How to Check the Investigator You Are About to Instruct Is Licensed, in Singapore and Four Neighbours Where the Answer Is Different

2026-09-07 · Philip Choo · AI9OS

Here is a test you can run in ten seconds, before you sign anything.

Did they ask you for your identification documents?

In Singapore, a licensed private investigation agency has no discretion about this. Section 10 of the Private Security Industry Act requires an agency to obtain identification documents from its client, and s 12 imposes a duty to keep records. An agency that takes your instruction, quotes a fee and starts work without ever asking who you are is not doing you a favour by keeping things informal. It is behaving like an organisation that does not have the obligation, which usually means it does not have the licence.

That single question catches more than any amount of website reading, because the licence is a fact about the firm and the paperwork is a consequence of it.

What goes wrong when the answer is no

Three things, in rising order of expense.

The evidence may be worth nothing. Material gathered unlawfully invites a challenge to its admissibility, and the challenge lands at the worst possible moment, after you have relied on it. The frustrating version of this outcome is well known to litigators: you know the fact, and you cannot use it.

The exposure may travel to you. Instructing someone to do a thing does not insulate you from how they do it. Where an investigator breaks a privacy or surveillance law in the course of your matter, the question of who directed the work is not academic.

And the legislature has already told you what it thinks of the arrangement. Section 35 of the Act provides that an unlicensed private investigation agency cannot recover its fees. Read that as a signal rather than a saving: a statute that strips a class of provider of the right to be paid is not describing a technicality.

Singapore: two licences, not one

This is the part most often got wrong, including by people who have engaged investigators for years.

The Act creates two separate licences and holding one does not supply the other. A private investigator's licence under s 6 attaches to an individual. A private investigation agency's licence under s 7 attaches to the business entity. A sole operator selling investigative services engages both provisions at once, and s 8 adds a matching duty running the other way: a person must not employ another as a private investigator unless that person is licensed.

The penalties are set at different levels, which tells you how the two are regarded. An unlicensed individual faces a fine up to $10,000 and imprisonment up to two years under s 6(2). An unlicensed agency faces a fine up to $50,000 and imprisonment up to two years under s 7(2).

Section 5(1) is the provision everything turns on, and it is deliberately broad. It says nothing about how the information is obtained. There is no exemption for work done from a desk, no carve-out for public records, and no line at which research becomes something else. If you are obtaining information about a person for reward, you are inside the definition, whatever your tooling looks like.

Advertising is its own offence. Sections 6(1)(b) and 7(1)(b) are independent limbs: it is an offence to advertise, or in any way hold out, that you carry out or supply such services for reward, whether or not any work is ever performed. A firm can commit this one without ever taking an instruction.

The regulator is the Police Regulatory Department, whose Security Industry Division carries the private security regimes.

The four questions, and what a real answer sounds like

1. "Which licence do you hold, the agency licence or an individual licence?" A licensed firm answers this immediately and distinguishes the two without prompting. Hesitation here is the answer.
2. "Who at your firm will actually do the work, and are they licensed?" Section 8 makes this the agency's problem as well as yours.
3. "What identification do you need from me?" If the answer is none, see above.
4. "This matter touches Vietnam. What are you allowed to do there, and what will you not do?" The best answer is a list of refusals. A provider who will not tell you what they decline to do has not thought about it.

There is a second set of questions for after the work comes back, and they matter just as much: a nil result is not a finding until you prove you could have found something. A licensed provider can still hand you a negative finding produced by a search that never ran.

The same four questions abroad, where the answers change shape

This is the part that catches out even careful buyers, because the instinct is to assume every jurisdiction regulates investigation roughly the way home does. Several do not.

Hong Kong does not license private investigation at all. The Security and Guarding Services Ordinance (Cap 460) regulates guarding work through four defined limbs, and investigation is not among them. Asking a Hong Kong provider for their investigator's licence produces confusion rather than a document, because there is no such instrument. The constraint there sits elsewhere, in the Personal Data (Privacy) Ordinance (Cap 486), whose doxxing offence under s 64 was strengthened in 2021 and reaches recklessness, with penalties on indictment running to $1,000,000 and five years.

Japan regulates the method, not the subject matter. The Detective Business Act (Act No. 60 of 2006) turns on how the work is done: interviews, tailing and stakeouts under Art 2(1). Work carried out solely by telephone enquiry or internet collection sits outside the definition. That is close to the inverse of Singapore, where the method is irrelevant and the purpose decides. A provider who tells you the same activity is regulated identically in both places has not read either statute.

South Korea's constraint arrives through credit and personal information law rather than through a private investigator's licence, which changes who you should be asking and what they should be showing you.

Across ASEAN the answers vary more than the region's reputation suggests, and in three member states we will not give you an answer at all. Brunei, Cambodia and Myanmar are not covered on this registry, and the reason is stated rather than hidden: without a served status register there is no way to confirm that a citation is still in force, and a legal position that cannot be checked is not worth publishing. Absence here means absence of a verifiable source, not absence of law.

The registry sets out what is published for each covered jurisdiction, provision by provision, with the date each entry was last verified against the instrument and an explicit note of what could not be confirmed.

What this article is, and who is writing it

AI9OS.COM (UEN 53527859D) is a publisher. It is a sole proprietorship. It is not licensed under the Private Security Industry Act, it does not carry out private investigation, and nothing on this site is an offer to do so. It publishes what the law says.

Spyrrus Tech Pte Ltd (UEN 202022197D) holds a private investigation agency licence under the Act. It is an affiliated company. The author of this article is its Head Investigator, OSINT, and holds an individual private investigator's licence. That affiliation is disclosed here because a reader is entitled to know it before weighing anything above.

The two are kept deliberately separate, and the line between them is the same one this article has been describing. Publishing what the law says is not regulated activity. Telling you whether you may proceed with your matter is. The first is what you are reading. The second is licensed work and is contracted directly with a licensed agency, which this publisher is not.

This is general information about legal provisions in force at the date shown. It is not legal advice, and it is not advice about your matter. Where the answer decides whether you may proceed, take it to a solicitor.