Author: Prakhar Shankar
Abstract
This paper presents a comparative analysis of emerging global governance frameworks for algorithmic media systems, examining how different jurisdictions are addressing the challenges of platform power, algorithmic transparency, and democratic accountability. The study critically evaluates four major regulatory instruments: the European Union’s Digital Services Act (Regulation 2022/2065) and AI Act (Regulation 2024/1689), India’s Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules 2021, Brazil’s proposed regulatory framework, and Australia’s News Media Bargaining Code. Drawing on regulatory theory, platform governance scholarship, and democratic theory, the paper identifies three fundamental tensions animating global platform regulation: (a) the tension between algorithmic transparency and proprietary business interests; (b) the tension between content governance and freedom of expression; and (c) the tension between national sovereignty and the transnational character of platform operations. Through systematic documentary analysis of legislative texts, regulatory guidance documents, and compliance reports, supplemented by synthesis of recent academic literature, the paper evaluates the effectiveness of existing frameworks in achieving their stated objectives. The analysis reveals significant regulatory divergence across jurisdictions, with the EU pursuing a comprehensive risk-based approach, India combining intermediary liability reform with government content oversight powers, and Australia pioneering a revenue-sharing model addressing the economic dimensions of platform power. The paper argues that effective algorithmic accountability requires a multi-layered governance architecture combining mandatory transparency obligations, independent algorithmic auditing, participatory governance mechanisms, and international regulatory coordination. The study concludes by proposing a normative framework for algorithmic accountability grounded in principles of transparency, contestability, proportionality, and democratic legitimacy, with specific recommendations for policy development in the Global South context.
Keywords: platform regulation, algorithmic accountability, Digital Services Act, AI Act, content moderation, platform governance, regulatory theory, comparative media law.
