Terence Lee’s The Media, Cultural Control and Government in Singapore (2010) provides a foundational analysis of how a “managed” media system can be used to preserve political stability through calibrated information control. Extending Lee’s framework to China’s more centralized and technologically sophisticated media regime illuminates a shared—but differently scaled—conception of political modernity that stands in sharp contrast to U.S. liberal democratic values. In both Singapore and China, media regulation is not a peripheral policy domain but a core instrument of governance, national development, and regime legitimacy, shaping the boundaries of public discourse and citizen autonomy.
At the heart of this divergence lies a competing definition of political modernity. China, and to a lesser extent Singapore, define modern governance by a state’s demonstrated capacity to deliver prosperity, stability, resilience, and long-term development under sovereign control, rather than by adherence to liberal democratic procedures such as electoral competition or maximal press freedom. This performance-based conception unsettles liberal democratic assumptions by challenging the primacy of how power is chosen over what power can achieve, exposing a fundamental ideological rift over legitimacy, governance, and the role of media in modern political life.
Legal Regulation as an Instrument of Media Governance
Legal regulation occupies a central position in the media governance frameworks of both Singapore and China, functioning as a primary mechanism through which the state structures public discourse and maintains political order. In neither case is law conceived merely as a neutral safeguard or procedural boundary; rather, it operates as an active tool for shaping media behavior in line with broader governance objectives. This contrasts sharply with U.S. liberal democratic traditions, where legal regulation of media is designed principally to limit state power and protect expressive freedom.
In Singapore, media regulation is characterized by a dense legal architecture that enables continuous state oversight while preserving the appearance of institutional normalcy. The Press and Publications Act requires all newspapers and periodicals to obtain licenses that can be revoked if content is judged to undermine the public interest or social harmony. The Broadcasting Act extends similar controls to television, radio, and online media, granting authorities wide discretion over politically sensitive or undesirable content. Defamation and sedition laws further discipline journalistic practice by exposing media outlets and reporters to legal risk when criticizing political leaders, thereby encouraging self-censorship. Internet governance under the Infocomm Media Development Authority reinforces this framework, presenting content regulation as a protective measure aligned with social stability and national development rather than overt repression.
China’s legal regime operates on a more expansive and coercive scale, reflecting a far stronger fusion of law, political authority, and technological control. Statutes such as the Cybersecurity Law, National Security Law, and publishing regulations require all media organizations and digital platforms to conform explicitly to Communist Party directives. Censorship of sensitive topics—including criticism of the Party, human rights issues, protests, and historical events—is systematic and institutionalized, treated not as an exception but as a necessary defense against political instability. Restrictions on foreign media further assert China’s claim to narrative sovereignty, rejecting external standards of press freedom as illegitimate intrusions into domestic governance.
A defining feature of China’s legal regulation is its integration with mass surveillance infrastructure. The Great Firewall, the Cyberspace Administration of China, and state-controlled internet service providers enable continuous monitoring of online activity. Domestic platforms such as WeChat and TikTok’s Chinese counterpart are legally obligated to share user data and enforce content controls, with severe penalties imposed for noncompliance. Here, law functions less as a constraint on power than as a coordinating instrument that enables large-scale governance, reinforcing China’s conception of modernity as state capacity and performance.
The contrast with U.S. liberal democratic values is fundamental. In the United States, freedom of speech and the press are constitutionally protected as procedural rights, largely independent of political outcomes or considerations of stability. Government licensing of media content, pre-publication approval, or criminalization of political criticism would be unconstitutional, and online platforms are generally shielded from liability for user-generated content. Singapore and China, by contrast, treat legal regulation as a means of subordinating expression to collective goals of order, development, and regime security. The resulting conflict is not merely legal but philosophical, reflecting a deeper divide between procedure-based legitimacy and performance-based governance as competing foundations of political modernity.
Media Control Through Licensing and Ownership Structures
Licensing and ownership form a central pillar of media regulation in both Singapore and China, functioning as structural mechanisms through which the state shapes the boundaries of permissible discourse. Rather than serving merely administrative or technical purposes, licensing regimes in both systems operate as instruments of political alignment, ensuring that media activity remains consistent with national priorities and regime objectives. Ownership patterns reinforce this logic, embedding media institutions within broader state-centered governance frameworks.
In Singapore, all media organizations are required to obtain government-issued licenses, a requirement that allows the state to condition media participation on compliance with regulatory and political expectations. Major media outlets are either directly state-owned, such as Mediacorp, or closely linked to political and economic elites aligned with the ruling establishment. This configuration reflects a belief that media should support long-term governance goals—such as stability, development, and social cohesion—rather than function as an adversarial force. Restrictions on foreign media further reinforce sovereign control over the narrative space, permitting limited pluralism while ensuring that external actors do not challenge domestic political legitimacy.
