Introduction

When discussing media governance models beyond the scope of Western liberal-democratic paradigms, scholars often focus on their similarities (Gehlbach and Sonin 2014; Frantz 2018). As an implicit presumption of such studies, the level of political control within non-Western information landscapes tend to be portaryed as uniformly stringent and rigid. This underlying presumption, however, should be subject to reconsideration since contemporary political scholarship has made significant strides in refining regime classification typologies in recent decades, unveiling a spectrum with varying shades of political control (Croissant et al. 2015). For instance, the seminal work of Diamond (2002) distinguished non-democratic regimes into those featuring multiparty elections and those characterized by political closedness. For either sub-type, the issue of journalistic governance is vital: News outlets hold the capacity to shape the prevailing discourse on contemporary affairs, substantially molding public sentiment (Pan et al. 2022). Via these channels of influence, press narratives can either buttress or undermine a regime’s stability (Stein 2016; Huang et al. 2019). Thus, the governance and orchestration of the information ecosystem emerge as a salient imperative in the context of authoritarian resilience (Nathan 2003).

To enhance our grasp of regulatory systems beyond the confines of the Western democratic-liberal model, we adopt a comparative case study approach (Hague and McCormick 2019). Our study contrasts two distinct cases employing a most-different design to control for the influence of numerous potential variables. Focusing on media governance, the analysis scrutinizes the regulatory frameworks and the embedded dynamics between the state and society. Regarding the methodology, we opt for a qualitative research strategy (Creswell and Creswell 2023; Kuckartz and Rädiker 2023), relying on primary sources like legislative documents and secondary sources. Qualitative methods are predominantly exploratory, incorporate a more reflexive understanding of the researcher’s role, and often rely on purposive sampling. They provide “thick descriptions” (Geertz 1973), facilitating hypothesis generation. Notably, a qualitative approach exhibits inherent challenges, such as the higher susceptibility to subjectivity, limited number of cases, and absence of quantifiable precision. However, the benefits outweigh the weaknesses: A qualitative comparative analysis offers detailed insights and a comprehensive understanding of the context. These strengths are vital when analyzing intricate regulatory texts and their broader societal impact.

To conduct the case study, we turn our attention to the two nations with evident authoritarian attributes: Singapore and Vietnam. Singapore, notably, eludes simplistic classifications, receiving designations such as hybrid or electoral-hegemonic authoritarian (Ong 2021). These varying categorizations arise due to the country’s departure from the principles of traditional liberal democracy without fully exhibiting the tenets of a conventional autocracy. Notwithstanding the presence of multiparty elections, the singular dominance of the People’s Action Party (PAP) since 1959 punctuates the Singaporean political landscape. Conversely, Vietnam is emblematic of a one-party authoritarian model, with governance vested in the Communist Party of Vietnam (CPV) since the nation’s unification in 1976 (Schmidt 2015).

The rationale for selecting Singapore and Vietnam rests on three considerations. Firstly, in line with the most-different research design, these nations exhibit stark contrasts in ideology, economic development, cultural norms, historical context, and social dynamics (e.g., ethnic homogeneity).Footnote 1 Despite these differences, both countries have achieved political stability over many decades, distinguishing them from other failed authoritarian and hybrid cases. This regime resilience invites an investigation into what commonalities and disparities underlie their durability, specifically concerning media governance. Secondly, each country approximates a “typical” case within their respective classification. Singapore is often cited as a paradigmatic hybrid regime (Tan and Preece 2022), whereas Vietnam embodies many characteristics of authoritarian states. Juxtaposing these nations, we hope to facilitate a more pronounced comparison and offer insights for other contexts, thereby improving the generalizability of the findings. Thirdly, research on media governance outside liberal democratic settings disproportionately centers on China. Incorporating Singapore and Vietnam diversifies and enriches the academic discourse, introducing a more nuanced understanding of media governance across different political regimes.

While contrasting the media regulatory paradigms of both nations promises vital insights, such analyses remain scarce. Existing scholarship predominantly consists of individual investigations regarding the press landscapes of Vietnam (Libby 2011; Cain 2014) and Singapore (Lee and Ansara 2017; Ducharme 2018). Although publications analyzing Southeast Asia sometimes encompass both countries, they typically discuss them in isolated chapters (Williams and Rich 2013; George and Venkiteswaran 2019). Notable exceptions, such as Aim Sinpeng’s exploration of digital media across the broader Southeast Asian region (Sinpeng 2020), remain infrequent and do not undertake an exhaustive comparison between Vietnam and Singapore.

In light of this research gap, this study aspires to juxtapose media governance and journalistic practices in Vietnam and Singapore. Our overarching research questions are as follows: Firstly, which media regulations have Vietnam and Singapore instituted? Secondly, how do these frameworks impact the day-to-day operations of news outlets? Thirdly, in what manner do these policies bolster the stability of the prevailing ruling coalitions?

Our findings reveal that both Vietnam and Singapore have implemented extensive media regulations, including censorship, ownership controls, personnel management, and repression instruments. Compared to Singapore’s subtler, network-oriented strategy, Vietnam adopts a more coercive approach characterized by explicit political guidelines. Since the 1980s, Vietnam’s media governance regime appears to have emulated elements of the Singaporean model, incorporating less overtly repressive measures and embracing pro-market elements. In their entirety, these two legislative frameworks profoundly affect the daily lives of journalists, curtailing their ability to conduct their work independently. Vietnamese press institutions are subject to more direct state oversight and face harsher consequences for non-compliance. Conversely, journalists in Singapore enjoy greater autonomy, but the institutional setup guides them to support the government’s narratives. The Singaporean government has also increasingly utilized legal actions to engender conformity. Lastly, media governance has likely contributed to the longevity of these regimes. Vietnam’s stringent media controls stifle dissent more rigorously, theoretically constructing an information environment that bolsters the position of the ruling coalition. Nevertheless, the severity and blatancy of the political interventions may inadvertently foster distrust and prompt citizens to seek unregulated news sources, potentially undermining the long-term stability of the status quo. At first glance, Singapore’s media framework affords more space for (limited) dissent and oppositional forces. Nevertheless, Singapore’s mix of behind-the-scenes incentive structures and fine-tuned coercion tactics may prove to be more efficient for a highly differentiated market economy with porous information borders in the 21st century. Projecting into the future, the rising share of opposition votes in Singapore and substantial societal transformations in Vietnam pose questions about the future efficacy of these media systems in ensuring regime resilience.

