Legal & compliance
How Teman is described, what it may never claim, how your data is handled, and where the service stands in each market we plan to enter — written from our regulatory research, with the open questions stated as open.
Design-stage document, not legal advice. This page records the rules we hold ourselves to and the questions still open. Every position on it is scheduled for written confirmation by Singapore counsel before any public launch.
How we describe Teman
One official description — used in the app, the website, contracts and listings — so the service never drifts into claims it cannot stand behind.
The official description
Teman is an AI-guided emotional-support service for adults in Singapore. It offers conversation, guided self-help and structured check-ins, built on two curated knowledge bases and supervised by a panel of qualified counsellors.
Teman is not a healthcare service, not therapy, and not a crisis line. It does not diagnose, prescribe or treat. Its design keeps it deliberately outside clinical and medical-device territory — it produces no clinical outputs. Where a person needs professional or emergency care, Teman’s only job is to say so and hand them to humans who provide it.
This paragraph is the single source of truth for how the service describes itself.
The words we never use
- “Counselling” for what the AI does — counselling describes our human panel, never the software
- “Therapist”, “psychotherapist”, “psychologist” — for the AI, or for any person not actually registered under those titles
- “Diagnosis”, “assessment”, “screening”, “treatment”, “clinical” about the AI — these words pull a product into clinical characterisation, and disclaimers do not pull it back out
- “Clinically proven”, “reduces anxiety”, “treats depression” — no outcome claims without a defensible evidence base
- “Anonymous”, “100% private” — almost never true once data is processed; we promise precise things instead
- “Crisis service”, “suicide prevention”, “emergency care” — false, and dangerous if believed
Singapore: where Teman stands
The legal ground under the design — checked against statutes, ministry guidance and the professional code we build to.
Licensing — no category applies today
Counselling, psychology and psychotherapy are not licensable healthcare services in Singapore today: the Healthcare Services Act schedules sixteen licensable services, and no mental-health counselling service is among them. But the Act defines a “healthcare service” broadly — care of the body or mind, reward or not. We therefore design strictly on the non-clinical side of that line, and watch for any future scheduling.
AI in health — the standard regulators would reach for
MOH and HSA’s AI guidance (AIHGle 2.0, 2026) is written for licensed providers, so it does not formally bind a non-licensed service — but it is the yardstick a regulator would use. Its sharpest rule: consumer AI must not produce outputs that require clinical expertise to interpret safely, even when accompanied by disclaimers. Disclaimers never rescue a clinical design. That is why the AI here is never the therapeutic actor, and every screen says what it is.
Titles and the professions
“Counsellor” is not a protected title in Singapore; SAC registration is voluntary and has been since 2003. Psychologist titles are changing: MOH announced in May 2026 that the five subdisciplines — including counselling psychology — will be reserved for registered practitioners, with a public register to follow. Teman never uses reserved titles, for the AI or for anyone on the panel who is not registered.
The code we build to
We hold the operating design to the Singapore Association for Counselling’s Code of Ethics: truthful public statements (Section I), confidentiality bounded by the duty to protect from harm (B.4), competence and supervision (C.2–C.3) — and no fee sharing with third-party agents (A.4.3). Our panel counsellors’ registration obligations stay theirs.
And A.4.3 is now the live question, not a settled one. Sessions are booked and paid through Teman, which collects the member’s payment and remits the counsellor’s share after deducting an administration fee. That is a fee-sharing structure with a third-party agent, and A.4.3 is the clause that speaks to it. We are not going to argue the point in our own favour on a public page. It is with Singapore counsel, and the answer decides whether this model can open at all — see What is still open below. Until it is answered, treat the booking flow as a prototype, not a service.
The five rules our design follows
Not values statements — constraints with legal consequences, drawn from the jurisdictions we plan to enter.
The AI is never the therapeutic actor
Engagement, psychoeducation, triage, between-session support, crisis detection — yes. The therapeutic relationship belongs to humans. Several US states now prohibit AI from providing or advertising therapy, defining therapeutic communication to include offering emotional support in response to distress. The AI’s role here is narrower than that line, on purpose.
Scope, not disclaimers
The exemptions regulators provide are for self-help and educational resources that do not purport to offer therapy. Teman is built as support and guided self-help — content that helps you think, not a service that treats you — because a disclaimer never rescues a clinical design.
A qualified human owns every risk
Risk detection hands over to 24/7 human lines immediately, and flags the conversation. 100% of crisis-flagged conversations are reviewed by a qualified counsellor the same day. The AI never carries active risk alone — that is the design, not an escalation path.
“Counsellor” describes people
The AI is never called a counsellor, therapist or psychologist — not in copy, not in the system prompt, not in interface strings, not as a persona name. Every human described as qualified actually is, and their registration is their own.
Truthful by construction
No efficacy claims, no outcome promises, no invented supervision. What we say the service does is what it does — and where something is a design intention rather than a shipped fact, we say that too.
Why this discipline pays
Under the EU AI Act and medical-device guidance, what the maker says the product is for drives its legal class. Marketing copy is the highest-leverage decision in the file. The same discipline protects us in Singapore, the region, and everywhere after.