China’s approach represents a more comprehensive and centralized extension of this model. All major media institutions are state-owned or directly controlled by the Communist Party, while ostensibly private digital platforms such as Weibo or ByteDance are embedded with internal Party committees to ensure ideological compliance. Licensing rules effectively prevent the emergence of independent media, and ownership structures eliminate meaningful separation between political authority and information production. Foreign media are tightly monitored, with critical reporting frequently resulting in censorship, operational constraints, or expulsion, underscoring China’s rejection of external claims to universal standards of press freedom.
The contrast with U.S. liberal democratic values is stark. In the United States, media organizations operate without political licensing beyond basic business and technical requirements, and ownership is predominantly private and diverse, fostering competition and pluralism. This model assumes that dissent, rivalry, and decentralized control enhance accountability and democratic governance. Singapore and China, by contrast, operate on the premise that coordination and alignment produce better outcomes, prioritizing order and performance over adversarial scrutiny. As a result, licensing and ownership become key sites where state-centered conceptions of political modernity directly collide with liberal ideals of press independence and the media’s role as a Fourth Estate.
Economic and Professional Structures as Instruments of Media Discipline
The economic and professional organization of the media industry in Singapore and China functions as a subtle yet powerful mechanism of regulation, shaping journalistic behavior without the constant need for direct legal intervention. In both systems, market structures, advertising flows, and career incentives are closely aligned with political authority, ensuring that media institutions internalize state priorities as part of their everyday operations. Industry structure thus becomes an extension of governance, reinforcing compliance through economic dependence and professional socialization.
In Singapore, advertising revenue is heavily concentrated among government-linked companies and firms aligned with state interests, creating strong financial incentives for media outlets to avoid politically sensitive or contentious topics. Journalists operate within a professional culture shaped by the risk of legal action or the potential loss of publishing licenses, leading to widespread self-censorship. As Terence Lee observes, this dynamic produces “technologies of self-government,” whereby journalists internalize regulatory boundaries and adjust their conduct accordingly. Stability and restraint become professional norms, aligning media practice with the state’s broader developmental and governance objectives.
China’s media industry operates under a more overt fusion of economic power and political authority. State-owned enterprises dominate advertising markets and can strategically withhold funding from outlets that deviate from Party expectations. Media organizations and digital platforms are financially supported by government-aligned entities, making political loyalty a prerequisite for institutional survival. Journalistic careers are similarly conditioned by adherence to Party directives, with professional advancement tied to contributions to political stability rather than investigative rigor. Corporate responsibility laws further compel platforms to police user content, effectively turning private firms into agents of state regulation and embedding preemptive self-censorship into business operations.
The divergence from U.S. liberal democratic norms is pronounced. In the United States, journalistic ethics emphasize adversarial oversight and truth-telling as essential democratic functions, and advertising revenue is not structurally linked to political compliance. Conflict, exposure, and dissent are treated as productive forces that enhance accountability. By contrast, Singapore and China prioritize systemic reliability and social order, viewing adversarial journalism as a potential source of instability. The resulting divide reflects fundamentally different assumptions about the role of markets, professionalism, and conflict in modern media systems and political governance.
Narrative Governance and the Management of Media Content
Control over media content constitutes a central mechanism through which Singapore and China shape public discourse and reinforce political authority. In both systems, content regulation is not limited to preventing explicit threats to the state but extends to structuring how social, political, and historical issues are framed. Media content is thus treated as a strategic resource, managed to sustain stability, reinforce legitimacy, and guide public perception in accordance with state-defined priorities.
In Singapore, restrictions on coverage of sensitive issues such as race, religion, and political dissent reflect a governing assumption that social cohesion must precede political openness. Media narratives are carefully framed to emphasize economic development, multicultural harmony, and social order, presenting governance outcomes rather than political contestation as the primary markers of success. While outright bans are relatively limited, opposition voices are routinely marginalized in mainstream media, narrowing the range of perspectives available to the public and reinforcing a results-oriented conception of good governance.
China’s approach to content management is more comprehensive and centralized, encompassing print media, broadcasting, film, and digital platforms. State media consistently frame narratives around Communist Party achievements, national unity, and ideological conformity, embedding political authority within everyday informational flows. Dissenting or oppositional voices are effectively excluded from mainstream platforms, with outlets and digital services that host sensitive or critical content facing fines, shutdowns, or legal sanctions. Narrative control functions as a precondition for political order, rather than as a reactive measure against exceptional threats.
At the core of China’s content strategy is a prioritization of predictability and order over pluralism. By erasing dissent from dominant media channels, the state seeks to minimize uncertainty and prevent challenges to Party legitimacy. Content regulation thus becomes an essential component of modern governance, aligned with a broader emphasis on stability, continuity, and centralized coordination.