The significance of this research undertaking is severalfold: Primarily, it seeks to address the lack of comparative investigations into media governance mechanisms across authoritarian and hybrid regimes—namely, political entities marked by varying degrees of authoritarian characteristics. Such efforts are essential to counter the oversimplifications that often emerge in prevalent perceptions. Secondly, this research is crucial to government officials, non-governmental organizations (NGOs), and journalists who engage with and operate within these two nations. A nuanced understanding of the distinctive dynamics of media regulation in these contexts can enhance decision-making and strategic initiatives. Lastly, against the backdrop of heated debates surrounding press governance, a comparative analysis aids in discerning prevailing trends in regulatory approaches and in anticipating potential trajectories on a global scale.

This article begins with exploring the significance and salience of authoritarian and hybrid regimes. Subsequent sections delve into the scholarly literature concerning media control within authoritarian milieus and provide background information for both Vietnam and Singapore. Following this, we embark on a meticulous comparative examination of the media landscapes of these two nations, culminating in a synthesis and concluding remarks.

Vietnamese authoritarian and Singaporean hybrid structures compared

Throughout the annals of political scholarship, scholars have grappled with the delicate task of categorizing political regimes. Traditionally, this endeavour relied upon a reductionist and rigid binary classification, dichotomizing the world into authoritarian or democratic systems. However, as the discipline of political science matured, it embraced a more nuanced approach, one that acknowledges the intricate variations inherent to political systems (Croissant et al. 2015). This paradigm shift underscores that political realities are not beholden to rigid dichotomies but instead manifest along a complex spectrum, encompassing myriad grey shades and gradations between the poles of authoritarianism and democracy (Frantz 2018). Authoritarianism represents a multifaceted concept, with various permutations and amalgamations of democratic and authoritarian attributes.

The task of categorizing nations within this refined conceptual framework represents an intellectual challenge predicated on three central considerations: Firstly, the issue of how to delineate democracy and, conversely, its absence remains an ongoing and contentious matter steeped in subjective interpretation. Secondly, assessing the precise political character of a particular country is complex, given the inherent ambiguities concerning the availability and reliability of information sources. Lastly, interpreting a nation’s political system through the prism of these classifications necessitates careful deliberations, as scholars, while striving for objectivity, inevitably rely on subjective judgment (Diamond 2002).

When considering regime classifications, the work of Larry Diamond offers a helpful framework. Diamond’s taxonomy discerns Singapore as the quintessential exemplar of a hybrid regime characterized by the delicate interplay of democratic and authoritarian elements. Specifically, Singapore embodies a variant of hegemonic electoral authoritarianism: It conducts multiparty elections to determine the country’s leadership, yet the system inherently tilts the balance in favour of the ruling party. Crucially, party and government apparatus maintain distinct identities in this political structure. Such hybrid regimes, as typified by Singapore, frequently eschew obvious or coercive methods of repression, instead opting for subtler and less overt mechanisms of control (Croissant and Lorenz 2018).

In stark contrast, Vietnam aligns more closely with the concept of a politically closed regime, where the ruling party wields undisputed supremacy over the political terrain, effectively marginalizing substantive opposition and curtailing political pluralism. Although Larry Diamond’s insights are rooted in a bygone era, their relevance endures. While Vietnam exhibits sporadic pockets of dissenting voices, the pervasive influence of a single party continues to cast an enduring shadow over the official political landscape. In Singapore, the expanded electoral presence of the opposition, while noteworthy, has yet to culminate in a power transition to an opposition party. Certainly, scholars may engage in spirited debates over these nuanced classifications, but the overarching trajectory remains evident: Although neither nation adheres entirely to the prototypical closed authoritarian model, Vietnam gravitates more distinctly toward authoritarianism. In comparison, Singapore encapsulates a more intricate, hybrid fusion of democratic and authoritarian attributes.

The media ecosystem across different regime types

Historically, states characterized as authoritarian have configured their media systems in alignment with the interests of the ruling coalition, relegating dissenting voices to the periphery (Frantz 2018). This strategy typically involves deploying two central mechanisms of control over the media landscape. On the one hand, these regimes assert their authority in selecting key personnel, including influential decision-makers within journalistic institutions. On the other hand, they wield the tool of censorship, both proactively to restrict information prior to the dissemination of news (ex-ante) and reactively to curtail distribution after publication (ex-post).

The deliberation over the specific design of press institutions carries substantial consequences for the endurance of a regime. The media environment plays a pivotal role in shaping public opinion, either fortifying or undermining a regime’s stability. Specifically, information disseminated by press actors enables public discourse and delineates the boundaries of acceptable discourse (Pan et al. 2022). Moreover, the media discourse not only informs the general populace but also serves as an informational conduit for opposition forces, offering insights into the prevailing state of government affairs. These dynamics imbue the media with the dual function of acting as a barometer and a catalyst for socio-political satisfaction or discontent (Stein 2016).

Acknowledging these mechanisms, ruling coalitions in authoritarian settings strive to establish control over the media landscape, thereby facilitating the dissemination of pro-government narratives (Stein 2013). However, such regimes grapple with a dilemma (Gamboa 1995; Collings 2001): they must curtail the circulation of unfavourable and sensitive information but, at the same time, solicit societal feedback to refine policy implementation processes and identify pockets of discontent (Graber 2003; Lee and Chan 2009; Sheen et al. 2022). Helping to quell corruption and localize protests, journalists represent a valuable information channel. Paradoxically, overt government interference in the news cycle risks completely delegitimizing the press, undermining its benefits for the ruling coalition (McGreevy-Stafford 2020). Consequently, pursuing a delicate equilibrium between control and minimal interference is paramount for regimes to achieve resilience.

