Did “influencers” in MOF’s campaign contravene Advertising Standards Authority’s guidelines?

TODAY, 2015

Earlier this month, it emerged that the Ministry of Finance (MOF) had paid some social media practitioners, or so-called “influencers’, to help publicise Budget 2018. Leaving aside the debate of whether it was money well spent by the ministry (note: the MOF has declined to disclose how much it dished out to each “influencer”), there is also the question of whether these “influencers” had in fact contravened the guidelines issued by the Advertising Standards Authority of Singapore (ASAS).

Let’s take a little, short step back into the recent past, to 2015.

Concerned about how some had used social media (Facebook, Instagram and Twitter) to promote certain services and products unethically, including how Singtel had run an online smear campaign against its competitors, the ASAS held a consultation exercise in December that year, to seek feedback on how its advertising standards guidelines should be improved to include new forms of advertising.

Specifically, the ASAS highlighted how sponsored or paid posts online should be disclosed prominently on the channel or platform.

TODAY reported at the time (emphasis mine):

The draft guidelines for digital and social-media advertising that ASAS has come up with requires personalities hired for marketing work to differentiate sponsored messages from personal opinions and editorial content in their posts on social media, such as Facebook, Instagram and Twitter. They must also disclose any commercial relationships in a prominent manner.

For example, if a user is endorsing a specific company, product or service, these advertisements should not look like “impartial or casual” tweets on their Twitter account.

Even if a blogger is writing his genuine thoughts about a product or service provided by a company he has a commercial relationship with, he should declare the relationship in the post, ASAS proposes.

Coming back to the MOF’s campaign, it was reported by the Straits Times that the ministry had roped in and paid 50 such “influencers” to publicise its upcoming Budget speech.

The ministry had apparently engaged marketing company StarNgage to reach out to the 50 “influencers”.

Straits Times, 17 Jan 2018

Looking at some of these posts on the Instagram accounts of these “influencers’, it seems that none of them had adopted or adhered to the ASAS’ advertising guidelines to declare, prominently, that their messages or posts were paid for or sponsored by the ministry.

Here are some of these posts:

Before we penned down our signatures to seal our union for #KenTingWeds, there was a lot of planning done to make sure we worked within our budget and planned our finances well for our future together. 💸 Similarly, the Singapore government has to plan the #SGBudget ahead to help us Singaporeans and support our businesses in the next Financial Year, and our President will pen down her signature as assent for the enactment of the Supply Bill. 🖋 If you didn’t know, the #SGBudget2018 is a strategic financial plan to position Singapore & Singaporeans; and you can actually voice your thoughts & needs to help the Government plan this! 💡 Read more on the Budget 2018 at http://bit.ly/kaitinghearts 📲 #sp #MOFSG #ministryoffinance #MOFxStarNgage

A post shared by Kaiting Cheng (@kaitinghearts) on





In preparation for Budget 2018, REACH has organised Pre-Budget 2018 Listening Points across Singapore. These Listening Points are easily accessible, open booths for Singaporeans to give their views in person 🙋🏻‍♂️ Do join me at today’s Listening Point from now till 2.00pm at the covered area close to the Multi-Purpose Hall at Tanjong Pagar Complex – loving the heritage feels and free ice cream heh 😂 Alternatively, you may visit the last Listening Point on this Friday 12 January, at SMU (near Koufu Foodcourt), from 11.30am to 2pm. You may also provide your feedback via the REACH Budget 2018 microsite, www.reach.gov.sg/budget2018 (check out the link in my bio) until 12th Jan. Go on to let your voice be heard :)) #royceshares #sponsored #sgbudget2018 #mofsg #reachsingapore #mofsgxstarngage

A post shared by #emceeroyce (@theroycelee) on


None of the above “influencers” had declared, as required by the ASAS’ guidelines, their commercial relationship with the MOF “in a prominent manner”.

The whole purpose of the ASAS’ guidelines is to ensure that consumers, or the public at large, are not misled or deceived by posts which are disguised as casual posts, but which in fact are paid for by commercial entities or through commercial, paid or sponsored contracts.

It would seem that the posts by these “influencers” have contravened the guidelines.

Having said that, the guidelines are not law, and thus cannot be enforced by the police.

What one would expect, however, is for the MOF to disclose the following:

  1. What were the specific contractual terms it had with the “influencers” or the middleman involved?
  2. How much was paid to each “influencer” for the posts?
  3. Did the ministry inform the “influencers” of the ASAS’ guidelines?

For the detailed guidelines, please click here.

Below is an extract of the more relevant part of the guidelines (emphasis mine):

“Commercial relationship” refers to a relationship where the originator of social media content is given an incentive or has an obligation to create social media content for a client.”

“The foremost principle is that all marketing communication must be identified as such and distinguished from editorial or personal opinions.”

“Marketing communication should be clearly distinguishable from personal opinions and editorial content, and should not be made to appear like them.

Where there exists a connection between the endorser and the marketer of the product or service that may materially affect the weight or credibility of the endorsement, such a connection must be fully disclosed. Examples of such connections include commercial relationships between the endorser and sponsor, complimentary samples, friendly favours and special invitations.”

“Social media content may reflect the genuine feeling of the originator for a product or service. However, if the content originator has a commercial relationship with the marketer in question, such a relationship should be indicated in the content.”

“Where a marketing communication is individually addressed to a consumer, the subject descriptor and context should not be misleading, and the commercial nature of the communication should not be concealed.”

“Marketers should take appropriate steps to ensure that the commercial nature of the social media content under their control or influence, or a sponsor’s control or influence, is clearly indicated and that the rules and standards of acceptable commercial behaviour on the platform are respected.”


  • Disclosures in marketing communication should be simple and straightforward. Marketers should use clear language and syntax and avoid legalese or technical jargon.
  • (b) Regardless of the platform used, the disclosures for sponsored content should be clear and prominent.
  • The disclosures should:
  • (i) Be displayed as early as is reasonably possible so that they are noticeable to consumers with minimal scrolling or clicking;
  • (ii) Convey and clearly show that the content has been paid for;
  • (iii) Be in a colour that contrasts with the background to emphasise the text of the disclosure;
  • (iv) Be reasonably visible and readable on a variety of devices;
  • (v) Be easily read without referring the consumer elsewhere to obtain the information;

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