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Singapore Model AI Governance Framework for Generative AI

Model AI Governance Framework for Generative AI

AI Verify Foundation and the Infocomm Media Development Authority (IMDA), Singapore

The framework is a voluntary governance baseline with no penalties, but it is widely used by Singapore regulators, corporate buyers and investors as the skeleton of generative AI due-diligence questionnaires. It sets out nine dimensions: Accountability (allocating responsibility along the development chain), Data (training-data governance and provenance), Trusted Development and Deployment (baseline evaluation and disclosure practice), Incident Reporting (detection and response), Testing and Assurance (a third-party testing ecosystem), Security (new attack surfaces specific to generative AI), Content Provenance (labelling and watermarking), Safety and Alignment R&D, and AI for Public Good. It stresses that no single intervention is a silver bullet and the dimensions must be viewed in totality.

Verified against official sources · 2026-09-12Partly secondary sources — verify before relying

Does this apply to me?

A Chinese AI company will be asked to answer against this framework when it: (1) bids for AI projects with Singapore government agencies or government-linked companies; (2) completes AI governance due-diligence questionnaires for large Singapore financial, telecom or healthcare customers; (3) applies to participate in AI Verify testing or the Global AI Assurance Sandbox; or (4) establishes a regional headquarters in Singapore and explains its model governance to regulators. The framework is not legally binding, but commitments made in a questionnaire or tender can become contractually enforceable.

Key industries: GenAI & foundation models, AI agents, Enterprise SaaS, Embodied AI & robotics

Application timeline

  1. 2024-06-19

    Framework published, setting out nine governance dimensions

    From publication it serves as Singapore’s stated baseline expectation for generative AI governance, used in regulatory dialogue, public procurement and corporate self-assessment.

Obligations (6)

Each states its trigger, the evidence to retain and the clause it comes from

Allocate responsibility along the AI development chain

Severity MediumDimension: Accountability

Under the Accountability dimension, define the responsibility boundaries of model developers, application integrators and end deployers, reflect them consistently in customer contracts and internal governance documents, and place each risk with the party best placed to control it.

Applies when
Chinese companies supplying foundation models, model APIs or AI applications to the Singapore market.
Evidence to retain
  • · AI governance responsibility matrix (RACI)
  • · Responsibility allocation clauses in customer contracts
  • · AI governance committee charter and meeting minutes

Estimated first-time effort: 4–10 person-days (estimate, not a commitment)

Establish training-data governance and provenance management

Severity HighDimension: Data

Under the Data dimension, govern the source, licensing status, quality and bias risk of training data, and be able to explain how the data was obtained and processed. In the Singapore context this links directly to PDPC’s requirement to document reliance on the Publicly Available Exception.

Applies when
Chinese AI companies that train or fine-tune models themselves and deliver them to Singapore customers.
Evidence to retain
  • · Training-data inventory with licensing status
  • · Provenance records of source and transformation
  • · Data quality and bias assessment report
  • · Dataset admission approval records

Estimated first-time effort: 10–25 person-days (estimate, not a commitment)

Run baseline safety evaluations and disclose results downstream

Severity HighDimension: Trusted Development and Deployment

Under the Trusted Development and Deployment dimension, run baseline evaluations of model capabilities, known risks and limitations, and disclose the scope, method and results to downstream integrators and deployers through a model card or equivalent, so they can judge the boundaries of appropriate use.

Applies when
Chinese companies distributing model weights, model APIs or embedded AI features into Singapore.
Evidence to retain
  • · Model card or system card covering evaluation method and results
  • · Safety evaluation and red-teaming reports
  • · List of known limitations and out-of-scope uses
  • · Version change and re-evaluation records

Estimated first-time effort: 10–30 person-days (estimate, not a commitment)

Establish detection, reporting and response for AI incidents

Severity HighDimension: Incident Reporting

Under the Incident Reporting dimension, put in place monitoring capable of detecting anomalous model behaviour, misuse and harm events, define internal escalation paths and criteria for external notification, and retain records of how incidents were handled. The mechanism must interlock with the PDPA breach-notification deadline of three calendar days after assessment.

Applies when
Chinese companies operating generative AI services in Singapore where harmful outputs or data leakage are possible.
Evidence to retain
  • · AI incident severity criteria and response plan
  • · Incident register with closure records
  • · Misuse monitoring and content moderation logs
  • · Documented interlock with the PDPA breach-notification workflow

Estimated first-time effort: 6–15 person-days (estimate, not a commitment)

Provide provenance signals for generated content

Severity MediumDimension: Content Provenance

Under the Content Provenance dimension, apply labelling, watermarking or metadata so that downstream users and platforms can identify machine-generated content. Where the same product also enters Korea, note that Art. 31 of the Korean AI Framework Act makes labelling of generative output a statutory duty.

Applies when
Chinese companies offering text, image, audio or video generation capabilities in Singapore.
Evidence to retain
  • · Technical description of the content-marking scheme
  • · Watermark or metadata implementation and robustness test records
  • · Screenshots of the user-facing indication

Estimated first-time effort: 8–20 person-days (estimate, not a commitment)

Engage third-party testing and assurance

Severity MediumDimension: Testing and Assurance

Under the Testing and Assurance dimension, supplement self-assessment with independent third-party testing to raise the credibility of external claims. Singapore has built a testing ecosystem around the AI Verify testing framework and toolkit, including tester accreditation, and participation is commonly probed in tenders and large-customer due diligence.

Applies when
Chinese AI companies targeting Singapore public procurement or large-enterprise supply chains.
Evidence to retain
  • · Third-party test report with scope statement
  • · Remediation closure records for test findings
  • · Consistency check between public claims and test conclusions

Estimated first-time effort: 10–30 person-days (estimate, not a commitment)

Penalties

The framework itself carries no penalties. Exposure arises in two ways: governance commitments made in tenders or customer questionnaires can become contractual obligations, and a mismatch between commitment and practice can amount to misrepresentation and attract regulatory attention.

Known uncertainty

The framework is voluntary and imposes no statutory duties or penalties; the items above are practice requirements distilled from its nine dimensions for due-diligence and self-assessment use and must not be presented as legal obligations. This pass verified the contents page and executive summary of the 19 June 2024 PDF rather than every dimension in full; the resource page also signals that more detailed guidance will be developed under each dimension, so check for a newer version before use.

Related standards

  • ISO/IEC 42001 Artificial Intelligence Management System (AIMS) · ISO/IEC 42001:2023 (edition 1, dated 2023-12); European adoption EN ISO/IEC 42001:2026
  • ISO/IEC 23894:2023 Artificial intelligence — Guidance on risk management · ISO/IEC 23894:2023 (edition 1, dated 2023-02)
  • NIST Artificial Intelligence Risk Management Framework 1.0 (NIST AI 100-1) · AI RMF 1.0 (NIST AI 100-1, released 2023-01-26; being revised under the White House AI Action Plan)

Sources (2)

Content as of 2026-09-12 · corpus 2026.09|Compiled from public official sources with links and review dates for compliance decision support. Rules change; have licensed professionals review before external disclosure, regulatory filing or contractual commitments.

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Singapore Model AI Governance Framework for Generative AI · Obligations & official sources | HaiWen HQ