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When journalists covering pro-democracy demonstrations in Hong Kong on September 28, 2014, got word that protesters were having problems with cell phone service, it appeared to be a familiar response from governments across the world to dissent.

After a Hong Kong radio station reported that police were threatening to shut down mobile networks altogether, the news hit social media, and protesters began sharing links to apps that create a mesh network with the use of Bluetooth and radio frequencies and can function independently of telecommunications towers.

International headlines the following week described the territory’s “Internet shutdown,” summoning the specter of a tactic aimed at limiting the ability of protesters to communicate with each other and the public.

Table of Contents Attacks on the Press book cover

There was some justification for those concerns. Bandwidth invariably falters during mass uprisings because of the number of people sharing information to coordinate protests, but authorities from Cairo to San Francisco have intentionally shut down cell phone and Internet service as a supposed security measure during demonstrations. In Hong Kong, the possibility of an intentional interruption struck a particular nerve because interference with mobile and Internet services is a tactic used by censors in mainland China.

In the summer of 2013, telecommunications networks in part of China’s Xinjinag Uighur Autonomous Region were severed for several weeks and the communications app Weixin disabled to suppress news reports of a clash between security forces and Muslim protesters, according to The New York Times. Residents and observers feared that Chinese censorship had finally caught up with the special administrative region of Hong Kong.

In fact, the supposed Hong Kong Internet shutdown never materialized. Such a drastic intervention is unlikely there because telecommunications are an integral part of the highly developed urban infrastructure, and a comparatively strong rule of law helps protects digital media from blunt censorship.

As the pro-democracy news website InMediaHK reported on October 1, 2014, in a state of emergency two Hong Kong ordinances grant the chief executive power to seize control of telecommunications stations, but only by serving a warrant to the heads of several network operators in a competitive market.

“One can imagine the huge impact should … a warrant be issued,” wrote Oiwan Lam, a voluntary editor for the site, in an interview with legislative councillor Charles Mok translated by Global Voices. Network providers must satisfy consumers accustomed to the world’s second-fastest Internet speeds, as measured by Akamai, and those consumers are part of a significant financial sector that includes many supporters of Beijing. In other words, economic influence protects the telecommunications infrastructure for everyone.

That is the good news for Hong Kong. The bad news is, the actual threat there is more insidious. Commercial institutions may help sustain journalists’ access to the Internet, but the same institutions can also erode media outlets’ independence or marginalize their reporting online, acting as a check on press freedom even as freedom of expression appears to flourish. As tensions between democracy advocates and Beijing loyalists continue to mount in Hong Kong, this dynamic is of growing concern.

“Pro-democracy online news outlets are under huge pressure,” Lam observed in an email in November 2014, adding that unless founders have the support of someone in the government or business sector–which undermines their independence–“the commercial model is a dead end.” InMediaHK is supported by foundations and local donors. A team of volunteers gets by on a shoestring budget thanks to in-kind contributions of such items as office furniture. “The cash flow is relatively small,” Lam noted.

In July, another Web outlet, The House News, closed its doors after two years of curating news and blog posts for an estimated 300,000 unique daily visitors. Mok, an IT entrepreneur as well as a legislative councillor, wrote a public response to the news: “You believed there could be a Huffington Post of Hong Kong, an online media with its own independent voice and sustainable in its own right.”

That concept, however, was not sustainable, House News co-founder Tony Tsoi added. “Some people asked me if any of our clients withdrew their ads,” he wrote in a farewell post, translated by Global Voices. “My answer is no. They never advertise on our site in the first place.”

Apple Daily, Hong Kong’s flagship pro-democracy tabloid, published by the Next Media group, weathered a discriminatory advertising market for years, thanks in part to founder Jimmy Lai’s personal fortune; he invested $100 million to launch the paper in 1995. The company adapted to the digital market with its Taiwan-based subsidiary Next Media Animation, which produces satirical news videos, and Lai embraced digital operations, driving traffic to his Hong Kong website up to 20 million page views per day, according to The Sydney Morning Herald.

Coverage of intensifying political tensions during 2014 appeared to have brought pressure on the outlet to a head. Lai was threatened in 2013, and accused of corruption on the basis of documents leaked after an apparent cyberattack against an associate in 2014, according to the Guardian. On December 12, 2014, he resigned as Apple Daily‘s publisher after police clearing the city’s Central district of protesters briefly detained him, along with around 250 of the democracy movement’s other holdouts, according to Reuters.

Meanwhile, despite surging popularity online, Apple Daily‘s financial standing looks increasingly precarious. Two banks, HSBC and Standard Chartered, discontinued a long-standing advertising relationship with Next Media in 2014,leaving the company short more than $3 million in revenue, according to The Wall Street Journal.