Within this broader context, it is imperative to recognize that media systems in authoritarian and hybrid states exhibit considerable variation in terms of political control (Whitten-Woodring 2009). Generally, the extent of media scrutiny imposed corresponds to the level of hybridity and openness. While substantial research endeavours have been dedicated to distinguishing between media regimes in democratic and authoritarian contexts, the exploration of finer distinctions among states exhibiting authoritarian traits remains in its nascent stages. The work of Hallin and Mancini (2004), illuminating diverse models of media systems within liberal democracies, sparked a spirited debate regarding the applicability of their analytical framework beyond Western democratic contexts. Building upon this foundation, Voltmer (2011) advocated for a more expansive analytical framework encompassing the Global South. However, her focus is still primarily centered on democracies, with only a limited number of hybrid cases.

As a result, research about the roles played by media within non-democratic settings remains notably underdeveloped. The scholarly characterization of the media often oscillates between two extremes: Journalists are either a mere conduit for disseminating government ideologies or a pivotal element in challenges posed to the political system (Heinrich and Pleines 2018; Xia et al. 2022). Past studies have typically delved into one particular regime type, such as competitive or hegemonic authoritarian regimes (Akhrarkhodjaeva 2008; Jamil 2023), or undertaken broad comparative analyses between authoritarian and democratic political systems (Gehlbach and Sonin 2014; Peleg 2019). A notable exception is Toepfl (2020) who introduced a more nuanced perspective by categorizing societal public spheres (including the media) within authoritarian contexts into three distinct typologies: 1) “uncritical publics”, characterized by the absence of criticism unless it aligns with the interests of the ruling coalition; 2) “policy-critical publics”, where criticism is directed towards lower-level institutions, policies, and officials; and 3) “leadership-critical publics”, where criticism extends to the country’s central leadership. Each authoritarian-leaning country may exhibit one, two, or all three typologies, each offering a unique interplay of benefits and drawbacks for the ruling coalitions. Similarly, Whitten-Woodring and Patrick (2012) underscore the diversities inherent in political control and media governance within non-liberal-democratic nations. According to their findings, multiple factors contribute to this variance, such as international and civil conflicts, which tend to undermine media freedom. Another study finds that the availability of natural resources can significantly influence the dynamics governing media control (Egorov et al. 2009).

Despite these theoretical frameworks offering essential conceptual scaffolding, a systematic examination of media ecosystems across states characterized by varying shades of authoritarianism remains sparse. This research gap is particularly pronounced when considering countries such as Vietnam and Singapore. Typically, these two nations are incorporated into broader media studies encompassing Southeast Asia (Williams and Rich 2013; George and Venkiteswaran 2019) but are rarely subjected to comprehensive analytical comparisons. Therefore, in the subsequent section, we shall provide a comparative analysis of the media governance landscapes in Singapore and Vietnam.

Media regulatory frameworks in Singapore and Vietnam

Singapore

The media governance paradigm in Singapore is fundamentally anchored in the imperative of preserving internal stability, positioning the press within the overarching dominance of the political superstructure (Ducharme 2018; Lee 2016). Singapore’s Constitution does not even contain any reference to the press or the concept of press freedom.Footnote 2 It is worth noting, however, that journalists in Singapore assume a role that is both constrained and constructive, contributing to the broader objectives across the political, social, and economic spectra (Tey 2008).

To begin with the bureaucratic structure, the responsibility for content regulation across all forms of media rests with the Ministry of Communications and Information (MCI) and its affiliated agency, the Info-communications Media Development Authority (IMDA). The authority of the IMDA stems from the 2016 Info-communications Media Development Authority Act (IMDA Act). In concert with the Newspapers and Printing Presses Act (NPPA), the Broadcasting Act (BA), and numerous ancillary statutes,Footnote 3 the IMDA Act constitutes the bedrock of Singapore’s media regulatory system (Lim 2022). Notably, the MCI wields the power to grant or revoke annual media licenses, representing a potent instrument to oversee and control media entities. Additionally, online news platforms reporting consistently on Singapore and drawing significant local IP traffic are mandated to secure individual broadcasting licenses.

In terms of media coverage, the IMDA exercises a considerable degree of discretionary authority through its content guidelines. Journalists may face state interventions when their endeavours deviate from the vague concepts of the “public interest”, “public order”, and “national harmony”, or when they traverse the bounds of “good taste” and “decency” (Lim 2022). News websites must provide a performance bond of US$50,000 and swiftly remove content that runs afoul of the “public interest” (Lee and Ansara 2017). While critical content (e.g., corruption) may surface, news reporting tends to align with government interests. However, there exists a shifting grey area demarcated by informally designated “out-of-bounds markers” (OB markers), delineating topics of politically accepted speech. These implicit boundaries encompass satire targeting government officials, ongoing political controversies, discussions about race, religion, sexual minorities, and diplomatic relations (particularly with Malaysia, Indonesia, and China). These subjects are generally considered taboo or subject to rigorous scrutiny, with media outlets predominantly adhering to government-prescribed guidelines (George 2012; Nie et al. 2013; BBC 2020).

In the areas of staffing, management, and ownership, it is essential to highlight that government-linked institutions hold stakes in major news organizations (Freedom House 2023a). These affiliations provide the government with a lever to influence pivotal positions within newspaper companies, encompassing board members and senior editorial personnel (George 2014; Reporters Without Borders 2023a). In many instances, former trusted government officials ascend to the upper echelons of the media elite. Their presence further diminishes the likelihood of adversarial reporting (George 2012; George and Venkiteswaran 2019).

Beyond the realm of privatized entertainment, the media landscape in Singapore is essentially dominated by two entities: the Singapore Press Holdings (SPH)Footnote 4 and MediaCorp, owned by a state investment agency. SPH maintains close ties with the ruling party and enjoys a quasi-monopoly over the print press.Footnote 5 Simultaneously, MediaCorp dominates the domestic free-to-air TV and radio sector, affording the state considerable influence in staffing decisions at the managerial and editorial levels. Together, these two conglomerates exert significant influence over all local print newspapers and broadcasters while also increasingly expanding their presence in the digital domain (Lee and Ansara 2017).

