Last updated 20 October 2026 — by Adrian Tan, SDM. Marketing guidance, not legal advice. Section numbers refer to the Employment Act 1968, the Employment (Children and Young Persons) Regulations and the Children and Young Persons Act 1993 on Singapore Statutes Online as at 20 October 2026. Where we infer how a rule applies to modelling or social content, we say so.
Children sell. A toddler in a diaper ad, a primary-school kid unboxing a toy on TikTok, a family channel with a sponsored holiday — brands use children because audiences respond to them, and parents of young children are among the most valuable customers in Singapore. So it surprises most marketers to learn that Singapore has no law written specifically for child models, child actors or kidfluencers.
That is not the same as “no rules”. Three general regimes still reach a children’s shoot or a paid post: the Employment Act, which bans employing children under 13 and can make parents liable; the Children and Young Persons Act, which controls children in public performances and now covers everyone under 18; and the Singapore Code of Advertising Practice, which sets how children may be shown and spoken to. The gaps between them are exactly where brands and agencies take on risk without noticing.
This guide is for brands, agencies, production houses and creator-management teams casting anyone under 18 in Singapore. It also matters if you are hiring foreign talent: for adults flown in for a shoot, see our guide to work pass rules for foreign influencers, models and film crew.
The honest starting point: no dedicated statute
In May 2024, after a controversial banner using children’s images, MP Alex Yam asked in Parliament what rules govern the use of children’s images in advertising, including AI-generated ones. The Ministry’s written reply pointed to the Advertising Standards Authority of Singapore (ASAS) and the Singapore Code of Advertising Practice (SCAP), noted that ads are not pre-approved in Singapore, and said a review of the code was under way. It did not point to a statute, because there is none aimed at children in advertising.
Law firm TSMP’s 2024 commentary on kidfluencers reached the same conclusion: Singapore has no express regulation for the work of child actors or kidfluencers, unlike France, which legislated for child influencers, or California, whose Coogan Law requires part of a child performer’s earnings to be held in trust. We found no 2025 or 2026 Singapore announcement that changes this. So the question for a brand is not “what does the child-model law say?” but “which general law does this shoot or post fall under?”
Three laws, three different definitions of “child”
The first trap is that each regime draws its age lines differently. A 14-year-old is a “child” under the Employment Act but a “young person” under the Children and Young Persons Act.
| Regime | Who is covered | What it does |
|---|---|---|
| Employment Act, Part 8 | “Child” under 15; “young person” 15 to under 16 (s 67A) | Restricts employing children; makes employers and complicit parents liable (ss 68, 74) |
| Employment (Children and Young Persons) Regulations | Children under 13 (reg 3) | No employment in any occupation, apart from family industrial work |
| Children and Young Persons Act | “Child” under 14; “young person” 14 to under 18 (s 2) | Controls children in public entertainment (s 14); ill-treatment offences (s 6) |
| SCAP (self-regulatory) | Children and young people in or targeted by ads | How ads may depict and address children (cl 6.1(b), cl 8, Appendix C) |
| PDPA guidance | Children under 13 for consent | Parent consent to use a young child’s personal data, including photos and video |
The Children and Young Persons Act’s upper age is worth noting: amendments passed in 2019 raised the “young person” ceiling to under 18, in force from 30 December 2025. Teenage creators of 16 and 17 are now inside its protections.
Rule 1: the Employment Act and the under-13 line
What the Act says
Section 68(1) of the Employment Act says a person must not employ a child in an industrial or non-industrial undertaking, except as the section allows. The exceptions are narrow. A child may work in an industrial undertaking in which only members of the same family are employed (s 68(2)). A child aged 13 or above may be employed in a non-industrial undertaking in “light work suited to his or her capacity” (s 68(3)), and a medical officer’s certificate on whether work is suitable is conclusive (s 68(4)).
The Employment (Children and Young Persons) Regulations then set the hard floor. Regulation 3 says no child below 13 may be employed in any occupation, subject only to the family-business exception. Regulation 10 adds that no child or young person may be employed in an occupation, place or conditions injurious to their health.
Who is liable
Section 74 is the provision brands and parents should read. Breaching Part 8 is an offence punishable by a fine of up to $5,000, imprisonment of up to two years, or both — and it expressly extends to any parent or guardian who knowingly or negligently permits the unlawful employment. Section 75 lets the Youth Court use its care-and-protection powers under the Children and Young Persons Act in these cases.
Does paid modelling count as employment?
This is the open question, and we want to be precise about it. The Employment Act’s definitions of “employer” and “employee” turn on a contract of service. A child booked for a day’s shoot through a talent agency, with the fee paid to a parent, may or may not be under a contract of service with anyone. We found no Singapore case and no MOM guidance applying Part 8 to modelling, acting or influencer work, and MOM’s page on employing young persons and children (updated 24 July 2025) does not mention performers at all.
