Governments are converging on a shared menu — transparency, risk management, election-specific rules, intermediary accountability, and targeted enforcement — even where their regulatory philosophies differ.
North America
US — NIST AI RMF 1.0 + GenAI Profile
Voluntary risk-management framework for trustworthy AI, with a 2024 profile for generative AI.
Relevance
Useful for audits and organizational controls; not a binding platform-democracy regime.
North America
US — HAVA & VVSG 2.0
Accessible voting systems; privacy-independent participation; usability, auditability, integrity.
Relevance
Election tech can improve access while embedding verification.
North America
US — FCC robocall enforcement
AI-generated voices in robocalls treated as unlawful; $6M fine in the Biden voice-clone case.
Relevance
Targeted election-integrity response to synthetic media.
CEE
EU — Digital Services Act
Systemic-risk regime for VLOPs; recommender transparency; non-profiling option; Commission investigative powers.
Relevance
The most developed structural framework for platform accountability.
CEE
EU — AI Act
Risk-based AI regulation; transparency for AI-generated content under Art. 50 (key obligations from Aug 2026).
Relevance
Directly relevant to deepfakes, provenance, and disclosure.
CEE
EU — Strengthened Code of Practice on Disinformation
Voluntary commitments on demonetization, political-ad transparency, research access.
Relevance
Useful soft-law layer; effectiveness evidence mixed.
Asia-Pacific
Singapore — POFMA & codes of practice
Correction directions, disabling powers, and codes for political-ad transparency and credible sources.
Relevance
Strong administrative toolkit; criticized for broad executive discretion.
Asia-Pacific
Singapore — Election rules (foreign influence & candidate deepfakes)
Restrictions on foreign online election ads; ban on manipulated content misrepresenting candidates during elections.
Relevance
Election-specific hardening against foreign influence & synthetic media.
Asia-Pacific
Taiwan — Anti-Infiltration Act
Criminalizes election-related acts funded/instructed by hostile foreign infiltration sources.
Relevance
Sovereignty-centered foreign-interference model.
Asia-Pacific
South Korea — Election Act amendment
Ban on AI-generated deepfakes in campaigns within 90 days of voting, with criminal penalties.
Relevance
Focused response to synthetic-media electoral manipulation.
Latin America & Caribbean
Brazil — PL 2630 / Fake News bill
Legislative proposal requiring platform transparency, AI-content labelling, and due-process rules for content removal; stalled by platform opposition and free-speech concerns.
Relevance
Would create the most comprehensive platform-regulation regime in the region if enacted.
Latin America & Caribbean
Mexico — INE synthetic-content criteria (2024)
Binding electoral guidance requiring parties and candidates to label AI-generated material and banning deepfakes impersonating opponents.
Relevance
Shows how an election-management body can move faster than statute on generative AI.
Latin America & Caribbean
Chile — Ley 21.096 & disinformation working group
Constitutional data-protection right (2018) plus a 2023 executive-branch working group coordinating platform, academic and press response to electoral disinformation.
Relevance
Combines rights-based data protection with a soft-law coordination model instead of speech criminalisation.
Latin America & Caribbean
Colombia — CRC digital-media guidelines & CNE electoral rules
Communications regulator (CRC) content-moderation transparency guidance; National Electoral Council rules on online political advertising and disclosure.
Relevance
Regulator-led transparency model rather than a single omnibus statute.
Sub-Saharan Africa
Kenya — Computer Misuse and Cybercrimes Act 2018 (amended 2021)
Criminalises false publication, cyber-harassment and fake news; amended to narrow scope after court challenges.
Relevance
Illustrates the tension between election-integrity goals and overbroad speech restrictions that chill dissent.
Sub-Saharan Africa
Nigeria — Electoral Act 2022 (social media provisions)
Regulates online political advertising and requires disclosure of sponsors; complemented by independent fact-checking coalitions (Dubawa, Africa Check).
Relevance
Hybrid model: statutory rules on ads plus civic verification infrastructure rather than top-down removal.
Sub-Saharan Africa
South Africa — POPIA & Films and Publications Amendment Act
POPIA (2020) enforces data-protection rights against platforms; the 2019 Films and Publications amendments create offences for non-consensual intimate imagery and 'harmful' online content.
Relevance
One of the region's most developed rights-based frameworks; enforcement capacity remains the constraint.
Sub-Saharan Africa
Ghana — Cybersecurity Act 2020 & NCA election guidelines
Establishes the Cyber Security Authority, mandates critical-information-infrastructure protection, and pairs with National Communications Authority guidance on election-period platform conduct.
Relevance
Institutional-capacity approach: build a regulator first, then layer election-specific rules on top.
MENA
Tunisia — Decree 54 on cybercrime (2022)
Criminalises the creation and spread of 'false news' with up to five years in prison; applied against journalists, activists and opposition figures.