Furthermore, newspaper companies are required to be publicly listed on the stock exchange. This rule aims to ensure that the profit motives of shareholders serve as a restraint on ideologically driven publishers who might be inclined to provide a platform for dissident voices (Kan 2020). Importantly, an investor’s stake in a media entity cannot exceed twelve percent without prior government approval. The ruling coalition thereby ensures that ownership remains diffused and prevents the rise of influential actors with political aspirations who could potentially challenge government interests (George 2014, 2021). This mechanism fosters a consortium of investors who primarily converge on a shared pursuit of profits, incentivizing them to support political stability and establish a harmonious relationship with government institutions (Edge 2014).

A distinct facet of this media ownership framework is the prevalence of management shares. As a unique type of stock, they grant their holders disproportionately greater voting weight – two hundred to one compared to ordinary shares – in matters pertaining to personnel decisions (Croissant and Lorenz 2018). Management shares are typically conferred upon establishment figures and government-affiliated entities, following a process that requires state approval (Rajah 2012; Edge 2014). This regulatory modification effectively enables the ruling coalition to co-opt establishment and market forces, nurturing a vested interest among these stakeholders in maintaining a stable political climate. Furthermore, since 2002, entities aiming to become substantial shareholders of a newspaper company or to amass a sizable stake in a broadcasting company must first secure the approval of the MCI (Lim 2022).

Concerning foreign actors, the IMDA imposes additional restrictions on foreign ownership in news organizations. Any infusion of foreign funds into a media company necessitates the prior approval of the IMDA. Furthermore, foreign entities are expressly barred from assuming majority voting power in companies engaged in broadcasting in Singapore (Hao 2022). Similarly, newspapers are obligated to maintain local ownership (Croissant and Lorenz 2018). The rules also stipulate that the CEO and at least half of the directors at a broadcasting company, as well as all directors of a newspaper outlet, must be Singaporean citizens. Any departures from these rules, again, necessitate approval by the MCI (Lim 2022).

The regulatory landscape governing foreign interference in Singaporean news organizations is further buttressed by the Foreign Interference (Countermeasures) Act. Under this legislative framework, Singaporean news organizations are prohibited from conducting political reporting in the country on behalf of a foreign principal. Disregarding these stipulations carries the penalty of removal and online blocking. Designated foreign publications or broadcasts deemed to be interfering in domestic politics may face bans or restrictions on their sale and distribution (Nie et al. 2013). Additionally, foreign media organizations operating in Singapore must designate a local representative who is accountable in the event of a libel lawsuit (Croissant and Lorenz 2018). These regulations deftly leverage the commercial interests of foreign media entities, compelling them to operate within the regulatory confines and engage in self-censorship (George and Venkiteswaran 2019).

In light of the growing prominence of the digital realm as the primary conduit for news dissemination, Singapore enacted the Online Safety (Miscellaneous Amendments) Act in 2023. This legislation empowers the state to swiftly remove, rectify, or label digital content deemed erroneous (Kan 2020). Accordingly, content providers, Internet Service Providers, and news outlets must delete content flagged as unacceptable by regulators (Freedom House 2022a). When actors fail to comply with these directives, authorities can block the respective websites and social media platforms (Tham and Lim 2022; Yu 2023). Nevertheless, the government typically resorts to outright blocking websites only in a small number of cases, including in those associated with terrorist content.

To enforce these aforementioned regulations and penalize infringements, the Singaporean state maintains a robust arsenal of repressive instruments at its disposal. Journalists run the risk of being charged with sedition, defamation, or for transgressing religious sensitivities (Chong 2012). Statutory provisions, such as the Penal Code and Sedition Act, enable the imprisonment of individuals considered antagonistic to the state. Moreover, the Internal Security Act empowers the government to effect arrests without the need for warrants and to detain individuals without trial (George and Venkiteswaran 2019). Criminal penalties for speech perceived as seditious, defamatory, or injurious to religious sensitivities can be draconian (Freedom House 2023a).

Despite this extensive legal arsenal, the government predominantly relies on libel cases, defamation lawsuits, or charges of contempt of court instead of resorting to these harsher measures as the primary mode of control (George 2012; Tan 2014). Offenses may result in substantial financial penalties or, on occasion, custodial sentences. Consequently, the most repressive and punitive measures do not constitute a common feature of Singapore’s media landscape but primarily function as a deterrent (Tey 2008; Ducharme 2018). Infrequent high-profile prosecutions, coupled with the selective removal of content and the ambiguities surrounding OB markers, foster an environment of self-censorship. These characteristics render direct and overt government censorship less relevant (Rajah 2012).

In sum, the Singaporean media system can be characterized as part of a state-guided “networked hegemony” (George 2012), underpinned primarily by ideological facets and buttressed by the looming prospect of state interventions. Within this milieu, tightly-knit social and political connections engender high in-group cohesion and norm conformity among media circles, delimiting a sphere of freedom that operates within prescribed boundaries. Armed with these insights, we now transition to the case of Vietnam.

Vietnam

Article 25 of Vietnam’s Constitution ostensibly enshrines press freedom for its citizens, yet this nominal provision is eclipsed by the pervasive influence exerted by the CPV. The CPV, guided by the ideological tenets of Marxism-Leninism, holds a firm grip on the nation’s media landscape (Heng 1998). Within this hierarchical media structure, the party occupies the apex position, presiding over an intricate web of formal connections that extends downward from the Party Politburo, cascading through various Party and government “supervisory organizations”, ultimately converging at the editor-in-chief of the publication and, subsequently, the editors and journalists (Hayton 2010).

Two preeminent institutions stand at the vanguard of regulatory oversight within this media ecosystem: the state’s MIC and the party’s Central Propaganda and Education Commission.Footnote 6 The former oversees legal matters, including licensing and penalties for media law violations. In contrast, the latter institution plays a crucial role in ideological surveillance, monitoring state institutions and wielding significant influence over the machinery of censorship.Footnote 7

Notably, the 2016 Press Law introduced a certain ambivalence concerning the role of journalists.Footnote 8 On the one hand, it mandates media entities to disseminate factual information, upholding their right to collect and disseminate information while criminalizing any interference in their journalistic endeavours. On the other hand, this legislation demands that media outlets propagate information in line with the party’s sanctioned stance (Hayton 2010). When in doubt about how to reconcile these opposing ideals or confronted with the looming spectre of punitive measures, the latter principle invariably supersedes any professed commitment to journalistic autonomy and impartiality (Le and Hutchinson 2022).

