody who has not bought in two years may be unsolicited for the purposes of the Act, and that is a decision somebody has to make and record before the send rather than after it.

Questions about buying email marketing in Singapore

Do I need an agency or a consultant for email in Singapore

A consultant is usually the better first purchase, because the early work is diagnosis, list hygiene and three or four automated flows, which is a finite job. Move to a retained agency when the calendar is continuous, the segments are several and somebody has to build and send every week.

Does the Spam Control Act apply to my newsletter

It depends on whether the message is an unsolicited commercial electronic message in the terms the Act uses, which turns on what the recipient asked for and consented to. That is the judgement to take to a Singapore lawyer, and the practical move is to keep a consent record per segment so the question is answerable from your own files.

Who should own the email platform account

Your company, with the supplier added as a user. The list, the suppression list and the sending domain are assets, and the day the relationship ends is the day that ownership matters most.

What does an email programme cost in Singapore

The two halves are the fee for the work and the platform licence, and they should be quoted separately. Of the vendors cited in our reading, HubSpot served no figure in its marketing pricing document on 27 October 2026, and one Singapore supplier we requested returned HTTP 403, so no Singapore retainer figure is reproduced here. Ask each supplier for the fee, the licence and the production count as three numbers, and ask whether GST at 9 per cent sits inside or outside the fee.

How fast should an unsubscribe be honoured

The Second Schedule to the Act sets ten business days after the day the request is submitted as the point after which no further unsolicited commercial electronic messages may be sent. Most platforms do it immediately, and the thing to verify is that your supplier's own process does not reintroduce a suppressed address from an older list import.

The question your email programme cannot answer

Email reaches people who already gave you their address, which makes it the channel with the cleanest numbers and the narrowest reach. The buyer who has never heard of you is now frequently asking an assistant who to use, and being read two or three names. No email report counts whether your name is in that sentence. A dated reading of your own buyer questions across ChatGPT, Gemini, Perplexity, Claude and Google AI Overviews does, with the sources behind each answer shown, and AI Knows Us was built to take it. The first one at aiknowsus.com needs no account, so the comparison between what your list hears and what a stranger is told costs nothing to run.