This approach stands in sharp contrast to U.S. liberal democratic norms. In the United States, government-imposed censorship is constitutionally prohibited, and media outlets are free to report on any topic, including governmental failures and political opposition. Pluralism and open debate are treated as intrinsic goods necessary for informed citizen participation and democratic accountability. Singapore and China, by contrast, treat pluralism and dissent as conditional—permissible only insofar as they do not disrupt systemic performance or state objectives. As a result, content control emerges as a key site of ideological divergence over the role of media in modern political life.
Surveillance and Digital Governance as Foundations of State Control
Surveillance and internet governance play a decisive role in how Singapore and China regulate the digital public sphere, extending state oversight beyond traditional media into everyday online behavior. In both systems, monitoring technologies are not presented merely as tools of repression but as integral components of modern governance, designed to preserve order, security, and social stability in increasingly networked societies. The regulation of digital space thus reflects broader assumptions about the relationship between state authority, individual conduct, and political legitimacy.
In Singapore, internet surveillance operates through a combination of direct monitoring and indirect oversight via government-linked broadband providers, complemented by symbolic “cyber-police” campaigns. While enforcement is often subtle, its effects are substantial: awareness of potential monitoring generates a chilling effect that encourages citizens to regulate their own online behavior. This model minimizes the need for overt coercion by fostering voluntary compliance, framing surveillance as a protective and modernizing measure rather than an explicitly punitive one.
China’s approach represents a far more expansive and technologically intensive system of digital governance. Through the Great Firewall, the Golden Shield Project, real-time social media monitoring, AI-driven facial recognition, and integration with the Social Credit System, the state exercises continuous oversight over both public and private digital activity. Platforms such as WeChat and domestic versions of TikTok are legally required to monitor communications and share data with authorities, with violations carrying penalties ranging from fines to detention. Citizens adapt to this environment by engaging in self-censorship, using coded language, or avoiding politically sensitive topics altogether.
Central to China’s model is the belief that effective governance at scale requires technological oversight. Surveillance is treated as essential infrastructure, comparable to transportation or energy systems, enabling coordination, predictability, and political control across a vast population. By embedding monitoring mechanisms into everyday life, the state normalizes compliance and aligns individual behavior with performance-driven governance goals.
The contrast with U.S. liberal democratic values is stark. In the United States, surveillance is constrained by legal standards emphasizing probable cause, judicial oversight, and privacy protections under constitutional and statutory law. Mass surveillance is widely viewed as a threat to individual liberty and democratic participation. Singapore and China, by contrast, prioritize collective stability and administrative efficiency over personal privacy, revealing a fundamental divergence in how digital governance and political modernity are understood.
Governing Dissent Through Regulation and Criminal Sanction
The regulation and criminalization of dissent represent a critical dimension of media control in both Singapore and China, revealing how the state defines the limits of acceptable political expression. In these systems, censorship is not merely reactive but institutionalized, functioning as a preventive mechanism designed to neutralize perceived threats to social order and political stability. Regulation thus extends beyond managing content to disciplining citizens and media actors through the possibility of legal sanction.
In Singapore, politically sensitive speech is regulated through defamation, sedition, and related laws that criminalize certain forms of criticism and dissent. Website blocking and vaguely defined content guidelines further reinforce these controls, creating an environment in which the boundaries of permissible speech are deliberately ambiguous. This vagueness fosters caution and compliance, encouraging citizens and media outlets to align their behavior with state priorities without the need for constant enforcement. The result is a system in which dissent is formally possible but substantively constrained through legal uncertainty and anticipatory self-restraint.
China’s approach is more expansive and punitive, characterized by aggressive and systematic censorship across digital and traditional media. Foreign platforms such as Google, YouTube, and X are blocked outright, while domestic platforms are legally required to self-censor under the Cybersecurity Law and related regulations. Laws criminalizing vaguely defined offenses such as “spreading rumors” or “picking quarrels” are routinely applied to bloggers, journalists, and activists, ensuring that dissent is not only discouraged but legally actionable. These measures reflect a deep-seated concern with political fragmentation, which the Chinese state associates with historical instability and national decline.
The contrast with U.S. liberal democratic values is fundamental. In the United States, the First Amendment protects criticism of government even when it is offensive, disruptive, or politically destabilizing, on the assumption that open contestation strengthens democratic governance. Ambiguous or comprehensive censorship is viewed as incompatible with the marketplace of ideas and informed citizen participation. Singapore and China, by contrast, treat dissenting speech as a systemic risk rather than a civic contribution, prioritizing order and regime security over expressive freedom. This divergence underscores a profound ideological divide over whether dissent is a democratic safeguard or a threat to political modernity.