Turning our attention to the domain of media coverage, the government wields the power to prohibit or demand modifications to content. This form of censorship culminates in two recurrent weekly gatherings orchestrated by the MIC, one convened in Hanoi and the other in Ho Chi Minh City.Footnote 9 All major media stakeholders are summoned to these meetings, which disseminate directives on censored content and provide guidelines for handling sensitive subjects. At these gatherings, news outlets are either castigated for content deemed too critical or praised for adhering to the “correct” ideological position. Deviations from the party line may culminate in punitive measures, ranging from the replacement of personnel to the suspension or outright closure of media outlets. Through these carefully orchestrated mechanisms, the authorities directly manipulate and oversee the content disseminated within the media landscape.

Topics regarded as veritable taboos include the contours of political pluralism, human rights discourse, religious matters, political unrest, the upper echelons of the party hierarchy (Nguyen et al. 2022), civic rights, sensitive aspects of Vietnam’s relationship with China, and any narrative that challenges the legitimacy of the CPV. In contrast, certain subjects are granted a degree of latitude and leniency, affording journalists considerable manoeuvrability within this tightly circumscribed realm of media expression:Footnote 10

. . . [T]he CPV tolerates some criticism, mostly internal, as an instrument of rule, while occasionally and arbitrarily striking down at detractors who venture outside a hazy red line: that is, the writing of these dissidents directly threatens the party-state’s claim to legitimacy (Cain 2014).

Undoubtedly, since the advent of the Doi Moi era, marking the onset of Vietnam’s reform-and-opening-up undertaking, the country’s media system has undergone profound changes. Societal pluralization, the burgeoning influence of market dynamics, and visible elite discord have collectively engendered a noteworthy expansion of the discursive sphere.Footnote 11 Within this shifting terrain, the boundaries of permissible criticism, albeit within circumscribed limits, have notably broadened, encompassing heretofore untouchable domains. Such subject areas include environmental problems, corruption, and policy implementation issues. Although corruption represents a sensitive topic, the party apparatus has allowed some coverage of corrupt practices to curtail their proliferation (Hayton 2010; Cain 2014; Nguyen et al. 2022). Nevertheless, investigative journalists, whether motivated by financial incentives or moral rectitude, must tread the treacherous needle of party politics. Any effort to report on misconduct within the upper echelons of the party hierarchy is still strictly prohibited (Nguyen 2022).Footnote 12

Turning the analysis to the underlying nexus of staffing, management, and ownership, it is crucial to highlight that every publication is held entirely or partially by the state – albeit in some instances, the state’s role is relegated to a more ancillary and peripheral capacity. Since 2016, the regulatory bodies have also compelled every media entity to register under the aegis of a state, political, social, or religious entity (referred to as the press managing agencies).Footnote 13 The government leverages these mechanisms to assert its authority, presiding over and granting approval to all pivotal personnel decisions within media institutions (Nguyen et al. 2022). Party membership serves as a vital instrument to reinforce this system: CPV members hold the majority of key positions in major newspaper entities, including editors-in-chief, senior editors, and managerial cadres (Hayton 2010; Nguyen 2022). A party member also occupies the influential position of newsroom secretary, guiding the contours of published content. Adding to this tight-knit web of political control, the head of any press managing agency bears responsibilities in case any journalist under their purview transgresses existing laws.Footnote 14 Despite these pervasive characteristics, the media terrain has witnessed a burgeoning diversification in the post-Doi Moi era (Hayton 2010), with a proliferation of privately owned news organizations increasingly punctuating the Vietnamese news environment (Nguyen 2022; Nguyen et al. 2022).Footnote 15

Besides domestic institutions, the provisions also target foreign entities, which face an even tighter controlled regulatory provisions. With few exceptions, installing satellite dishes designed to capture international broadcasts is banned, while foreign content disseminated via any pay television service is limited to thirty percent of the overall coverage (George and Venkiteswaran 2019). These stringent measures are reinforced through specific requirements for foreign news content: International television streams must operate under a deliberate temporal delay, ostensibly intended to facilitate censorship. All content about Vietnam is subjected to meticulous scrutiny prior to its dissemination. Regarding foreign journalists, the press law mandates that they secure prior approval from the Foreign Ministry’s Press Department before conducting journalistic activities (Hayton 2010).Footnote 16

In the age of online journalism, the party-state also exerts its dominion over the digital media realm (Le and Hutchinson 2022). The regulatory bodies utilize a digital firewall, albeit one that, when juxtaposed against its Chinese counterpart, is comparably porous (Freedom House 2022b). Websites that dare to broach politically, religious, or morally sensitive topics face blockage or censorship. Additionally, authorities wield the authority to outlaw content deemed a threat to national security or the social order (Hayton 2010). According to the 2019 Cybersecurity Law, websites and social networks that engage with socio-political and economic themes are required to secure a license and establish servers within the territorial confines of Vietnam. The stored data must remain accessible to authorities for up to 2 years (U.S. Department of State 2015; Nguyen 2018). Although social media sites such as Facebook and YouTube remain accessible (Nguyen-Thu 2020), the government can order the deletion of content from these platforms within 24 h (Strangio 2022).

To enforce this regulatory framework and penalize transgressions, the state deploys an extensive arsenal of hard-edged repression instruments, including arrests, the closure of news organizations, threats, intimidation, pervasive surveillance, court trials, and libel laws (Abuza 2015; Nguyen et al. 2022). The Penal Code criminalizes nebulous charges such as “anti-state propaganda” (Abuza 2015), while Decree 72 penalizes creators of online content that runs afoul of the state’s prescribed narrative. High-profile legal actions with severe penalties and ambiguous boundaries of accepted speech undergird this system, creating a climate of fear and self-censorship. Journalists learn to internalize the tacit rules of the game (Freedom House 2022b), but

. . . [t]his does not mean that Vietnamese journalists only write what they are told to, but that an essential part of their job is to identify risk, to avoid being negatively listed and to be creative in the grey area that is expanding or shrinking depending on different political situations (Nguyen-Thu 2020).