Money, referrals and independence
- A counsellor session is booked and paid for through Teman. Teman collects the member’s payment on the counsellor’s behalf, deducts an administration fee, and remits the balance to the counsellor
- The fee itself is the counsellor’s own, set by them within a published band (S$240–380). We do not discount it, and no part of it is set by how many people they see
- Counsellors paid for supervision and audit work receive a fixed professional fee, never linked to how many referrals they receive
- The business model is the platform — subscriptions for the AI service, plus the administration fee on sessions. It is not a margin on anyone’s clinical judgement, which is why the fee is the counsellor’s to set and why the supervision commitment above is absolute
SAC Code A.4.3 is the anchor, and it is the clause this model has to answer to: members shall not participate in fee sharing arrangements with third party agents. Collecting a member’s payment and remitting a share is exactly the structure that clause speaks to, so the honest position is that we do not yet know whether SAC-registered counsellors can join the panel on these terms. A flat per-session administration charge rather than a percentage is the structure that stands the best chance, and it is a one-constant change if the opinion comes back against a percentage. That question is with Singapore counsel — see What is still open.
Complaints and accountability
- Complaints reach a person, not a chatbot — with a published route and response times
- Anything about the quality of care goes to the panel, and where relevant, to the counsellor’s own professional body
- Panel counsellors carry their own professional indemnity cover; the platform carries its own
- Every safety incident is debriefed in the supervision cycle and feeds the audit record
Your data, under Singapore’s PDPA
Mental-health conversations are among the most sensitive data a service can hold. The obligations below are the launch architecture.
What we commit to
- Consent at signup — clear, purpose-limited, withdrawable at any time
- Improvement is opt-in — using conversations to make the system better is a separate, explicit consent, off by default
- De-identify before every model call — messages are stripped of identifying details before they reach an AI provider; the mapping that could re-identify you stays in Singapore
- Vendors in writing — model providers are contracted for retention limits and no-training defaults, verified — because their risk is our risk
- Encrypted in transit and at rest, role-based and logged access, published retention limits
- No sale, no ads — and no marketing nudges without consent; Singapore’s DNC rules apply to every reminder we send
- A breach workflow from day one — assessment and notification with a named owner and a decision log, not just a security policy
What you can ask for
- Access — a copy of your data, within statutory timelines
- Correction — anything wrong, fixed
- Export — your summaries and check-in history, yours to take
- Deletion — close your account and have conversations deleted, subject only to retention we must keep by law
- A human — data requests and complaints are answered by people
We build the data architecture once, to the strictest standard in the region (Indonesia’s GR 33/2026 sets a 72-hour breach clock and mandatory impact assessments for AI processing) — rather than four bespoke builds later.
Where we plan to operate
Regulatory posture market by market, from the October 2026 research pass. Colour = how open the door is for this design.
Singapore Home — open
First market. No licence category for counselling today; a deliberately non-clinical design; the PDPA and AI-governance foundation described on this page is built here first.
Malaysia Phase 2 — gated
The Counsellors Act 1998 gates the service of counselling for a fee, not only the title. Any AI entry must be a tool, never the counselling service itself — a structure we take to Malaysian counsel before shipping.
Indonesia Watch — data strict
The region’s strictest data bar: 72-hour breach clock, mandatory impact assessments that name AI explicitly, compliance deadline January 2027. We build to it once, globally.
Thailand Open today — window closing
No law directly controls counselling psychology today, while clinical psychology is licensed — and a 2025 petition is pushing to change that. A market to enter early or watch, not to assume.
Philippines Not an early market
The Psychology Act captures “psychological counselling … coaching” with penalties, and a separate law bars operating a guidance or counselling centre without a Board permit. Avoid until the structure allows.
US & EU Design discipline, not launch
Some US states permit emotionally supportive AI with guardrails; others prohibit AI therapy outright. The EU lets intended-purpose wording drive classification. Both reinforce rule 01: the AI is never the therapeutic actor.
Before any public launch
- Written opinion from Singapore counsel on service positioning and device classification
- Written opinion on the booking model against SAC Code A.4.3 — whether a registered member may join a panel whose fees are collected and remitted by the platform, and if so on what structure. Until it is answered, no panel counsellor is asked to rely on the arrangement
- Formal classification assessment of the AI — the question is genuinely untested for supervised AI support, and we treat it that way
- PDPA build-out: consent flows, de-identification pipeline, breach workflow, vendor terms in writing
- Complaints route and professional-indemnity cover for the panel, independent of the AI
- Crisis numbers re-verified quarterly and recorded — they are real services with real people on the line
What is still open
- Whether supervised AI support falls under Singapore’s medical-device rules — untested; the design keeps it clearly non-clinical while we get the assessment
- The current Second Schedule under the Allied Health Professions Act — psychologist title protections are announced; the timeline is not
- The legal status of “psychotherapist” as a title in Singapore — no primary source found; we simply don’t use it
- The operative edition of the SAC Code of Ethics — to be confirmed with SAC in writing before we rely on any clause contractually
- Whether a platform that collects session fees and remits a share can work with SAC-registered counsellors at all (A.4.3) — the model described under Money, referrals and independence is built on the answer being yes, and that answer is not in yet
Working document, current to October 2026 — not legal advice. Every position above is scheduled for confirmation by Singapore counsel before launch. See also Safety, supervision & limits.