The unfriendly advertising market may reflect China’s growing influence, but it is a challenge faced by online news outlets around Southeast Asia. The Internet offers freedom from traditional media controls, and journalists have successfully embraced the new medium to diversify the information environment–but they remain outside the financial mainstream. Web editors in the region are so aware of this trend that some are reversing the global norm, trying to break into a print market that their counterparts in the U.S. and Europe are finding increasingly unprofitable.

Malaysia’s 13-year-old online news portal Malaysiakini applied for a print license in 2010 but was rejected by the Home Ministry. Though the ministry no longer requires news outlets to renew their licenses annually, it retains sole discretion over the licensing process–power it has historically used to silence critical journalists. Appeals courts declared the ministry’s rejection of Malaysiakini‘sapplication unconstitutional, yet the ministry again rejected the license application in October 2014, according to local news reports. Separately, in Myanmar, the formerly exile-run weekly The Irrawaddy has gone in and out of print over the past two decades but has used its Web presence to maintain its reputation for independent reporting.

In 2014, after The Irrawaddy launched a Myanmar-language print edition from Yangon, Myanmar’s Ministry of Information began pressuring the publication to change its name, saying that it had approved the paper’s registration under the recognized brand by mistake. Newly launched publications in Myanmar rely on state-owned papers with wide distributions to advertise their content to the wider readership that they established under the junta’s official sanction. Yet those advertisements are watered down before publication, with mentions of human rights and corruption investigations removed, The Irrawaddy reports. More information is available since such publications launched, but authorities seem determined to limit their audience.

Irrawaddy editor Aung Zaw, who was awarded CPJ’s International Press Freedom Award in 2014, has operated from exile in Thailand for two decades, and his news organization was branded an “enemy of the state” by the former military regime. In 2014, Zaw warned in an editorial, “Burma’s vaunted media reforms are not as promising as they may seem. We expect the pressure to grow.” The government began releasing imprisoned journalists in 2011 and lifted print and online media censorship in 2012 but has yet to abolish punitive laws that inhibit free expression. In 2014, for the first time since the amnesty, at least 10 journalists were jailed.

Though Myanmar and China serve as cautionary tales, the model of media pressure most pertinent to Hong Kong may be that of Singapore, which has maintained tight control of the media despite the Internet’s revolutionary potential and which, unlike China, has avoided technical censorship through website blocking or the deliberate slowing or interruption of service. Approximately 73 percent of Singapore 5.5 million population enjoys high-quality Internet access, compared with 74 percent of Hong Kong’s 7 million residents, according to the International Telecommunication Union. “They both have a privately owned press, with self-censorship being the main day-to-day form of control,” Cherian George, a media scholar and former journalist from Singapore who recently joined Hong Kong Baptist University, wrote in an email.

Singapore has adapted media regulation to the Web. In May 2013, the government introduced a new licensing scheme for news portals that report local news and are viewed from at least 50,000 unique local IP addresses per month. The licensee is required to take down “illegal” content on request or lose a $40,000 bond based on terms outlined in the Broadcasting Act. Though multiple blogs and online platforms meet the conditions to require such a license, the government enforced the rule selectively through notifications to individual websites, and just 10 were affected–but they included Yahoo! News Singapore, one of the few major news platforms without government-linked management. The new license appeared to have been designed to extend government regulation to Yahoo!, signaling officials’ intent to minimize the Internet’s ability to disrupt traditional media controls. Yahoo! cooperated with the changes, though Alan Soon, managing editor for Southeast Asia, described them as “redundant.”

Since then, three separate digital startups founded by veteran journalists have been instructed to register for licensing under a 2013 amendment to the Broadcasting Act, a process that requires them to submit the names of all staff and donors and bars them from receiving foreign funding, according to local news reports and Human Rights Watch. The notifications to register–which were not publicly disclosed by the government–extended existing regulations to new sites that had yet to reach the legal benchmark of 50,000 visitors: The Independent Singapore, which was contacted by the government in July 2013; The Breakfast Network, contactedin December 2013; and The Mothership, contacted in March 2014. A fourth, more established website, The Online Citizen, was similarly notified in September 2014, despite being pressured to register as a political association, which limits investment from abroad, in 2011.

Both Malaysiakini and The Irrawaddy relied heavily on support from overseas foundations in the past, and InMediaHK gets 30 percent of its resources from social-development foundations, according to Lam, its volunteer editor. Singapore’s regulator, the Media Development Authority, appears to be aware of this trend. Responding to a statement by local nongovernmental organization Maruah, which criticized the expanding registration requirements, the Media Development Authority at once rebutted and, ironically, acknowledged its intent to stymie digital news reporting. “While it is convenient to blame MDA’s registration requirement for causing online commercial enterprises to be unviable, it is also true that many online sites struggle to be commercially viable in the first place,” the response said, according to The Online Citizen.

