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Singapore is often deemed to be Asia’s main tech hub and a top global alternative to the Silicon Valley. Many of the world’s major tech platforms – including GIFCT founders Facebook, Microsoft, Google and Youtube – have their headquarters for the Asia Pacific region in the Singapore. The government has been active in supporting the tech sector, advocating for an approach that promotes industry self-regulation and strong intellectual property laws.

With almost 500 million Internet users, and a history of mis- and disinformation spreading on social media and messaging apps and occasionally resulting in violence, content moderation has been a pressing issue in India for quite some time. Regulation of content is covered by different legislations under the Indian Penal Code, the Information Technology Act (ITA), and Criminal Procedure Code, and shortly under the Framework and Guideline for use of Social Media.

Terrorist use of the internet in India is mostly regulated through the criminalisation of cybercrime, covered by Section 66F of the Information Technology Act, which regulates cybercrimes and electronic commerce.

Over the last five years, Pakistan has introduced various measures aimed at regulating terrorist content online, including the 2020 Citizen Protection (Against Online Harm) Rules which directly targets content posted on social media, and the 2016 Prevention of Electronic Crimes Act which prohibits use of the internet for terrorist purposes.

These regulations supplement the Anti-Terrorism Act of 1997 (ATA) that provides the baseline legal framework for counterterrorism measures in the country. The ATA does not specifically target terrorist use of the internet, however, it considers the dissemination of digital content “which glorifies terrorists or terrorist activities” to be an offence – under section 11W. The same section also prohibits the dissemination of content that incite to hatred or “gives projection” to a terrorist actor.

Harmful and illegal online content have been regulated in Australia since the late-1990s via the Broadcasting Services Amendment (Online Services) Act of 1999, which established the legislative framework for online content regulation in the country.

Online regulation and content moderation in the United States is defined by the First Amendment right to freedom of speech and Section 230 of the Communication Decency Act 1996, which establishes a unique level of immunity from legal liability for tech platforms. It has broadly impacted the innovation of the modern Internet, causing global effects beyond the US. Recently, however, the Trump Administration administered an executive order directing independent rules-making agencies to consider regulations that narrow the scope of Section 230 and investigate companies engaging in “unfair or deceptive” content moderation practices. This shook the online regulation framework and resulted in a wave of proposed bills and Section 230 amendments from both government and civil society.

Canada’s approach to online regulation has, so far, been characterised by its support for tech sector self-regulation as opposed to government-led regulation of online content. However, concerns over foreign interference in Canadian politics and online hate speech and extremism, have led to public discussions considering the introduction of a legislation on harmful online content, and the possibility to make tech companies liable for content shared on their platforms.