administration did not legislate to protect media freedom, end the domineering state media, close down the Orwellian Ministry of Information, or implement the Broadcasting Law and award independent channels with licenses. Myanmar’s media developed during the transitional decade despite the lack of significant regulatory reforms or human rights protections because of its ability to operate in an online space outside the offline scope of the government’s regulatory framework. For example, new national, regional, and local media outlets, many of them covering current affairs and risky issues such as corruption and discrimination, were emerging online and were not required by law to seek a license under either print or broadcast laws. The NLD administration was beginning to recognize the limitations of its jurisdiction online before the coup and was already contemplating new laws to govern the online space that would have restricted the right to freedom of expression.77 CRIMINALIZED JOURNALISM In addition to the oppressive regulatory framework, individual journalists faced significant risks from Myanmar’s harsh criminal laws, many of which flagrantly violated the rights to freedom of expression and association. These included the colonial-era Penal Code (1861) as well as specialized laws such as the Electronic Transactions Law (2004), Official Secrets Act (1923), Telecommunications Law (2013), and Unlawful Associations Act (1908). Myanmar’s criminal laws all include vague and overly broad restrictions with unnecessary and disproportionate penalties and have regularly been used to criminalize journalists conducting standard journalistic practices protected under international human rights law. Scores of journalists were sentenced to prison under both the USDP and NLD administrations.78 Many journalists perceived that legitimate journalism was increasingly criminalized under the NLD administration from 2016 to 2021.79 ‘‘ Myanmar’s criminal laws all include vague and overly broad restrictions with unnecessary and disproportionate penalties and have regularly been used to criminalize journalists conducting standard journalistic practices protected under international human rights law. 77 ICNL (2021), “Myanmar: Draft Cyber Security Law and Other Threats to Fundamental Freedoms”. 78 Committee for the Protection of Journalists (CPJ) (2023), “Myanmar archives”. 79 Multiple authors (2020), “Myanmar’s media not free or fair”. A globally notorious case was the arrest and conviction of two Myanmar journalists under the Official Secrets Act (1923). The two journalists were reporting for Reuters on the military’s atrocity crimes against the Rohingya. Assessing Detentions of Journalists in Myanmar, Feb. 2021 to Feb. 2025 28