Influencer Agreement (Singapore)

An Influencer Agreement in Singapore fixes the respective duties and entitlements of the parties to the arrangement.

The ASAS Guidelines on Interactive Marketing Communications and Social Media, issued in alignment with the International Chamber of Commerce (ICC) Code on Advertising and Marketing Communication Practice, require influencers and brands to clearly disclose sponsored content and material connections. Sponsored posts, paid partnerships, gifted product reviews, and affiliate marketing arrangements must be disclosed using clear and prominent labels (such as #ad, #sponsored, or #paid) placed at the beginning of the content, not buried within hashtag lists or below the fold. Failure to disclose material connections constitutes misleading advertising under the SCAP and may trigger enforcement action by ASAS.

The Consumer Protection (Fair Trading) Act 2003 (Cap. 52A) prohibits unfair practices, including making false claims about products or services and failing to disclose material information that would affect a consumer's purchasing decision. The CCCS may investigate influencer marketing campaigns that involve deceptive practices, and consumers may seek remedies through the Consumers Association of Singapore (CASE) or the Small Claims Tribunals of the State Courts.

The Personal Data Protection Act 2012 (PDPA) applies to influencer marketing where the campaign involves the collection, use, or disclosure of personal data — for example, influencer campaigns that collect consumer data through competition entries, survey responses, or user-generated content submissions. The Personal Data Protection Commission (PDPC) requires organisations engaging influencers to impose contractual PDPA compliance obligations, including data protection, purpose limitation, and consent requirements.

Intellectual property rights in influencer-created content are governed by the Copyright Act 2021 and administered by the Intellectual Property Office of Singapore (IPOS). Under the Copyright Act 2021, the influencer (as creator) owns copyright in the content they produce unless the agreement expressly assigns or licences IP rights to the brand. Brands that wish to repurpose influencer content across their own marketing channels must secure appropriate IP rights through the influencer agreement.

For regulated industries — financial services (MAS Guidelines on Fair Dealing), healthcare (HSA Medicines Advertisement Regulations), food and beverages (SFA labelling requirements), and telecommunications (IMDA advertising codes) — influencer marketing campaigns must comply with sector-specific advertising regulations in addition to the general ASAS and CCCS requirements.

Singapore’s Infocomm Media Development Authority (IMDA) — the statutory board responsible for regulating the infocomm and media sectors — oversees internet content standards under the Broadcasting Act 1994 (Cap. 28) and the Internet Code of Practice. Influencer content published on social media platforms accessible in Singapore is subject to IMDA’s content guidelines, which prohibit content that is contrary to public interest, public order, public morality, or racial and religious harmony. Influencer agreements should include compliance obligations covering IMDA content standards, in addition to the ASAS advertising disclosure requirements and CCCS unfair practices provisions.

An Influencer Agreement is needed whenever a Singapore brand or company engages a social media influencer to create and publish sponsored content promoting the brand's products, services, or campaigns across digital platforms.

Product launch campaigns engage influencers to create awareness and generate interest in new products entering the Singapore market. Brands in fashion, beauty, food and beverage, electronics, and lifestyle sectors frequently engage multiple influencers across Instagram, TikTok, YouTube, and other platforms to create coordinated launch campaigns. The influencer agreement specifies the number of posts, the platforms, the content format (static posts, stories, reels, videos), the key messaging, and the disclosure requirements under ASAS guidelines.

Ongoing brand ambassador arrangements establish a longer-term relationship between the brand and the influencer, typically spanning 3 to 12 months with monthly content deliverables, event appearances, and exclusivity provisions preventing the influencer from promoting competing brands. Ambassador agreements require careful drafting of exclusivity clauses, content approval processes, and termination provisions.

Affiliate marketing arrangements engage influencers to promote products using unique discount codes or affiliate links, with the influencer receiving a commission on sales generated through their content. The influencer agreement must address commission rates, tracking mechanisms, payment frequency, and the influencer's disclosure obligations under ASAS guidelines (affiliate relationships are material connections that must be disclosed to consumers).

