The Platform Question: Power, Accountability and Global South The Platform Question: Power, Accountability and Global South and how much power they can exercise over users’ online experiences. These approaches vary significantly across jurisdictions, shaped by each country’s constitutional values, political priorities, and interpretation of free expression and state power. Together, they reflect a global effort to find equilibrium between freedom, safety, and accountability in an increasingly digital world. Evolution of Platform Governance Laws The early days of the internet in the 1990s and early 2000s were marked by optimism and experimentation. The internet’s strength lay in its openness. Anyone could publish, share, or build without needing permission. Regulators were therefore cautious not to impose rules that might slow innovation or discourage investment. The guiding principle of the time was simple i.e. let the internet grow first, regulate later. This approach led to what came to be known as “light-touch regulation.” The idea was to give online intermediaries i.e. internet service providers, web hosts, and later, social media companies, freedom from liability for the content their users created or shared. Governments recognized that holding platforms legally responsible for every user post would make the internet unmanageable and risk stifling free expression. Instead, the focus was on protecting these intermediaries so that speech could flow freely. While these platforms helped democratize access to information, they also exposed the risks of mass manipulation, surveillance, and disinformation. 18 The consequences of platform power soon became evident, particularly during the Arab Spring in 2011, when social media platforms became central to civic mobilization and political change across the Middle East and North Africa.[3] Platforms like Facebook and Twitter were hailed as instruments of empowerment for enabling citizens to organize protests, document state violence, and challenge authoritarian regimes. Yet, while these platforms helped democratize access to information, they also exposed the risks of mass manipulation, surveillance, and disinformation. Governments also felt the need to control platforms from amplifying content critical of the government or state. In Myanmar, Facebook was accused Platform Regulations Across the Globe of facilitating hate speech and incitement that contributed to violence against the Rohingya community.[4] Similarly, in 2019 during the Christchurch mosque attack in New Zealand, the perpetrator broadcasted the attack on Facebook Live, and the video spread rapidly across major platforms before it could be removed, highlighting the failure of content moderation systems and the viral nature of harmful content.[5] Across these incidents, a common pattern emerged: digital platforms had evolved from being neutral spaces of expression to intermediaries capable of shaping political realities, amplifying extremism, and tested limits of regulatory inaction. What began as a tool of empowerment had also become a medium of manipulation and harm and often amplified existing inequalities. Self regulation approaches by platforms were clearly failing. Governments and civil society began questioning whether the “freedom to innovate” had come at too high a cost. Debates around data privacy, content moderation, algorithmic bias, and corporate accountability grew louder, pushing policymakers to reconsider the adequacy of the early regulatory model. This shift marked the beginning of a new era of platform governance, where platforms were pressured to take responsibility for harmful and illegal content circulating online. Global Comparison of Governance Laws 1.United States The United States’ framework for regulating digital platforms is deeply rooted in its constitutional commitment to free speech and its long-standing philosophy of limited government intervention in matters of expression.[6] This foundational belief has shaped one of the most influential legal doctrines governing the internet i.e. Section 230 of the Communications Decency Act (CDA), 1996. Section 230, often described as the “First Amendment of the Internet,” provides broad immunity to online platforms by treating them as intermediaries rather than publishers of third-party content.[7] This means that platforms are not legally responsible for what users post. Section 230(c)(1) explicitly states that “no provider or user of an interactive computer service shall be treated as the publisher Platform Regulations Across the Globe Governments and civil society began questioning whether the “freedom to innovate” had come at too high a cost. 19