Our reading is therefore cautious rather than definitive: treat a paid engagement of a child under 13 as potentially caught by regulation 3, because the downside falls on the child’s parents as well as on you, and because “the agency employs them, not us” is a weak answer if the brand directs the work. Several of the detailed limits — the night-work ban in regulation 5, the hour limits in regulation 6, the combined school-and-work cap in regulation 8 — apply only where the child is employed “as a workman”, a term built around manual labour. A model is probably not a workman, so those limits may not apply to modelling directly. They are still sensible benchmarks for a shoot day.
Rule 2: the Children and Young Persons Act and public performances
Section 14(1) of the Children and Young Persons Act says no child or young person may take part in any public entertainment that is immoral, that is dangerous to life or prejudicial to their health, physical fitness and kind treatment, or that takes place without the consent of their parent or guardian. Breach carries a fine of up to $2,000, imprisonment of up to 12 months, or both (s 14(2)), and a court may cancel or suspend a licence under the Public Entertainments Act (s 14(3)).
“Entertainment” includes an exhibition or performance, and it is public if the public is admitted or a charge is made (s 14(4)). That language clearly reaches the live formats children’s marketing uses most: a kids’ fashion show in a mall atrium, a brand stage show at a family fair, a costumed product demo at a roadshow. Whether a filmed TV commercial or a social video counts as “public entertainment” is arguable and, as far as we can find, untested.
Section 6 adds the general ill-treatment offence, which covers acts that endanger a child’s safety or cause emotional harm (s 6(3)(b)). It is not an advertising rule, but it is the provision most relevant to the “prank” and “reaction” genre of family content, where a child’s real distress is the hook.
Rule 3: SCAP on how children are shown and addressed
The Singapore Code of Advertising Practice is self-regulatory: it works on complaints, has no fines and does not pre-approve ads. But it is the standard ASAS, the media and, according to the 2024 parliamentary reply, the government rely on. The current edition linked from ASAS is from 2008.
- Clause 6.1(b): special care must be taken in advertisements directed towards or depicting children and young people.
- Clause 8: ads must not exploit children’s natural credulity or young people’s lack of experience, or strain their loyalty (8.1), and must contain nothing that could harm them mentally, morally or physically (8.2).
- Appendix C, safety (para 2): children should not be shown going off with strangers or in strange places, in hazardous situations, unattended in street scenes unless old enough to take responsibility for their own safety, or with dangerous substances without adult supervision — and nothing should be shown that would be unsafe for a child to copy.
- Appendix C, social values (para 3): no pressure that makes a child feel inferior for not owning the product; product size and performance must be easy to judge and fantasy easy to tell from reality; ads for costly goods should acknowledge that parental permission is needed (3.4); no encouraging children to nag or pester (3.5); no disrespect towards parents or other adults (3.6).
Note that ASAS’s separate Children’s Code (in force since 1 January 2015) deals only with food and beverage advertising aimed at children. It does not cover how children are depicted.
How the rules land on four real formats
The same child can fall under different rules depending on the format. This is our applicability reading for four common scenarios:
| Scenario | Employment Act / Regs | CYPA s 14 | SCAP | PDPA consent |
|---|---|---|---|---|
| Paid 10-year-old in a studio TVC shoot | Likely in scope: under 13, paid work (employment status untested) | Arguable for a filmed ad | Yes: depiction and safety rules | Parent consent for footage and data |
| 12-year-old in a live mall fashion show | Likely in scope if paid | Yes: public entertainment; parent consent required | Yes, if part of the promotion | Parent consent for photos used later |
| Paid TikTok deal with a 14-year-old creator | “Child” under the Act (under 15); light work only, if employment | Arguable for online content | Yes, plus ASAS social media guidelines on disclosure | Teen may consent if terms are understandable; get the parent too |
| Parent-run family channel with a sponsored post | Untested; s 74 parent liability if it is employment | Arguable; s 6 if content causes distress | Yes: the sponsored post is an ad | Parent consents, but the brand should still check |
The pattern is that a live event is the clearest case: s 14 of the CYPA applies plainly. Online content is the least clear. That is not a reason to relax about online formats; it is a reason to set your own standard, because the law will not set one for you.
Data, images and consent
Every child shoot produces personal data: photos, video, names and often school or location details in the background. The PDPC’s Advisory Guidelines on the PDPA for Children’s Personal Data in the Digital Environment (March 2024) treat children’s data as needing a higher standard of protection, and expect parental consent for children under 13. Teenagers aged 13 to 17 may consent themselves where the terms are understandable to them. We cover the full detail in our guide to marketing with children’s personal data in Singapore.
For production, the practical consequences are a written release signed by a parent or guardian that names the uses (paid social, OOH, the brand’s own channels, the creator’s channels), the territories and the duration; a plan for removing footage on request; and care with background detail — school crests, uniforms, house numbers. The same release should settle who owns the content, which our guide to copyright for images in Singapore marketing touches on.
Kidfluencers: where the gap is widest
The kidfluencer model — a parent running a child’s account and taking brand deals — sits in the middle of every gap described above. The child may be the main subject of paid content without any contract naming them. Earnings go to the parent. There is no Singapore rule requiring any of it to be set aside for the child, and no rule capping how often or how long the child films. The parent is both the child’s protector under the law and the commercial beneficiary.