The Breakfast Network declined to comply with the requirement and shut down its operations, though it still posts content to its Facebook page. “The demand to register or else has created a wrinkle in our barely-formed plans to become a sustainable and professional outfit,” founder Bertha Henson wrote when she announced her decision not to register her largely pro bono staff according to the MDA’s requirements. “People have asked us about our shareholders. There is really just one: me. … I should carry the risk on my own, because everyone, even the Media Development Authority, knows that getting online advertising is tough.”

Although Henson’s reluctant farewell is similar in tone to the one Tony Tsoi would write in Hong Kong a few months later, the restrictions in Singapore are far more extreme, according to Cherian George, who left Singapore after his reputation for outspoken commentary caused his employer, Nanyang Technological University, to block him from obtaining tenure until his contract expired. “What’s happening in Hong Kong is a globally more familiar problem, that of taming the media by exploiting their soft spot–their owners’ other business interests,” George wrote by email from Hong Kong. “In Singapore, licensing means that even if you find a way to insulate yourself from the government’s economic pressures, it can just ban you from publishing.” The licensing protects what George describes as the media duopoly, made up of government-owned MediaCorp, which dominates broadcasting, and government-leaning Singapore Press Holdings, which has a virtual monopoly on newspapers. “By law, newspaper companies must accept government nominees to its board of directors,” George added.

Yet Singapore’s media environment could still be instructive for journalists in Hong Kong, and not because of resemblances with their own city but, instead, because it represents an alternative manifestation of the Chinese Communist Party’s approach to information control. Before China became the global power most likely to be cited by authorities wishing to implement effective media restrictions, that role was played by Singapore, according to a 2003 analysis by Foreign Policy.

China first allowed private Internet accounts in 1995 and launched the technological Internet-filtering project known as the Golden Shield in 1998, according to CPJ research. What happened in between was a trip to Singapore made by the head of the Chinese propaganda department, Ding Guan’gen. After his return, the propaganda department instructed all cadres to study an internal document detailing Singapore’s successes, the South China Morning Post reported.

Singapore itself soon abandoned the technical model of filtering that Chinese authorities embraced and embellished. By 2005, tests conducted by the OpenNet Initiative found website blocks in the city-state to be so minimal as to be largely symbolic, despite a technical infrastructure that would enable much broader controls. Yet legal and economic restrictions on media freedom have not changed. The Broadcasting (Class License) Notification under the Broadcasting Act, which was updated in 2013 to pressure a new generation of online outlets, was first passed in July 1996.

Although China maintains a uniquely elaborate censorship apparatus, the way in which it is implemented still merits comparison with Singapore, where news and opinion become a threat only when they have momentum from foreign foundations or the influence of 50,000 local readers. In September 2013, a judicial interpretation issued by China’s top legal authorities outlined specific conditions for prosecuting illegal content online, including information that is viewed more than 5,000 times or reposted more than 500 times, according to Human Rights Watch. The interpretation has precipitated the detention of members of the business elite with millions of followers on social media, including venture capitalist Charles Xue. Independent, antigovernment views proliferate online in both China and Singapore, and neither state can stifle them all. Increasingly, it is views with a platform, and individuals and reporters who boast influence, that are targeted for censorship and reprisals.

Press freedom in Hong Kong reached new lows in 2013 and 2014, thanks to physical attacks, self-censorship, and partisanship. In many ways, journalists in the territory are squeezed between two models that pose threats of news censorship: the blunt but complex methods used on the mainland and the less overt legal and economic pressures in Southeast Asia. Hong Kong’s size and economic development will not necessarily protect it; in both models, the city of Singapore leads the way.

But Hong Kong retains a major advantage. As of late 2014 there was still room for independent media, for the same reason that hundreds of thousands of people will still take to the streets to protect fundamental rights such as universal suffrage.

“There is a healthy degree of pushback [in Hong Kong], a striking contrast with Singapore,” George observed. Civil society and press freedom groups may not be able to entirely combat the economic pressures facing online news outlets, but they have an opportunity to increase the stakes in other ways. “You can raise the political cost to owners and editors of giving in too easily to pressure,” George wrote.

The hope is that an informed, engaged public can ensure that although the price for independent reporting is rising, the payback for interrupting it is higher still.

Madeline Earp is a research analyst for Freedom House’s Freedom on the Net report, and a former senior researcher in CPJ’s Asia program.