The Platform Question: Power, Accountability and Global South The Platform Question: Power, Accountability and Global South Section 79 of the IT Act and lead to arbitrary censorship. If passed, the Bill could set a troubling precedent by expanding government power over online speech and increasing the liability of digital platforms. 5. China 4. Brazil In Brazil, platforms are governed under the Marco Civil da Internet, also known as Brazilian Civil Rights Framework for the Internet (“BCRFI”). As per the BCRFI, platforms will incur civil liability if they do not remove unlawful content (generated by users) after a specific order from the courts. Under exceptional circumstances, platforms will be required to remove content that invades a person’s privacy by disseminating nonconsensual intimate images (“NCII”) once the user reports the same to the platform. In cases involving child pornography, platforms might face criminal liability if they fail to remove such content upon the receipt of notice. The executive arm does not have powers to issue content takedown orders to social media platforms. [16] Platforms may bear a greater burden to prove they acted diligently in removing infringing or harmful content. Platforms must establish selfregulation systems with notice and appeal mechanisms, publish transparency reports, create userfriendly complaint channels, and appoint local legal representatives. 24 passive, court-order-dependent model toward one of shared responsibility, where platforms must act with greater care and transparency. In June 2025, Brazil’s Supreme Federal Court (STF) significantly changed the platform governance framework under the Marco Civil da Internet.[17] The court partially struck down Article 19, which had previously shielded platforms from civil liability for user-generated content unless they failed to comply with a specific court order. The Court held that platforms can be held liable for serious offences such as hate speech, terrorism, child sexual abuse, and gender-based violence even without a prior judicial order.[18] The ruling emphasized that platforms will have to bear presumption of liability in cases involving paid promotion or automated dissemination (e.g., bots). In such situations, platforms may bear a greater burden to prove they acted diligently in removing infringing or harmful content. Platforms must establish self-regulation systems with notice and appeal mechanisms, publish transparency reports, create user-friendly complaint channels, and appoint local legal representatives in Brazil with authority to respond to judicial and administrative proceedings. In essence, the STF’s ruling marks a turning point in Brazil’s digital governance. It moves the country away from a Platform Regulations Across the Globe Analysts often describe three major approaches to internet governance — the U.S. model of minimal regulation, the European model of balanced regulation, and the Chinese model of strong state control. While this may oversimplify global differences, China does stand out for its unique combination of domestic tech power and governmentdriven content regulation. The Chinese government takes a proactive role in regulating both platforms themselves and the content hosted on them. Regulations such as the 2020 Provisions on Ecological Governance of Network Information Content require platforms to remove harmful material, undergo compliance inspections, and regularly report on content moderation practices.[19] China has long maintained tight control over its digital ecosystem, with strict censorship laws that demand platforms comply with the Great Firewall—a vast system of surveillance and content regulation.[20] Global platforms like Google and Facebook have exited China due to the impossibility of operating within China’s strict censorship regime while adhering to international norms on free speech. Platforms that operate within China, like WeChat, supposedly censor and surveil texts shared within the platform. Platforms also need to train personnel to conduct human reviews of uploaded content. If they do not fulfill their monitoring responsibilities, they risk consequences like warnings, fines, service suspension, and the cancellation of permits or licenses for conducting business.[21] Conclusion Across jurisdictions, the governance of digital platforms reveals one central truth, the struggle to balance freedom, accountability, and safety in the digital age is far from settled. Each country’s approach is a reflection of its political philosophy, social priorities, and constitutional values. The United States continues to champion free expression and innovation, Platform Regulations Across the Globe Global platforms like Google and Facebook have exited China due to the impossibility of operating within China’s strict censorship regime while adhering to international norms on free speech. 25