Three years, three sentences — SPH Media's closure needs fuller accounting

When Singapore Police announced on 29 April 2026 that no criminal charges would be brought against any current or former employee or director of SPH Media, the statement ran to three sentences.

After nearly three years of investigation, the public received no more than that.

The brevity is not merely disproportionate. It leaves material legal and regulatory questions — arising from SPH Media's own published findings — without a public answer.

What Allen & Gledhill actually found

SPH Media operates as SPH Media Trust (SMT), a not-for-profit entity formed in December 2021 following the restructuring of the then-listed Singapore Press Holdings Limited.

Following the transfer of the media business, SMT initiated a review of the data it had inherited, including circulation data. That review, covering the period from September 2020 to March 2022, found that circulation numbers had been overstated by up to 90,000 average daily copies across some months during that period.

The SMT board subsequently tasked its Audit and Risk Committee to investigate the matter more fully, engaging Allen & Gledhill to conduct a forensic investigation.

SPH Media filed its police report on 21 June 2023 following the recommendation of its Audit and Risk Committee, after the committee had engaged Allen & Gledhill to conduct a forensic investigation.

The recommendation was made, in the committee's own words, "in full cognizance of prosecutions in other jurisdictions for cases with similar facts."

What Allen & Gledhill found was not a single lapse. The committee's published report identified at least six concurrent mechanisms: phantom print copies counted as distributed; continued reporting of print runs discontinued on instructions; digital allocations with negligible actual usage — including one arrangement where only seven access codes were activated in eighteen months against 15,000 reported copies; systematic double-counting from subscription coding; fixed digital reporting disconnected from actual downloads; and print copies disposed of at the warehouse rather than delivered. Staff referred to these phantom copies as "Avatar" — understood internally to mean "throw away."

The report is explicit that staff knew the copies were not distributed and that instructions came from superiors. The aggregate overstatement for August 2021 alone was 82,600 average daily copies — approximately 10 per cent of reported daily circulation.

How the matter came to light

The police statement does not address how the matter entered the public domain.

The overstatement was discovered through an internal review covering the relevant period. Disciplinary actions against senior staff followed internally in January 2023.

According to a whistleblower allegation reported at the time, SPH Media Trust chief executive Teo Lay Lim told staff during a subsequent town hall meeting to "let the matter rest" and expressed concern about the matter coming to the attention of the Ministry of Communications and Information and being debated in Parliament. SPH Media did not respond to queries on that allegation, and no subsequent statement has addressed it.

It was Wake Up Singapore's reporting of the disciplinary actions that brought the matter into public view. The board's decision to commission a fuller investigation, Allen & Gledhill's engagement, and the police referral all followed that external exposure — not a management-initiated disclosure.

What Parliament was told — and what it was not

Parliamentary engagement with this matter spans three years, but the questions that most directly bear on accountability received the least substantive answers.

In February 2023, Parliament put seventeen questions to Josephine Teo on the matter — covering the financial impact, regulatory liability, advertiser implications, public trust, and whether the government was pursuing senior management of the former listed entity.

The responses were notable for what they deferred rather than answered. On the financial impact of the inflation and whether regulatory actions would be taken against current and former employees and the board — questions raised specifically in the context of SPH having been a listed company subject to SGX market rules — Josephine Teo replied: "the answer is we do not know."

On whether the government was pursuing senior management accountability for the falsification that occurred during the listed period, Josephine Teo declined to engage, directing Members to await the Audit and Risk Committee's findings.

On the question of criminal sanctions and civil liabilities to third parties, Josephine Teo said it would be SMT's obligation to refer the matter to the police if evidence of laws having been broken emerged — effectively making the listed company's regulator accountability question contingent on the not-for-profit successor's own referral.

Former Non-Constituency Member of Parliament Hazel Poa asked why SMT had not broken the news of its own findings, having been an organisation whose role is to expose wrongdoing. Josephine Teo said it was a matter for SMT's management and board to consider.

The focus of the responses was on the funding relationship and its implications, rather than on the legal dimensions of what had occurred during the listed period.

In July 2023, following the publication of the Audit and Risk Committee report, Josephine Teo addressed a further round of parliamentary questions.

Her responses focused on three points: that the events preceded the government's funding relationship with SPH Media Trust, that no public funds were involved, and that the government's reasons for funding the organisation had little to do with circulation figures.

The focus of the responses was on the funding relationship and its implications, rather than on the legal dimensions of what had occurred during the listed period.

