Statute Details
- Title: Films (Classification — Exempt Films Other than Video Games) Notification 2019
- Act / Instrument Code: FA1981-S338-2019
- Type: Subsidiary legislation (SL)
- Authorising Act: Films Act (Cap. 107)
- Power Used: Section 40(2) of the Films Act
- Commencement: 29 April 2019
- Status: Current version as at 27 March 2026
- Key Provisions (as provided): Sections 2, 3, 4, 5, 6, 7
- Core Concept: Defines “exempt film” and provides exemptions from certain Films Act requirements/offences
What Is This Legislation About?
The Films (Classification — Exempt Films Other than Video Games) Notification 2019 is a Singapore legal instrument made under the Films Act. Its main function is to identify certain categories of films that can be treated as “exempt films” for classification purposes. In practical terms, if a film falls within the defined exempt categories and does not contain “impermissible material”, the film may be shown or distributed without some of the normal regulatory steps that would otherwise apply.
This Notification is not a general “classification scheme” for all films. Instead, it creates a targeted set of exemptions. The Films Act generally regulates film classification, including requirements relating to permits and offences for distributing or publicly exhibiting unclassified films. This Notification carves out specific film types—such as documentary records of particular subjects, news bulletins, training films, certain advertising, and child-appropriate performances—so long as they meet strict content limitations.
For practitioners, the key is that the exemption is conditional. The Notification does not simply say “these films are exempt”. It requires both (i) that the film fits within one of the listed exempt categories and (ii) that it does not contain impermissible material (as defined in the Notification). Where those conditions are not met, the exemption will not apply and the Films Act’s general classification requirements and offences may be triggered.
What Are the Key Provisions?
Section 1 (Citation and commencement) provides the formal name of the Notification and states that it comes into operation on 29 April 2019. This matters for determining which version applies to a particular film release or distribution event.
Section 2 (General definitions) supplies important interpretive terms used throughout the Notification. Several definitions are particularly relevant in practice:
- “Film” is defined by exclusion. It expressly does not include video games, obscene films, party political films, prohibited films, films against national security to be classified, and films containing material prescribed for section 16(1)(e) of the Films Act.
- “Cause-related event” is defined to include events intended to demonstrate support/opposition, publicise a cause/campaign, or mark/commemorate certain non-community cultural events and specified national-significance events. This definition becomes relevant because some advertising is exempt only if it is not designed to publicise a “cause-related event”.
- “Documentary record” is defined broadly as a non-fictional record of actual persons, events or situations. It also includes programmes where the sole or dominant purpose is to depict actual contemporary events/people/situations, even if presented with entertainment value.
- “Completed” is defined differently depending on whether the film is a standalone film, a television series, or a season of a television series. This affects the temporal exemptions (e.g., films completed before certain years).
- Definitions also cross-reference the Broadcasting Act (for free-to-air and subscription nationwide television services) and the Health Products Act (for “health-related goods or services”).
Section 3 (Meaning of “exempt film”) is the heart of the Notification. It sets out categories of films that qualify as “exempt films” provided they do not contain impermissible material. The exempt categories are extensive and include, for example:
- Documentary records of specific cultural and artistic performances (e.g., instrumental music, choral/jazz/folk music, traditional drama/pantomime/puppet shows, classical/traditional dance in original format, and “video artwork”).
- Documentary records of horse-riding, athletic activity, acrobatics, or sporting events (excluding opening/closing ceremonies, parades, or similar connected activities).
- Documentary records of community-based cultural activities/events, National Day celebrations/rallies, State funerals, or other public events of national significance.
- News bulletins or reports.
- Films used for objective, systemised observation and experiment (a “branch of knowledge” context).
- Films of a technical or similar nature used in business/trade/profession.
- Films whose main purpose is training, instruction, or reference (manuals, lessons, encyclopedias, guides).
- Films consisting wholly of programmes previously broadcast in Singapore on a free-to-air broadcasting service by a licensed broadcaster.
- Older television series/season content: episodes or seasons of a television series completed before 1980 anywhere.
- Films completed before 1966 anywhere.
- Karaoke films limited to scenery, wildlife, or other activity only.
- Advertising programmes or commercials that promote goods/brands/services but not health-related goods or services, and advertisements that promote events only if the event is not a cause-related event.
- Quiz programmes or similar.
- Documentary records of monuments/buildings/architectural works; wildlife/nature/geological formations; natural/scientific phenomena and medical/scientific events; archaeological/historical elements; and actual events/persons including travel by or biography of an actual person.
