Since the early 2020s, governments around the world have increasingly turned to regulatory frameworks to tackle online disinformation while preserving fundamental rights. Although not without flaws, these efforts demonstrate how targeted interventions can disrupt the disinformation life cycle. Australia and the United Kingdom have embedded “safety by design” principles into legislation, encouraging platforms to build user safety into their core infrastructure via different mechanisms. The UK’s Online Safety Act 2023 (OSA) mandates proactive risk planning in platform development,35 while Australia’s Online Safety Bill 2021 promotes these standards through voluntary guidance.36 This shift embeds harm prevention into the architecture of digital services. The European Union’s Digital Services Act (DSA) 2022 establishes a harmonized legal framework for digital services across the EU, with the overarching aim of creating a safer, more transparent and rights-respecting online environment for all users.37 The DSA places binding obligations on very large online platforms (VLOPs) and very large online search engines (VLOSEs) – together referred to as VLOPSEs – to identify and mitigate a range of online harms – such as illegal content, disinformation and threats to public health or democratic processes – while upholding key fundamental rights, including freedom of expression and access to information. The DSA addresses disinformation not by regulating content directly but by requiring platforms to assess and mitigate systemic risks linked to the design and functioning of their services, aiming to intercept disinformation at the pre-creation, creation and distribution points of the life cycle. VLOPSEs must evaluate how their recommender systems, monetization models and content moderation practices may facilitate the spread of both illegal content (as defined by national law) and legal but harmful content, such as health misinformation, coordinated harassment or falsehoods that undermine electoral processes or civic discourse. Regarding post-creation, VLOPSEs are required to demonstrate how they mitigate risks identified on their services, which could include deploying friction mechanisms, warning labels and source disclosures to reduce the impact of disinformation after exposure and to support more informed user decision-making. Regulations in both the EU and the UK also strengthen platform accountability at the point of content consumption. The UK’s OSA addresses disinformation through a layered approach that combines platform regulation with public empowerment – most notably via its strengthened media literacy duty. While the OSA does not directly regulate disinformation as a category, it places legal obligations on platforms to assess and mitigate risks from illegal content and content harmful to adults and empowers the regulator Ofcom to supervise compliance. The DSA is still in early implementation stage but has begun reshaping platform behaviour by formalizing systemic risk governance and increasing scrutiny of recommender systems, content ranking and advertising transparency. VLOPSEs published their first transparency reports in early 2023, followed by systemic risk assessments submitted to the European Commission in August 2023. Independent audits were submitted in August 2024.38 The DSA Transparency Database enables public access to content removal decisions and regulatory notices, strengthening civil society oversight.39 While early implementation has driven improvements such as clearer content labelling and user control over personalization, challenges remain. The DSA enhances conditions for MIL by demystifying platform systems and enabling evidence-informed engagement by educators, researchers and users. The UK’s OSA complements this approach through a statutory media literacy duty. Ofcom’s Media Literacy Strategy 2024–202740 is being implemented through research, pilot programmes and civil society partnerships aiming to improve public understanding of online harms and promote safer digital participation. This is bolstered by the UK Department for Science, Innovation and Technology’s (DSIT) strategic priority principles on safety by design,41 which guide platforms to proactively embed user protection and disinformation mitigation into service architecture. Together, these initiatives reflect a shift towards integrated regulatory ecosystems that support both systemic accountability and user empowerment.Marketplace Iterate both upstream policies (to disincentivize bad actors) and downstream protocols (to triage and respond to crises in a timely manner). This could include strengthened penalties for repeat offender accounts, changes to terms of service or platform functions, improved user controls or partnerships with high-trust media and other expert institutions. 4.6 Policy approaches to tackling disinformation Rethinking Media Literacy: A New Ecosystem Model for Information Integrity 22

Rethinking Media Literacy 2025