Internalized Control and the Normalization of Self-Censorship
The encouragement of self-censorship constitutes one of the most effective and least visible mechanisms of media governance in both Singapore and China. Rather than relying exclusively on overt repression, these systems cultivate environments in which citizens, journalists, and platform users internalize the limits of acceptable expression. Through legal signaling, technological mediation, and publicized enforcement, self-regulation becomes a routine and rational response to state power.
In Singapore, self-censorship is fostered through a combination of legal threats, selective enforcement, and symbolic actions such as website bans. These measures communicate the boundaries of permissible speech without requiring constant intervention, encouraging individuals to govern their own behavior. As Terence Lee describes, this process operates through “technologies of self-government,” whereby citizens and media actors internalize regulatory expectations and align their conduct with state-defined norms. Compliance is achieved primarily through socialization and anticipation rather than coercion.
China institutionalizes self-censorship on a far more comprehensive scale, embedding it into the technological and administrative infrastructure of everyday life. AI-driven content moderation, algorithmic downranking of sensitive topics, and the integration of surveillance with the Social Credit System intensify internal compliance. Platforms actively train users on what is “safe” to post, while highly publicized punishments reinforce the personal and professional risks of transgression. In this environment, self-censorship becomes a rational strategy for avoiding legal, economic, or social penalties.
The contrast with U.S. liberal democratic values is pronounced. In the United States, self-censorship is largely shaped by social norms or market pressures rather than state coercion, and fear-induced compliance is widely regarded as incompatible with democratic ideals of civic autonomy, transparency, and protection for dissenting voices. Singapore and China, by contrast, view internalized restraint as a feature of effective governance, consistent with a capacity-centered understanding of political modernity in which order and performance take precedence over expressive freedom.
Integration of Media Regulation with National Development Objectives
In both Singapore and China, media and internet governance are closely integrated with broader national development strategies, transforming regulation into an instrument of state-led modernization. Media controls are framed not merely as tools of political oversight but as mechanisms that support technological advancement, social cohesion, and long-term national priorities. By aligning regulatory practices with development objectives, both states position information management as essential to achieving collective stability, economic growth, and cultural continuity.
Singapore emphasizes a developmental framing of regulation, presenting restrictions on media and online content as protective measures designed to safeguard social harmony, moral integrity, and technological progress. Media policies reinforce the state’s vision of modernization and social cohesion, signaling to citizens and journalists that compliance is part of a collective project rather than an act of coercion. In this sense, regulation functions as a tool for shaping societal behavior to align with long-term developmental goals rather than as an instrument of overt political repression.
China expands this approach on a much larger scale, explicitly linking media and internet controls to the ideology of “Cyber Sovereignty” and the “Chinese Dream” of national rejuvenation. Censorship and technological oversight are justified as necessary to defend cultural values, economic stability, and political order from perceived Western influence or “digital imperialism.” Platforms and tech initiatives are structured so that loyalty and political compliance are prerequisites for participation in economic and social advancement. In China’s model, modernity is inseparable from the state’s capacity to deliver coordinated development, and media regulation is a core mechanism of that governance.
The contrast with U.S. liberal democratic principles is profound. In the United States, regulatory interventions are constrained by legal rights, market competition, and procedural transparency rather than collective moral imperatives or performance-based objectives. Subordinating individual freedoms to state-led goals, as practiced in Singapore and China, conflicts with liberal democratic values that prioritize pluralism, personal autonomy, and independent accountability. By integrating media regulation with national development, Singapore and China redefine the role of information control as an instrument of state capacity, highlighting a fundamental divergence from procedural, rights-based conceptions of governance.
Summary & Implications
Singapore and China offer contrasting models of media governance that reflect fundamentally different conceptions of political modernity. Singapore employs a softer form of performance-based control, using licensing, legal enforcement, and moral framing to encourage conformity while preserving a limited pluralistic space. China extends this approach with intensive technological surveillance, strict legal frameworks, and pervasive Party oversight, leaving virtually no independent room for media or dissent. Both systems prioritize political stability and regime objectives over individual rights, defining modern governance in terms of state capacity—the ability to organize society, mobilize resources, and achieve large-scale outcomes—rather than adherence to liberal democratic procedures.
By contrast, the United States emphasizes procedural legitimacy, pluralism, and individual freedoms, valuing dissent, debate, and accountability even at the expense of efficiency or systemic stability. The deeper tension, therefore, is not simply authoritarianism versus democracy, but a clash between performance-oriented governance and procedure-oriented legitimacy. China—and to a lesser extent Singapore—redefines modern politics as a capacity to govern effectively at scale, challenging the liberal assumption that the form of political institutions determines their modernity or success.
References
- The Media, Cultural Control and Government in Singapore. Terence Lee. 2010