In this guide · 8 sections
- 01Do Singapore's DNC rules apply to WhatsApp?
- 02Marketing message or service message?
- 03Clear and unambiguous consent, and Meta's opt-in rule
- 04Broadcast lists vs WhatsApp API marketing templates
- 05Penalties and WhatsApp bans
- 06WhatsApp marketing checklist before you send
- 07Do it yourself or get help?
- 08Frequently asked questions
Short answer
Promotional WhatsApp messages to Singapore numbers fall under the PDPA's DNC rules: check the DNC Registry within 21 days, or get clear and unambiguous consent first. Meta also requires opt-in naming your business. Identify yourself and honour opt-outs, or risk penalties and a ban.
Do Singapore's DNC rules apply to WhatsApp?
Yes. The PDPC's Advisory Guidelines on the Do Not Call Provisions (revised 1 February 2021) say the DNC provisions apply equally to all ways of sending a specified message to a Singapore telephone number, including voice calls, SMS and data applications such as WhatsApp, iMessage or Viber that use a Singapore number.
A 'specified message' is broadly a marketing message: one that offers, advertises or promotes goods, services, land or a business opportunity. The DNC duties, set out in Part 9 of the PDPA, are:
- Check the DNC Registry within 21 days before sending, unless you have clear and unambiguous consent from the user of the number.
- Identify the sender and give contact details that stay valid for at least 30 days after the message.
- Do not hide your caller ID on voice calls.
- Never use harvested or generated numbers: section 48B of the PDPA prohibits sending messages to numbers obtained through address-harvesting software or using dictionary attacks.
Our guide to checking numbers against the DNC Registry covers the checking process, fees and the API.
Marketing message or service message?
Not every WhatsApp from a business is marketing. PDPC's guide to the DNC provisions lists messages that are not specified messages and need no DNC check.
| Message | DNC check needed? | Why |
|---|---|---|
| Appointment reminder | No | Strictly related to an existing transaction |
| Delivery or order confirmation | No | Confirms a transaction |
| Delivery update with a discount code | Yes | Adding a promotion makes it marketing |
| Change to a membership's terms | No | Relates to the ongoing relationship |
| New product offer to a one-off buyer | Yes | A one-off purchase is not an ongoing relationship |
| Offer to a staff member's office number about business software | Usually no | B2B messages to business numbers are excluded |
PDPC also warns not to assume that service messages with promotions are exempt. A single promo line in an order update turns it into a specified message.
Clear and unambiguous consent, and Meta's opt-in rule
With clear and unambiguous consent, you do not need to check the DNC Registry for that person. PDPC says consent must come from a positive action specific to these messages, the person must be told the messages go to their Singapore number, it must not be buried in general terms, and it should be recorded so you can refer to it later.
Meta adds its own rule. Its opt-in documentation and the WhatsApp Business Messaging Policy say you may contact people on WhatsApp only if they gave you their number and opted in to receive messages from you, with your business name clearly stated. Meta lets the opt-in be general rather than WhatsApp-specific, as long as you comply with local law, which in Singapore means the PDPA.
Use an unticked checkbox
For example: 'I agree to receive offers and updates from [Business name] by WhatsApp and SMS at the number above.' Do not pre-tick it.
Separate marketing from service consent
Order updates and offers are different. A separate box for offers keeps your service messages DNC-free and reduces blocks.
Record the evidence
Store the date, time, wording shown and source (website form, in-store tablet, WhatsApp keyword) against each number.
Make opting out easy
Include a line such as 'Reply STOP to opt out' and act on it promptly. Meta's policy says you must respect every opt-out request, on or off WhatsApp.
Broadcast lists vs WhatsApp API marketing templates
Broadcast lists (Business app)
- Up to 256 contacts per list
- Only people who saved your number receive it
- Free, from your phone
- No built-in consent records or opt-out handling
Best for: Very small businesses with customers who saved the number.
Marketing templates (Business Platform API)
- Pre-approved message templates for promotions
- Charged per delivered message, by market
- Opt-in capture, opt-outs and segments through a provider
- Quality signals and messaging limits apply
Best for: Regular campaigns to hundreds or thousands of opted-in customers.
WhatsApp's broadcast list help page sets the 256-contact limit and the saved-number requirement. On the API, Meta's pricing page says it charges per delivered message by category and market, and business-initiated messages outside a 24-hour customer service window must use templates. Our guide to WhatsApp Business API costs in Singapore has the rates. The PDPA rules are the same for both routes.
Penalties and WhatsApp bans
There are two kinds of consequence, and the second often arrives first.
- PDPC financial penalties: for breaches of the DNC provisions, the maximum is S$200,000 for an individual and S$1 million for others. For using harvested numbers or dictionary attacks, the cap for a person with Singapore turnover above S$20 million is 5% of that turnover, for breaches from 1 October 2022.
- WhatsApp restrictions: Meta's policy says it may limit or remove access if you receive significant negative feedback, and users can block or report businesses. On the API, quality ratings and messaging limits shrink when people block or report you.
- Number bans: a Business app number reported for spam can be banned, taking your customer chats with it. Our guide to fixing a banned WhatsApp Business account covers appeals.
WhatsApp marketing checklist before you send
Before each WhatsApp campaign
This checklist reflects PDPC and Meta guidance as of October 2026 and is general information, not legal advice.
Do it yourself or get help?
A shop with a few hundred loyal customers can run compliant broadcasts from the Business app if consent is recorded and opt-outs are honoured. Once you send regularly or to larger lists, the API with proper opt-in capture is safer and easier to audit.
Our WhatsApp Notifications (S$590) sets up the official Business Platform with approved templates, opt-in capture and triggers from your store. The PDPA Compliance Pack (S$690) prepares your privacy policy, consent wording and data inventory so marketing consent holds up.
Frequently asked questions
Yes, if you follow the PDPA's Do Not Call provisions and WhatsApp's own policies. Check numbers against the DNC Registry within 21 days or get clear and unambiguous consent, identify your business in each message, honour opt-outs, and never message numbers from harvested or generated lists. Meta also requires opt-in that names your business.
For marketing messages to Singapore numbers, yes, unless the person gave you clear and unambiguous consent to receive them or the message relates only to an ongoing relationship such as a membership or account. PDPC's guidelines say the DNC rules apply to WhatsApp and similar apps that use a Singapore number.
You should not. Meta's policy requires opt-in permission before you message people, and promotional messages fall under the PDPA's DNC rules. Broadcast lists also only reach people who saved your number. Adding people to marketing groups without permission leads to reports, blocks and possible account bans.
The PDPC can impose financial penalties of up to S$200,000 on an individual and up to S$1 million on an organisation for breaches of the DNC provisions. Using dictionary attacks or address-harvested numbers has separate penalties, with a higher cap for very large businesses. WhatsApp may also restrict or ban the number.
Only if it relates solely to an ongoing relationship, such as a membership, subscription or account, and the offer is about that relationship. A customer who made a single purchase does not have an ongoing relationship, so a new offer to them is a specified message needing consent or a DNC check.