The regulation of hate speech online and its enforcement - a comparative outlook

Abstract

ABSTRACT On the initiative of the British Association of Comparative Law, this issue develops a broad comparative perspective on aspects of the legal regulation of hate speech online in China, France, Germany, the UK, Europe and the US. This editorial introduces the key lines of debates running through the papers. First, contributors discuss the appropriate role of public and private actors in regulating hate speech, with extensive reference to the German NetzDG and consideration of the UK Online Safety Bill. They also consider the communicative environment in which hate speech or ‘vilification’ arises; the ‘intermediate’ regulation or restrictions that sit between inclusion and prohibition of hate speech; and the concerns about the control, or lack of control, exercised by private actors over the speech of governmental public figures. They finally remind us that different legal and political cultures ultimately shape regional approaches, even when they share apparently similar rules.