Relevance
Demonstrates how counter-disinformation laws can be repurposed to suppress civic discourse.
MENA
UAE — National AI Strategy 2031 & Federal Decree-Law 34/2021
State-led AI industrial strategy paired with a cybercrimes law that criminalises 'rumours' and content 'harmful to public order', with penalties up to life imprisonment for some offences.
Relevance
Illustrates a state-capacity model that pairs heavy AI investment with tight speech control — the inverse of the EU's rights-based framing.
MENA
Jordan — Cybercrimes Law 2023
Broadly criminalises online 'false news', 'contempt of religion' and content 'undermining national unity', with prison terms and platform-blocking powers.
Relevance
A recent regional example of the counter-disinformation frame being used to narrow civic space; drew criticism from UN Special Rapporteurs.
MENA
Morocco — Law 09-08 on personal data & 2020 draft social-media bill
One of the region's earliest data-protection regimes (CNDP regulator) alongside a controversial (later shelved) 2020 draft criminalising 'fake news' on social media.
Relevance
Shows the tension between a functioning data-protection authority and periodic legislative attempts to restrict online speech.
CEE
Estonia — i-Voting legal framework & 2023 Riigikogu review
Statutory basis for internet voting in Riigikogu Election Act; independent audit and source-code publication after the 2023 election where >50% of ballots were cast online.
Relevance
Most mature legal-technical framework for binding online voting in a democracy.
CEE
Poland — Electoral Code amendments & KRRiT digital oversight
2023–24 amendments require online political-ad disclosure; the KRRiT broadcasting regulator has expanded remit over on-demand and platform content, alongside the National Cybersecurity Strategy 2019–24.
Relevance
Post-2023 government has pushed reforms to align with the EU DSA and rebuild public-media independence.
CEE
Ukraine — Diia framework & Centre for Countering Disinformation
Law on Public Electronic Services underpins the Diia app; a National Security and Defence Council body coordinates wartime rapid response to Russian influence operations.
Relevance
Live example of digital public infrastructure and information defence operating under wartime conditions.
CEE
Romania — AEP & CNA rules on online political ads (post-2024 annulment)
After the Constitutional Court annulled the 2024 presidential first round over undisclosed TikTok campaign spending, the Permanent Electoral Authority (AEP) and audiovisual regulator (CNA) tightened rules on online political advertising and platform reporting.
Relevance
First EU case where an election was annulled over social-media manipulation — a stress test for DSA enforcement.
North America
US — NIST AI RMF 1.0 + GenAI Profile
Voluntary risk-management framework for trustworthy AI, with a 2024 profile for generative AI.
Relevance
Useful for audits and organizational controls; not a binding platform-democracy regime.
North America
US — HAVA & VVSG 2.0
Accessible voting systems; privacy-independent participation; usability, auditability, integrity.
Relevance
Election tech can improve access while embedding verification.
North America
US — FCC robocall enforcement
AI-generated voices in robocalls treated as unlawful; $6M fine in the Biden voice-clone case.
Relevance
Targeted election-integrity response to synthetic media.
CEE
EU — Digital Services Act
Systemic-risk regime for VLOPs; recommender transparency; non-profiling option; Commission investigative powers.
Relevance
The most developed structural framework for platform accountability.
CEE
EU — AI Act
Risk-based AI regulation; transparency for AI-generated content under Art. 50 (key obligations from Aug 2026).
Relevance
Directly relevant to deepfakes, provenance, and disclosure.
CEE
EU — Strengthened Code of Practice on Disinformation
Voluntary commitments on demonetization, political-ad transparency, research access.
Relevance
Useful soft-law layer; effectiveness evidence mixed.
Asia-Pacific
Singapore — POFMA & codes of practice
Correction directions, disabling powers, and codes for political-ad transparency and credible sources.
Relevance
Strong administrative toolkit; criticized for broad executive discretion.
Asia-Pacific
Singapore — Election rules (foreign influence & candidate deepfakes)
Restrictions on foreign online election ads; ban on manipulated content misrepresenting candidates during elections.
Relevance
Election-specific hardening against foreign influence & synthetic media.
Asia-Pacific
Taiwan — Anti-Infiltration Act
Criminalizes election-related acts funded/instructed by hostile foreign infiltration sources.
Relevance
Sovereignty-centered foreign-interference model.
Asia-Pacific
South Korea — Election Act amendment
Ban on AI-generated deepfakes in campaigns within 90 days of voting, with criminal penalties.
Relevance
Focused response to synthetic-media electoral manipulation.
Latin America & Caribbean
Brazil — PL 2630 / Fake News bill
Legislative proposal requiring platform transparency, AI-content labelling, and due-process rules for content removal; stalled by platform opposition and free-speech concerns.