In sum, the forces of economic and societal modernization push against and pull away from the pillars of the country’s media system. Direct state interventions and a top-down relationship between authorities and journalists characterize the regulatory framework. Yet, while the state tries to monitor crucial steps of the journalistic process, the growing complexity of the media environment hampers stringent oversight, leaving more room for journalistic agency.

Comparing Singaporean and Vietnamese media governance landscapes

Table 1 juxtaposes key attributes of the Singaporean and Vietnamese media governance landscapes. Before delving into the details, it is important to note that significant differences between the two cases lie beneath superficial resemblances. Each detail holds significant and tangible ramifications for journalists and their lives. Conversely, within these distinctions, one can discern overarching abstract commonalities. As such, we shall embark on a dialectical argumentation, elucidating the contrasts within similarities and vice versa.

Table 1 Comparing the Vietnamese and Singaporean median governance landscape
Full size table

To begin with, we find that both regimes assert their influence over their respective media domains. Regulatory bodies exert control in areas such as censorship, ownership, and personnel management to shape the disseminated narratives. Nonetheless, the degree of intervention and the methodologies employed exhibit marked disparities. The Vietnamese government predominantly adheres to a direct, repressive, and state-centric modus operandi. A notable illustration of this dichotomy is evident in the contrasting incarceration rates of journalists. In 2018, Vietnam witnessed the imprisonment of eleven reporters, a stark contrast to Singapore’s absence of such incarcerations (Xia and Shen 2020). Consequently, Freedom House categorizes the Singaporean press as “partly free” (Freedom House 2023a), while its Vietnamese counterpart is deemed “not free” (Freedom House 2023b). Likewise, Reporters Without Borders ranks Singapore at 129th place out of 180 countries (Reporters Without Borders 2023a), whereas Vietnam occupies the 178th position (Reporters Without Borders 2023b) in its 2023 Press Freedom Index. To expound upon how these abstract distinctions materialize in the intricate interplay between the state and journalists in both contexts necessitates an approach transcending a mere enumeration of technical regulations. Hence, we will use the following descriptions to accentuate the essence of the quotidian dynamics within newsrooms. First for Singapore:

Contrary to folklore, the newsroom does not receive daily instructions about what to publish, and sensitive articles are not submitted to government officials for vetting. . . . The most senior figures in the leadership prefer to have editors who independently come to the right conclusions – even if they occasionally do not – than to replace them with mere functionaries. As members of the establishment, newspaper editors are expected to have an instinctive grasp of Singapore’s national interests and how to protect them. They interact regularly with cabinet ministers to keep these instincts honed. . . . Editors are [also] able to argue privately to PAP leaders . . . that to stand a chance in this competition for eyeballs, the national media must be free . . . to create compelling products. Persuaded by this argument, the government has allowed editors to follow their news judgements instead of official taste in much of their day-to-day decision-making (George 2002).

And next for Vietnam:

Every Tuesday a group of mainly grey-haired men gathers outside an imposing colonial building on Nguyen Du. . . . This is the weekly gathering of Vietnam’s media elite: around 100 of the country’s editors-in chief. It’s not a press conference, what goes on inside the [MIC] is never reported and no one outside the select group of regular invitees has ever been allowed in. . . . This is where the [CPV] manages the media. . . . Once all the editors are seated, a senior official . . . opens proceedings. It’s rarely a discussion, more often a critique. The [official] reads out a list of items in Vietnam’s newspapers, magazines, radio programmes, television bulletins and websites which the Ministry thought were ‘negative’: such-and-such a publication, the page number, the title of the article and the reasons why it has offended the Ministry’s sensitivities. It’s the first warning, a simple ticking-off. . . . [R]epeated failures bring tougher penalties – editors-in-chief can be ordered to replace their editors and publications can be fined, suspended or even banned altogether (Hayton 2010).

The preceding quote vividly exemplifies the meticulous manoeuvring undertaken by the Vietnamese party-state to orchestrate and oversee the media landscape. It is an intricate dance wherein party representatives are strategically deployed throughout the media infrastructure. These actors effectively communicate the government’s expectations and objectives. The CPV strives to tether journalists closely to the state’s agenda, permeating the very fabric of journalistic spaces, from the lofty realms of constitutional provisions down to the micro-level interactions between editors and their subordinates. In contrast, the Singaporean modus operandi adopts a network-oriented approach, wherein trusted stakeholders occupy critical positions within the media hierarchy. These individuals, socialized into the system and intrinsically motivated by profit, tend to adhere to the tacit rules of the game. Singapore’s approach is fortified by targeted state interventions, regulations, and legal actions, effectively tilting the playing field in favour of pro-stability and pro-establishment forces. Consequently, the Singaporean system does not necessitate the presence of a government representative in every newsroom deliberation.

Yet, beneath these palpable distinctions, a tapestry of shared commonalities arises. While the spectre of repression and brute force constantly looms, these are not the primary instruments deployed by either regime. Instead, the most severe punitive measures serve as a deterrent and are infrequently invoked. Occasional high-profile court cases act as a stark public reminder of these states’ capacity to wield power, notwithstanding the harrowing personal consequences endured by the persecuted individuals. In both contexts, the prevailing control mechanisms encompass softer forms of repression, media regulations, and (self-)censorship. Journalists are incentivized to exercise self-restraint, either out of apprehension for repercussions or ideological alignment with the government. This reduces the imperative for overt state censorship, dispelling the stereotypical notion of an omnipresent authoritarian ‘big brother’ meticulously scrutinizing every journalistic venture.

