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Law Library of Congress, Global Legal Research Directorate, September 2019.

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United States Government work. Public domain material.

This report is provided for reference purposes only. It does not constitute legal advice and does not represent the official opinion of the United States Government. The information provided reflects research undertaken as of the date of writing. It has not been updated.


Comparative Summary by Ruth Levush, Senior Foreign Law Specialist, Law Library of Congress, Global Legal Research Directorate

Concerns regarding the impact of viral dissemination of disinformation on democratic systems of government, on political discourse, on public trust in state institutions, and on social harmony have been expressed by many around the world. These concerns are shared by countries with advanced economies as well as those with emerging and developing economies.

The term “disinformation” as used in this report refers to “false information deliberately and often covertly spread . . . in order to influence public opinion or obscure the truth.” Disinformation for this purpose,

does not cover issues arising from the creation and dissemination online of illegal content (notably defamation, hate speech, incitement to violence) . . . , nor other forms of deliberate but not misleading distortions of facts such a [sic] satire and parody.

The use of technological tools and techniques, including bots, big data, trolling, deep-fakes, and others, enables those intending to manipulate public opinion by spreading false, inaccurate, or misleading information, to reach targeted and potentially endless audiences. The use of technology in influencing campaigns becomes harder to spot when individuals or foreign adversaries anonymously facilitate the creation of internal tensions within the country. The inability to trace sources further enables dissemination of political ads by foreign or domestic sources in violation of campaign financing rules, in countries where such rules apply.

While the dangers associated with the viral distribution of disinformation are widely recognized, the potential harm that may derive from disproportional measures to counter disinformation should not be underestimated. Unlimited governmental censorship of online communications; an expansive definition of what constitutes “disinformation”; broad application of emergency powers to block content based on grounds of national or public security; draconian penalties for alleged offenders without the ability to present an effective defense; and strict enforcement of defamation laws in the absence of journalistic defenses are just a few examples of potential threats to the principle of free speech and the administration of the rule of law posed by overreaching regulations concerning disinformation.

This report is composed of individual surveys of the European Union (EU) and fifteen selected countries from around the globe. The countries surveyed vary geographically, culturally, in their systems of government, and in their commitment to democratic principles of governance, which include protections for freedom of expression, the right to privacy, and transparency and oversight of governmental actions, among other things. The surveys were prepared by the foreign law specialists and analysts of the Law Library of Congress’s Global Legal Research Directorate based on primary and secondary sources available in the Law Library of Congress’s collections, legal databases to which it subscribes, and open sources.