Relevance
Would create the most comprehensive platform-regulation regime in the region if enacted.
Latin America & Caribbean
Mexico — INE synthetic-content criteria (2024)
Binding electoral guidance requiring parties and candidates to label AI-generated material and banning deepfakes impersonating opponents.
Relevance
Shows how an election-management body can move faster than statute on generative AI.
Latin America & Caribbean
Chile — Ley 21.096 & disinformation working group
Constitutional data-protection right (2018) plus a 2023 executive-branch working group coordinating platform, academic and press response to electoral disinformation.
Relevance
Combines rights-based data protection with a soft-law coordination model instead of speech criminalisation.
Latin America & Caribbean
Colombia — CRC digital-media guidelines & CNE electoral rules
Communications regulator (CRC) content-moderation transparency guidance; National Electoral Council rules on online political advertising and disclosure.
Relevance
Regulator-led transparency model rather than a single omnibus statute.
Sub-Saharan Africa
Kenya — Computer Misuse and Cybercrimes Act 2018 (amended 2021)
Criminalises false publication, cyber-harassment and fake news; amended to narrow scope after court challenges.
Relevance
Illustrates the tension between election-integrity goals and overbroad speech restrictions that chill dissent.
Sub-Saharan Africa
Nigeria — Electoral Act 2022 (social media provisions)
Regulates online political advertising and requires disclosure of sponsors; complemented by independent fact-checking coalitions (Dubawa, Africa Check).
Relevance
Hybrid model: statutory rules on ads plus civic verification infrastructure rather than top-down removal.
Sub-Saharan Africa
South Africa — POPIA & Films and Publications Amendment Act
POPIA (2020) enforces data-protection rights against platforms; the 2019 Films and Publications amendments create offences for non-consensual intimate imagery and 'harmful' online content.
Relevance
One of the region's most developed rights-based frameworks; enforcement capacity remains the constraint.
Sub-Saharan Africa
Ghana — Cybersecurity Act 2020 & NCA election guidelines
Establishes the Cyber Security Authority, mandates critical-information-infrastructure protection, and pairs with National Communications Authority guidance on election-period platform conduct.
Relevance
Institutional-capacity approach: build a regulator first, then layer election-specific rules on top.
MENA
Tunisia — Decree 54 on cybercrime (2022)
Criminalises the creation and spread of 'false news' with up to five years in prison; applied against journalists, activists and opposition figures.
Relevance
Demonstrates how counter-disinformation laws can be repurposed to suppress civic discourse.
MENA
UAE — National AI Strategy 2031 & Federal Decree-Law 34/2021
State-led AI industrial strategy paired with a cybercrimes law that criminalises 'rumours' and content 'harmful to public order', with penalties up to life imprisonment for some offences.
Relevance
Illustrates a state-capacity model that pairs heavy AI investment with tight speech control — the inverse of the EU's rights-based framing.
MENA
Jordan — Cybercrimes Law 2023
Broadly criminalises online 'false news', 'contempt of religion' and content 'undermining national unity', with prison terms and platform-blocking powers.
Relevance
A recent regional example of the counter-disinformation frame being used to narrow civic space; drew criticism from UN Special Rapporteurs.
MENA
Morocco — Law 09-08 on personal data & 2020 draft social-media bill
One of the region's earliest data-protection regimes (CNDP regulator) alongside a controversial (later shelved) 2020 draft criminalising 'fake news' on social media.
Relevance
Shows the tension between a functioning data-protection authority and periodic legislative attempts to restrict online speech.
CEE
Estonia — i-Voting legal framework & 2023 Riigikogu review
Statutory basis for internet voting in Riigikogu Election Act; independent audit and source-code publication after the 2023 election where >50% of ballots were cast online.
Relevance
Most mature legal-technical framework for binding online voting in a democracy.
CEE
Poland — Electoral Code amendments & KRRiT digital oversight
2023–24 amendments require online political-ad disclosure; the KRRiT broadcasting regulator has expanded remit over on-demand and platform content, alongside the National Cybersecurity Strategy 2019–24.
Relevance
Post-2023 government has pushed reforms to align with the EU DSA and rebuild public-media independence.
CEE
Ukraine — Diia framework & Centre for Countering Disinformation
Law on Public Electronic Services underpins the Diia app; a National Security and Defence Council body coordinates wartime rapid response to Russian influence operations.
Relevance
Live example of digital public infrastructure and information defence operating under wartime conditions.
CEE
Romania — AEP & CNA rules on online political ads (post-2024 annulment)
After the Constitutional Court annulled the 2024 presidential first round over undisclosed TikTok campaign spending, the Permanent Electoral Authority (AEP) and audiovisual regulator (CNA) tightened rules on online political advertising and platform reporting.
Relevance
First EU case where an election was annulled over social-media manipulation — a stress test for DSA enforcement.