Regulated product campaigns require influencer agreements with additional compliance provisions. Financial services companies regulated by the Monetary Authority of Singapore (MAS) must comply with MAS Guidelines on Fair Dealing and the Financial Advisers Act (Cap. 110) when engaging influencers to promote financial products. Healthcare and pharmaceutical companies must comply with the Health Sciences Authority (HSA) Medicines (Advertisement and Sale) Act (Cap. 177) and the Medicines (Advertisement) Regulations. Food companies must comply with the Singapore Food Agency (SFA) Sale of Food Act 1973 (Cap. 283) labelling and advertising requirements.

Event and experiential marketing engages influencers to attend brand events, product launches, and experiential activations in Singapore, creating live content (stories, live streams, event coverage) for their followers. The influencer agreement should address event logistics, content specifications, attendance requirements, and the brand's right to use event content across its own channels.

An Influencer Agreement under Singapore contract law must contain the following elements to establish a clear and enforceable engagement framework compliant with ASAS disclosure guidelines, PDPA requirements, and intellectual property provisions.

Party identification requires the brand's full legal name, ACRA UEN, registered address, and the name and designation of the brand's marketing contact or authorised signatory. The influencer's full legal name (not social media handle only), NRIC or FIN number, residential address, and social media handles across all relevant platforms (Instagram, TikTok, YouTube, Facebook, Twitter/X, LinkedIn) with current follower counts and engagement metrics should be stated.

Campaign details must specify the campaign name or project identifier, the product or service being promoted, the campaign duration (start and end dates), the target audience demographics, and the key marketing messages or talking points. The campaign brief — typically attached as a schedule — should outline the brand's creative direction, tone of voice guidelines, mandatory mentions (brand name, product features, hashtags), and any restrictions on content (prohibited claims, competitor references, sensitive topics).

Content deliverables must itemise the specific content the influencer is required to create and publish: number of posts per platform, content format (static image, carousel, story, reel, video, blog post, live stream), minimum and maximum content duration (for video content), publication schedule (specific dates or flexible windows), and platform-specific requirements (Instagram feed vs. stories, TikTok vs. YouTube). Content approval process — whether the brand has the right to review and approve content before publication, the review turnaround time, and the number of revision rounds — must be clearly defined.

Disclosure and ASAS compliance must require the influencer to comply with the ASAS Guidelines on Interactive Marketing Communications and Social Media by including clear and prominent disclosure labels on all sponsored content. The specific disclosure format (#ad, #sponsored, Paid Partnership tag, or other approved format) and placement (beginning of caption, first line of description) should be mandated. Non-compliance with disclosure requirements should be grounds for withholding payment or terminating the agreement.

Exclusivity provisions must define whether the influencer is restricted from promoting competing products or services during the campaign period and any post-campaign exclusivity window. The agreement should list specific competitor brands or product categories covered by the exclusivity restriction. Broader exclusivity periods typically command higher fees.

Fees and payment terms must state the total engagement fee (or fee per content piece), payment schedule (upfront, upon publication, or milestone-based), payment method (bank transfer, PayNow), and any additional compensation (performance bonuses based on engagement metrics, affiliate commissions, product gifts). GST at 9% under the Goods and Services Tax Act (Cap. 117A) applies if the influencer is GST-registered. Income tax obligations under the Income Tax Act 1947 (Cap. 134) are the influencer's responsibility.

Intellectual property rights must address ownership and licensing of the content created under the agreement. The brand may acquire: (1) full IP assignment (the brand owns the content outright); (2) an exclusive licence (the influencer retains ownership but grants the brand exclusive rights to use, modify, and sublicence the content); or (3) a non-exclusive licence (both parties may use the content). The licence scope — including the territories, duration, platforms, and right to modify content — must be specified. The forms-legal.com Influencer Agreement template covers all ASAS disclosure requirements, IP licensing provisions, PDPA compliance clauses, and payment terms for Singapore influencer marketing engagements. Under Singapore law, Section 169 of the Companies Act 1967 (Cap. 50) and Section 8 of the Employment Act 1968 (Cap. 91) govern the core requirements for this type of document.