For a brand, the risk is reputational before it is legal. A sponsored post that shows a distressed child, a child in an unsafe situation, or a child pressing a product on other children breaches SCAP’s Appendix C, and the brand, not just the creator, carries the backlash. The disclosure rules still apply too: ASAS’s Guidelines on Interactive Marketing Communication and Social Media require paid relationships to be clearly disclosed, which our influencer and KOL marketing guide explains.
Two platform points to check before you brief. The major platforms’ terms set a minimum account age of 13, so a creator account featuring a younger child is in practice run by the adult; contract with that adult and make the child’s welfare terms explicit. And platforms have their own rules on content made for children — YouTube’s “made for kids” designation, for example, changes how a video can be monetised and targeted. Check each platform’s current policy page at briefing time.
Worked example: a children’s shoe campaign
Consider a hypothetical Singapore children’s footwear brand planning a back-to-school campaign: a half-day studio shoot with four children aged 7 to 12, a live “mini runway” at a mall the following weekend, and three paid TikTok posts by a parent-run family account with an 11-year-old.
| Element | Risk | What we would do |
|---|---|---|
| Studio shoot, ages 7 to 12 | All under 13; a paid booking may be employment under reg 3, with s 74 liability for parents | Take legal advice on structure; consider older models; at minimum, parent on set, short sessions, breaks, no school hours |
| Mall mini runway | Public entertainment under CYPA s 14: needs parental consent and must not prejudice health or kind treatment | Written parent consent per child; a supervised waiting area; a short running order; no evening slot |
| Family TikTok posts | Kidfluencer gap; SCAP Appendix C on pester power; disclosure | Script with no “ask your parents to buy” lines; clear paid-partnership label; a welfare clause in the contract |
| Footage reuse | PDPA consent for under-13s; ownership | Parent release naming every use, territory and duration; a takedown process |
| Copy | SCAP 3.1 to 3.5: no “everyone has these”, no nagging prompts | Focus on comfort and fit, with sizes shown clearly |
None of this makes the campaign weaker. A parent watching a back-to-school ad wants to see children who look comfortable and safe, which is what the rules are designed to produce.
A brand and agency checklist
- Record every child’s age at casting. Under 13 and paid is the highest-risk combination under the Employment Regulations; take advice on how the engagement is structured.
- Identify live, public formats early, and collect written parental consent for each child under CYPA s 14.
- Review scripts against SCAP clause 8 and Appendix C: safety, no pressure, no nagging prompts, a clear line between fantasy and reality.
- Use a parent release that names uses, territories, duration and ownership, with a takedown route.
- Set welfare terms on set: a parent or guardian present, short sessions with breaks, nothing during school hours, no hot lights or hazardous props (reg 10 bars conditions injurious to health).
- For creator deals, contract with the adult who runs the account, add a welfare clause, and require clear paid-partnership labels.
Where this leaves brands
Singapore’s approach to children in advertising is general law plus self-regulation, with a review of SCAP under way since 2024. The one firm legal line is the Employment Regulations’ ban on employing children under 13; the clearest legal duty at events is the CYPA’s consent requirement; and SCAP sets the content standard. Where they leave gaps — especially for kidfluencers — the safest course is to adopt the standard a regulator would expect if it legislated tomorrow, which is roughly what the checklist above describes.
If you are planning a family-market campaign or a creator programme and want it to perform without these risks, our social media marketing team in Singapore can plan and run it with you, and you can see how we work in our client case studies. For the bigger picture on running social channels, start with our complete guide to social media management in Singapore.
Frequently asked questions
Is it legal to use child models in Singapore ads?
Yes, children can appear in ads, but general laws apply. The Employment (Children and Young Persons) Regulations bar employing children under 13 in any occupation, the CYPA requires parental consent for children in public entertainment, and SCAP sets rules on how children are depicted.
What is the minimum age to work as a model in Singapore?
There is no model-specific minimum age. Under regulation 3 of the Employment (Children and Young Persons) Regulations, children under 13 may not be employed in any occupation, and children aged 13 to 14 may do only light work. Whether paid modelling is “employment” is untested, so take care with under-13s.
Can parents be liable for their child’s modelling or influencer work?
Potentially. Section 74 of the Employment Act extends the offence to any parent or guardian who knowingly or negligently permits unlawful employment of a child, with a fine of up to $5,000, up to two years’ jail, or both.
Are kidfluencers regulated in Singapore?
Not specifically. There is no Singapore law on child influencers’ earnings, hours or content. General laws, SCAP and platform rules still apply, and sponsored posts must be clearly disclosed as advertising.
Do I need parental consent to film a child at a brand event?
Yes. Under section 14 of the Children and Young Persons Act, a child or young person may not take part in public entertainment without a parent’s or guardian’s consent. For personal data of children under 13, PDPC guidance also expects parental consent.
What does SCAP say about children in advertising?
SCAP requires special care in ads depicting or aimed at children. Ads must not exploit children’s credulity, show unsafe behaviour they might copy, make them feel inferior for not owning a product, or encourage them to pester their parents.