Most significantly, as recently as 15 October 2025 — six months before the police closure — a parliamentary question was put to Minister for Home Affairs K Shanmugam asking for an update on the outcome of the investigation. His entire written reply was: "The investigation is still going on."

Six months later, it concluded. Three sentences. No explanation of what those final six months entailed, no account of what changed, and no response to the questions Parliament itself had raised about regulatory liability during the listed period.

Three unresolved domains

The police examined falsification of accounts under Section 477A and cheating under Section 415 of the Penal Code. Both offences require proof of specific intent.

Establishing that threshold may be difficult even where the underlying conduct is not in dispute. That is a legitimate legal distinction. The problem is that the police statement does not make it.

Given that the core factual matrix had been established and publicly documented by June 2023, the absence of any explanation of the investigative steps undertaken over that period, or of the legal threshold applied, leaves the basis for the decision opaque.

But the criminal question is only one of three domains the matter raises.

The second is commercial misrepresentation. Advertisers who paid for placements based on reported figures were paying for an audience that, to the extent of 82,600 daily copies, did not exist. The committee's own report notes that some clients were not aware that their payments were being used to fund bulk copy purchases.

The Consumer Protection (Fair Trading) Act treats representations about the reach of a service as actionable if false or misleading. Teo Lay Lim told advertisers after the matter became public that circulation data was not the basis for advertising packages. If that is so, it is necessary to explain why those figures were systematically maintained across multiple schemes simultaneously and treated as KPI targets within the organisation.

Separate from advertiser relationships, the committee's report also noted that the inflated figures were submitted to the Info-communications Media Development Authority and the Singapore Department of Statistics as official regulatory data.

A further dimension, largely absent from public discussion, is whether the submission of knowingly inflated figures to government regulators was within the scope of the investigation at all.

The third domain engages securities law and carries the highest legal stakes. Singapore Press Holdings Limited — referred to as Listco in the committee's own report — was a publicly listed company on the Singapore Exchange during the period the inflation was occurring. The conduct occurred during that listed period. The subsequent restructuring of the media business into SPH Media Trust in December 2021 does not alter that.

This distinction matters because criminal liability under the Penal Code attaches to individuals — directors, employees, and officers — rather than to the corporate vehicle itself. Corporate restructuring does not, in itself, resolve whether individual liability arose from conduct during the listed period.

The same question arises under the Securities and Futures Act: whether individuals made or approved disclosures that were false or misleading in a material particular during the listed period, and whether that framework was examined.

Circulation figures for a media company are material commercial data — and audience reach is core to its market value in a way profit-and-loss adjustments do not capture.

SPH Media's committee report stated that the overstatement had no significant accounting impact. That addresses profit and loss. It does not address whether knowingly inflated audience data, maintained through deliberate mechanisms across years, constituted a misleading disclosure under the Securities and Futures Act while the company remained listed.

In January 2023, SGX stated publicly that it was reviewing the circulation information, including its materiality and time of occurrence. No public statement from SGX on the outcome of that review has been made. No public statement addressing the securities disclosure question has been made by the Monetary Authority of Singapore or the Attorney-General's Chambers either.

A sufficient public accounting

The restructuring that gave rise to SPH Media Trust also gave rise to a government funding commitment of S$900 million over five years. That public funding does not create legal liability where none exists.

But it does mean that the institution at the centre of this matter is now publicly funded — and that the corporate transformation which produced that funding relationship cannot itself function as a mechanism for leaving accountability questions unresolved.

The case for parliamentary scrutiny is therefore not merely procedural but institutional.

If the criminal threshold was not met, the legal reasoning should be stated.

If individual liability under the Securities and Futures Act was considered during the listed period and found inapplicable, that should be explained. 

If SGX concluded its January 2023 review and found no regulatory breach, that conclusion has not been made public. If the regulatory submission question falls outside the scope of the offences examined, that too should be said.

Absent that, the public is left with a published report identifying systematic inflation across multiple mechanisms, a legal recommendation for criminal referral made by reference to comparable prosecutions abroad, a corporate restructuring that does not, in itself, resolve questions of personal liability for conduct that preceded it, a Parliament told as recently as October 2025 that the investigation was ongoing, and an outcome that does not explain the gap between these elements.

Singapore lawyer Yeoh Lian Chuan has called publicly for the government to explain and justify the conclusion to Parliament, describing it as "ex facie mystifying" on the published record. Whether Parliament takes that up will determine whether the matter receives a public accounting beyond the three-sentence closure.