Anti-“fake news” legislation: A brief comparison across multiple countries

Anti-“fake news” legislation: A brief comparison across multiple countries

The introduction of the controversial Protection from Online Falsehoods and Manipulation Bill in the Singapore Parliament on 1 Apr has sparked numerous debates and discussions regarding what many media practitioners and civil rights groups have deemed to be an overreaching legislation.

Despite such criticisms and concerns, however, Prime Minister Lee Hsien Loong, has defended the Government’s rationale behind the proposed Act as recently as this week, stating that many other countries have also implemented laws aimed at curbing the spread of “fake news”.

“It is not just Singapore who is legislating this. France and Germany have done it. Australia introduced something similar and very draconian,” he said in a question-and-answer session during a joint press conference with Malaysian Prime Minister Mahathir Mohamad in Putrajaya on Tue (9 Apr).

The following table illustrates a rough comparison between Singapore’s proposed POFMA and anti-“fake news” legislation or measures drawn in the countries cited by Mr Lee, as well as the Anti-Fake News Act passed by Singapore’s closest neighbour Malaysia last year:

As seen in the table above, while France, Germany and Australia have listed specific aims in drafting and passing their respective pieces of legislation to combat disinformation, namely either to stop the spread of foreign state-sponsored campaigns during their national elections or to curb violent content and hate speech, Singapore’s proposed POFMA appears to be as comparatively broad and sweeping as Malaysia’s Anti-Fake News Act in terms of its scope, given that what constitutes as “fake news” or “false statements of fact” appear to not be very precisely defined.

How have the implemented anti-“fake news” Acts above fared so far?

Following Germany’s NetzDG implementation, Facebook said it has received 500 complaints related to over 1000 pieces of content in the second half of last year, with 63 people across three teams working on the process.

More than 30 percent of the complaints has led to the deletion or blocking of flagged content, with over two-thirds of those occurring within 24 hours.

NetzDG has received backlash mostly from far-right or alt-right political parties such as Alternative für Deutschland (AfD), citing suppression of free speech, according to independent New Zealand-based news site newsroom.

EuroNews reported that Twitter had blocked the “#Ouijevote” (#YesI’mVoting) by the French government intended at getting people to register to vote in the European Parliament elections, as the social media platform did not want to risk breaking the French law “on the fight against the manipulation of information”.

The French government’s information service (GIS), however, told AFP that “Twitter does not know how to do that (provide fair, clear and transparent information on who bought adverts), and so decided to have a completely hard-line policy, which is to cut any so-called political campaigns.”

GIS also said that it was planning to pay for its sponsored tweets, adding that such tweets are public information messages and thus should not be classified in the same category as tweets “from a political or party campaign”, according to AFP.

“It’s not that the law has backfired, it’s the host [Twitter] that has not complied with it,” added GIS.

Malaysia, however, is seeking to move in a different direction in terms of fighting “fake news” as Dr Mahathir has most recently indicated that his government will continue pushing for a repeal of its Anti-Fake News Act, which was passed by Najib Razak’s Barisan Nasional government only about a month before the General Election on 9 May last year.

Speaking to reporters at the question-and-answer session at the joint press conference on Tue, he said: “We understand how social media can be abused. For us, that means we have to learn how to handle fake news.

“When you have a law to prevent people from airing views, then we are afraid that the government itself may abuse it, as has happened in the past … We do not want any government, whether this or the next one, to abuse such laws.

“It (fake news) may be difficult to handle, but we can accept the challenge and will handle it,” stressed Dr Mahathir.

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