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PDPA fines and PDPC decisions: what they tell an SME

We read every enforcement decision the Personal Data Protection Commission (PDPC) has published, from April 2016 to September 2026, and classified each one by outcome, penalty, cause and sector. Here is what the record shows, and what it means for a small business.

How PDPC cases end

A financial penalty is the most common single outcome, but most decisions end another way: a warning, directions, a voluntary undertaking, or a finding of no breach.

Financial penalty152Voluntary undertaking122Warning55Directions only37No breach found21Other outcome4

Source: PDPC enforcement decisions, read 12 October 2026.

What the penalties look like

Half of all published penalties were S$11,000 or less. Only 4 reached S$100,000, and one, a 2019 healthcare case, reached the S$1 million maximum.

  • S$11,000median penalty
  • S$30,00075th percentile
  • S$60,00090th percentile
  • 4at S$100,000 or more
Under S$10,00058S$10,000 to S$49,99971S$50,000 to S$99,99918S$100,000 or more4

152 decisions record a financial penalty; 151 publish the amount. Percentiles are nearest-rank.

Source: PDPC enforcement decisions, read 12 October 2026.

The shift to voluntary undertakings

In 2024–2026, 89 of 115 published decisions (77%) were voluntary undertakings: the organisation commits to a fix plan, and the PDPC publishes it. Before 2020 there were none.

201622201719201829201951202050202140202238202327202460202528202627

Voluntary undertakings Other outcomes

Source: PDPC enforcement decisions, read 12 October 2026.

The most common causes

Many decisions show more than one cause. 83% cite the duty to protect personal data with reasonable security arrangements.

Ransomware or malware23%A flaw in a website, app or access control19%No Data Protection Officer, policies or training15%A vendor or service provider’s lapse13%Cloud storage or a server left open to the internet9%Phishing or a taken-over account8%No security review or testing7%Weak, default or shared passwords6%Software or devices not patched, or past end of life5%Personal data published or disclosed by mistake5%

Source: PDPC enforcement decisions, read 12 October 2026.

Sectors with the most decisions

Retail and technology firms lead the record, but every sector appears in it. Sectors are named here; organisations are not.

Retail, wholesale and e-commerce61Technology and telecoms46Education and childcare34Banking, insurance and finance30Associations, charities and non-profits28Other industries26Hotels, travel, clubs and events25Logistics, transport and marine22Food and beverage19Construction, engineering and manufacturing19

Source: PDPC enforcement decisions, read 12 October 2026.

What this means for a 20-person business

  1. The likely penalty is far below the maximum: the median is S$11,000. But the decision carries your organisation’s name for good.
  2. Ransomware or malware sits behind 23% of decisions. Patched systems and backups you can restore matter most.
  3. 15% of decisions found no Data Protection Officer, policies or training: the cheapest gaps to close.
  4. A vendor’s lapse shows up in 13% of decisions. Your contracts and your checks on vendors still count.
  5. Since 2024, most cases end in a voluntary undertaking. A credible fix plan, ready fast, is your best answer to the PDPC.
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