Online Library

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.

The United Kingdom has set out an ambitious online regulatory framework in its Online Harms White Paper, aiming to make the UK “the safest place in the world to be online” by countering various online harms ranging from cyberbullying to terrorist content. This is yet to come into effect, but the UK has approved an interim regime to fulfil obligations under the European Union Directive, which the UK needs to comply with during Brexit negotiations. The UK also has extensive counterterrorism legislation criminalising the viewing and sharing of terrorist content online.

Germany has an extensive framework for regulating online content, particularly with regards to hate speech and violent extremist and terrorist material. Experts also note that Germany’s regulatory framework has to some extent helped set the standard for the European, and possibly global, regulatory landscape.

France is, alongside New Zealand, an initiator of the Christchurch Call to Action to eliminate terrorist and violent extremist content online. Prior to the Christchurch Call, France has elevated tackling terrorist use of the internet as a key pillar of its counterterrorism policy,[1] supporting the EU proposal on Preventing the Dissemination of Terrorist Content Online, including the requirement for tech platforms to remove flagged terrorist content within one hour.

Morocco’s online regulatory framework consists of different laws and codes that strive to limit the spread of content than can pose a threat to the Kingdom’s “integrity, security and public order”. Central to this framework are the 2003 Anti-Terrorism Law passed in the aftermath of the 2003 Casablanca bombings and the 2016 Press Code that lays out limitations journalisitic publications and public speech. However, the existing regulatory framework is not explicitly clear regarding implications for tech platforms and the government’s powers to filter the online space – something which has been criticised by civil society. According to Freedom House, the government also resorts to “extralegal means” to remove content that it deems “controversial or undesirable” by pressuring media outlets and online figures to delete such content.

Brazil represents a major market for online platforms. It is the leading country in terms of internet use in South America, and a key market for Facebook and WhatsApp. WhatsApp’s popularity and the online disinformation campaigns that have been coordinated on the platform are essential to understand Brazil’s approach to online regulation. The messenger app has been accused of being used “for the dissemination of fake news”, whilst critics of the “fake news” bill have said that it served as a “standard” for new regulation in the country based on the app’s existing limitations on forwarding messages and group size.