At times, the authorities can merely react retroactively to the publication of a sensitive news story, as journalists, acting autonomously, venture beyond the discursive boundaries prescribed by the state. In such instances, the authorities must grapple with the centrifugal forces they have inadvertently fostered—a dilemma encapsulated by the evocative phrase: “Spirits that I’ve cited, my commands ignore”. Particularly in Singapore, journalists often encounter situations in which they must make editorial decisions in the absence of explicit government directives, increasing the likelihood of transgressing the government’s approved narrative. For those who overstep the fine line of political correctness, the response varies depending on the severity of the infringement and the offender’s prior record. Individuals with a clean slate may receive milder penalties or even an opportunity to retract their stories. Thus, Singaporean and Vietnamese journalists, in concert with state regulators, engage in a carefully choreographed and nuanced interplay within the well-defined boundaries of acceptable discourse, mirroring Erving Goffman’s micro-sociological understanding of role-playing.

There exist other similarities between these regimes’ media governance strategies, such as the overlapping spheres of (self-)censored content, encompassing topics like international relations, state or party-state personnel, and religious matters. On occasion, authorities in Singapore and Vietnam permit critical reporting on sensitive subjects like corruption, provided that such information yields tangible benefits for the government’s legitimacy. In a parallel vein, ownership and commercialization reveal, perhaps counterintuitively, shared traits characterized by a mix of (party-)state involvement and private investment. While the CPV retains a nominal stake in every media enterprise, it has significantly expanded private participation in the media sector and advocated for the commercialization of the press. This process has led to dwindling state subsidies for news organizations, requiring these press actors to operate according to market imperatives to increase profitability. This dynamic mirrors the Singaporean experience: The authorities in the city-state already recognized several decades ago that capitalist forces, public ownership, and commercial interests need not threaten political stability. Quite the opposite, the ruling coalition can strategically harness profit-driven private entities and influential establishment figures to advance the regime's interests, fostering a convergence between political and media elites.

Additionally, several other parallels come to the fore. Firstly, both countries—albeit with differing degrees of directness—utilize a conventional authoritarian tool, namely the naming or influencing of personnel within the newsroom and at the managerial level. Secondly, foreign news actors encounter a multitude of restrictions in each regime, with authorities perceiving foreign journalists as a particular threat. Thirdly, the regulatory bodies obstruct website access and suppresses content within the digital realm. Singapore, however, imposes restrictions on a smaller number of websites, numbering around 200 in 2019 (Yahoo News Singapore 2019), whereas Vietnam blocked approximately 2,000 websites in 2021 alone (Freedom House 2022b). While Vietnam employs broader filtering measures, many foreign news organizations and social media platforms, such as Facebook, remain accessible, much like in Singapore. Authorities in either country place greater emphasis on content removal rather than outright website blocking.

Beyond these commonalities, two pivotal distinctions emerge, primarily concerning the guiding ideologies and the structural differentiation between the Vietnamese party-state and the Singaporean system. While the latter explicitly segregates the dominant party from state roles, the Vietnamese government operates under the aegis of the party, with Marxist-Leninist principles serving as the foundational bedrock shaping media dynamics. Singapore, in comparison, lacks such a core ideology. Nevertheless, Singaporean elites are also influenced by various ideological currents, including pragmatism, free-market capitalism, and the concept of Asian values.

Conclusion

The metaphorical adage shared by a Vietnamese editor, “[t]hey want the knife to be sharp, but not too sharp” (Hayton 2010), captures the Vietnamese party elites’ view of the media’s role. However, given the differing regulatory landscapes of Singapore and Vietnam, one might ponder about the specific nature of this metaphorical knife. These two countries’ divergent strategies arguably stem from their distinct political, socio-economic, and ideological backgrounds. Vietnam’s media system originates from a Marxist-Leninist tradition. Accordingly, the press acts as a tool of the proletarian vanguard party to combat class enemies (Heng 1998; Cain 2014). The exigencies during the Vietnam War and following reunification potentially intensified the impetus to bind the media tightly to the political system. This adherence to Marxist-Leninist principles resulted in an institutional framework that encouraged direct oversight and a media financially dependent on the state. Due to the logic of path dependency, many of these characteristics persist today. However, the push for reform and opening, partly motivated by economic challenges and a crisis of legitimacy, engenered substantial transformations. New political directives shifted the sources of legitimacy, modified the extent of state penetration, and introduced free-market incentive structures. Notably, achieving economic progress typically necessitates a reduction in intrusive government interventions. A wholly closed Vietnamese media system would not only have been incompatible with these shifts but may have delegitimized the press in the eyes of the public. Other relevant factors include the forces of globalization and digitalization, which have further challenged the feasibility of maintaining a closed-off media space. Consequently, the party appears to have adjusted its media governance strategies to balance ideological goals and economic imperatives and ensure regime survival.

Since the 1980s, Singapore’s political system has not undergone as radical an ideological transformation as Vietnam’s, nor has the country experienced war or aligned itself with Marxist thought. Nonetheless, Singapore faced its own challenges in the form of insurgencies and ethnic riots throughout the twentieth century. In addition to the vulnerable geopolitical position as a small city-state, these factors seem to have cultivated an appreciation for a strong Leviathan securing stability. Utilizing illiberal laws from the colonial era, the early leaders of the PAP emphasized that the press should serve the needs of Singapore – as defined by the government – to promote economic development and nation-building (Lee 2000). However, the PAP’s social contract with Singaporean citizens to deliver economic progress necessitated a less oppressive media governance regime. Overly aggressive and blatant repression could have undermined citizens’ trust and the city’s growing status as a trade, media, and finance hub. Indeed, forceful state interventions against press organizations in 1971 sparked considerable public outcry, revealing the brute force behind the ostensibly consensual government style. The arguably diminishing level of authoritarianism from the first generation of leaders to the present strengthened these dynamics. Against this backdrop, since the mid-1970s, Singapore has retooled its media governance strategies, moving towards more nuanced approaches (George 2005).Footnote 17 Since the 1990s, the Singaporean overall strategy to media governance has not significantly changed. Instead, we argue that authorities have continuously refined their tactics and instruments to identify and deploy more effective tools. These measures include the introduction of the Info-communications Media Development Authority Act in 2016, amendments to the Films Act and the Newspaper and Printing Presses Act in 2002, and the implementation of the Broadcasting Act in 1994. With the advent of the internet and global media companies in the 1990s, the government responded with targeted regulations while increasing relying on judicial means to ensure media actors’ compliance. In sum, the cases of Vietnam and Singapore illustrate how a society’s ideological and economic foundations shape media landscapes.