- Demonstrations for tasks/hobbies/projects and documentary records of family events/activities.
- Magic shows, circus performances, or other shows that a reasonable adult will regard as suitable for children below 7 years of age.
Section 3 also defines “impermissible material” in sub-paragraph (2). Based on the extract, impermissible material includes, among other things: matters likely to cause offence to any race or religious group in Singapore; references to religious events or religious teaching/instruction; counselling/urging unlawful acts and depictions/descriptions of gambling, smoking, alcohol consumption, psychoactive substance abuse, or unlawful conduct; and depictions/descriptions of sex/sexual matters/nudity of any kind. The extract truncates the remainder of the definition, but the structure indicates a comprehensive content prohibition list.
Sections 4 to 6 provide the operational exemptions from Films Act requirements and offences. In the extract, the key points are:
- Section 4 exempts exempt films from the permit to remove imported films requirement. This is significant for importers and distributors who otherwise might need permits for removal steps linked to regulatory control.
- Section 5 exempts exempt films from offences relating to distributing or publicly exhibiting unclassified film. This is the practical “regulatory relief” provision: if the film is truly an exempt film, the distributor/exhibitor may avoid the classification offence risk for unclassified exhibition/distribution.
- Section 6 exempts from offences relating to public exhibition of unclassified film derived from certain television services. This targets a scenario where content is derived from specified broadcasting services (as defined by the Broadcasting Act), and the exemption is conditioned on the film being within the exempt framework.
Section 7 (Cancellation) provides that the Notification cancels earlier instruments (or cancels a prior Notification) as specified in the full text. Cancellation provisions are important for ensuring that practitioners rely on the correct operative exemption scheme.
How Is This Legislation Structured?
The Notification is structured as a short, self-contained instrument with seven sections:
- Section 1: Citation and commencement.
- Section 2: General definitions (including “film”, “documentary record”, “cause-related event”, and “completed”).
- Section 3: Definition of “exempt film” and the content limitation concept of “impermissible material”.
- Section 4: Exemption from permit requirements for removal of imported films (for exempt films).
- Section 5: Exemption from offences for distributing or publicly exhibiting unclassified films (for exempt films).
- Section 6: Exemption from offences for public exhibition of unclassified films derived from certain television services.
- Section 7: Cancellation of prior instrument(s).
Who Does This Legislation Apply To?
This Notification applies to persons who deal with films in Singapore—particularly those who import, distribute, or publicly exhibit films that may otherwise require classification under the Films Act. The exemptions are framed around the status of the film (“exempt film”), but the legal consequences (permits and offences) attach to regulated activities.
In practice, the Notification is most relevant to film importers, distributors, exhibitors (including venues and event organisers), and broadcasters/content re-publishers who may seek to rely on exempt status for certain documentary, news, training, advertising, or child-appropriate content. It is also relevant to legal counsel advising on compliance risk where a film is not classified but is intended for public viewing.
Why Is This Legislation Important?
The Notification is important because it provides a structured compliance pathway for low-risk film categories. Without it, many of these films might be treated as “unclassified” and therefore expose distributors/exhibitors to offences under the Films Act. By defining “exempt film” and linking that definition to exemptions from permit and offence provisions, the Notification reduces regulatory friction for content that is generally non-controversial and falls within tightly defined subject matter.
For practitioners, the most significant legal work is classification-by-analysis: determining whether a particular film fits within one of the enumerated exempt categories and whether it contains any impermissible material. Because the exemption is conditional, counsel should treat the impermissible material definition as a compliance “gate”. Even if a film is, for example, a documentary record of a permitted subject, the exemption may fail if the film includes prohibited content (e.g., depictions of sex/nudity, unlawful conduct, or content likely to offend race/religion, depending on the full impermissible material list).
Additionally, the temporal and source-based exemptions (e.g., films completed before certain years; programmes previously broadcast on free-to-air services) create evidentiary and documentation needs. Parties relying on the exemption should be prepared to show completion timing, original broadcast source/licensing, and the film’s content boundaries.
Related Legislation
- Films Act (Cap. 107)
- Broadcasting Act (Cap. 28)
- Health Products Act (Cap. 122D)
- Medicines (Advertisement and Sale) Act (Cap. 177)
- Tobacco (Control of Advertisements and Sale) Act (Cap. 309)
Source Documents
This article provides an overview of the Films (Classification — Exempt Films Other than Video Games) Notification 2019 for legal research and educational purposes. It does not constitute legal advice. Readers should consult the official text for authoritative provisions.