Notwithstanding these distinct paths, both regimes have exhibited remarkable resilience, effectively harnessing and directing the media apparatus to serve the state’s interests. These observations suggest multiple viable approaches for configuring a media environment in non-liberal-democratic regimes. The ruling coalitions have succeeded in co-opting and exerting pressure on substantial segments of the press to conform mostly to prevailing norms and regulations. While both governments possess an array of illiberal instruments at their disposal, they demonstrate restraint in deploying their monopoly on coercive force. Singapore emphasizes subtler, indirect methods of consensus-building and informal guidance (Tey 2008) to mold media organizations into “collaborative and non-adversarial establishment institutions”. These measures effectively relegate “government-press disputes backstage” (George 2014). Despite an enduring reliance on more direct, overt, and coercive strategies, Vietnam has, as we contend, gradually converged with Singapore’s tactics since the 1980s. We base this assessment on the following four dimensions, namely, the degree of openness in the media landscape, the frequency with which the authorities deploy the most repressive instruments, the directness of government intervention, and the level of marketization.

Since the 1980s,Footnote 18 the resemblance of the two media landscapes has grown moderately in the first three aspects but considerably with respect to commercialization and, to a limited extent, privatization (refer to Fig. 1). Though the Vietnamese party-state continues to permeate journalistic spheres, these interventions remain primarily politically motivated rather than economically driven. Media enterprises must adhere to market logic, and private actors wield notably greater influence than in the past. In essence, the Vietnamese ruling coalition has progressively adopted a “Singaporean blend” of “persuasion, consent, control, and punishment” (Tey 2008). Consequently, business executives have assumed more influential roles in clandestinely censoring content for commercial considerations (Nguyen-Thu 2020). The previously static Vietnamese state-media landscape of the pre-1980s era, though admittedly oversimplified in Fig. 1, has undergone a profound transformation.

Fig. 1
figure 1

Comparative analysis of press freedom, level of repressiveness, nature of state intervention, and market dynamics: Singapore versus Vietnam. Source: Illustration by authors

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How do the similarities and differences between the two countries potentially influence (future) political outcomes? Both nations have established enduring political orders despite differing press regimes. Each system restricts oppositional thought in the media, though to varying extents. On the surface, Vietnam’s more invasive governance tools allow it to steer journalists’ work in alignment with political imperatives. The direct interventions establish a clearer demarcation between permitted and prohibited speech, with harsh penalties deterring individuals from overstepping these boundaries. Combined, these measures typically limit critical reporting in support of the opposition. This situation seemingly reduces the risk of deteriorating public opinion and destabilizing collective actions. However, a trade-off exists: the overt nature of these restrictions can foster distrust in the media, prompting citizens to seek alternative information sources. Heavy-handed political oversight may also impair the press’s ability to check corruption and gauge the prevailing public sentiments. Both factors are detrimental to the longevity of a regime. Besides, Hanoi’s strategy to achieve economic growth through market reforms required limited openness and privatization. Rigid media controls appeared anachronistic or even detrimental to this goal. With the reformation of Vietnam’s media system in recent decades, the number of news organizations has dramatically grown. This expansion of information sources occasionally results in the dissemination of critical reporting before administrative bodies can react, challenging the party’s control over narratives. Conventional academic wisdom suggests that these changes heighten the possibility of citizens’ exposure to narratives divergent from official party lines, potentially fueling political dissatisfaction and collective mobilization.

However, Singapore’s experience illustrates that a media system with diminished blatant censorship does not necessarily compromise regime stability. On the contrary, refined media governance can channel the forces of media commercialization, pluralization, and professionalization to reinforce the political system (George and Venkiteswaran 2019). These developments can bolster authoritarian resilience by promoting transparency and responsiveness. Consequently, political science should analyze the complex institutional setting and their interaction patterns with society, transcending simple binary distinctions between open and closed media governance models. For instance, do these settings encourage the co-optation of opinion leaders? And do citizens grant legitimacy to the media? Furthermore, as market-driven elements increasingly permeate the economy, governments have more avenues to enhance regime legitimacy, offsetting the diminished direct control over the information space. Singapore is a case in point, as the academic literature partly attributes its longevity to economic successes (Wong and Huang 2010). Similarly, the CPV has sought performance-based legitimacy through the Doi Moi reforms (Dung and Ho 2022). Hence, our research indicates that the connection between the level of state oversight in a media environment and a regime’s (in)stability is not linear or unidirectional.

Nevertheless, we do not imply that tuning the media governance system towards a less restrictive and more fine-tuned version comes without risks for the ruling coalition. Policy innovations could be too limited or lenient, failing to produce the envisioned effects. Even well-crafted legislation may expand the discursive space in ways that empower oppositional forces. Creating a less oppressive media environment may alter the incentive structure for journalists, emboldening them to test the boundaries of acceptable speech. The resulting release of sensitive information may subtly yet significantly influence political attitudes and gradually erode the pillars of regime support. Moreover, increased press scrutiny on corruption could backfire and inadvertently tarnish the reputation of the entire political system. These effects might be magnified during times of political or economic crisis when a more permissive media structure could become a crucial conduit for amplifying dissent.

Underlying these debates, the question that looms large is whether Singapore’s more refined, indirect policy framework will serve as a blueprint for other authoritarian regimes. These political systems are grappling with the dynamics of the digital era within a neoliberal capitalist context, marked by the global flow of goods, people, and ideas. Given the rising significance of media control in the information age, this issue is poised to be a focal point of future research. The evolving landscape of news creation and dissemination – catalysed by digitalization and technologies such as artificial intelligence – presents novel challenges. Subsequent studies could expand upon our conclusions by incorporating additional countries into the comparative analysis or by examining regulatory frameworks in other domains, such as artificial intelligence. Drawing lessons from the past, it is evident that certain hybrid and authoritarian states have adeptly responded to emerging technologies and societal ruptures. The success of Singapore may indeed offer a compelling model for other regimes. As the findings of this paper suggest, Vietnam may already be borrowing a page or two out of Singapore’s playbook.