What does this research mean for the field?

The European Union and the United States diverge significantly in their strategies for addressing information manipulation—with the EU favoring platform regulation and the U.S. prioritizing free speech—which risks weakening democratic resilience without coordinated efforts. Novelty: ClaimNovelty.INCREMENTAL. Consensus alignment: ConsensusAlignment.NEUTRAL.

What question did this study set out to answer?

The paper aims to compare the approaches of the EU and U.S. in addressing the manipulation of information as a hybrid threat.

April 18, 2026Open Access

Manipulation of information as a hybrid threat: EU and the U.S. in comparative perspective

Key Points

The paper aims to compare the approaches of the EU and U.S. in addressing the manipulation of information as a hybrid threat.
Comparative analysis of EU and U.S. strategies regarding hybrid threats
Examination of regulatory frameworks such as the DSA and DMA in the EU
Assessment of U.S. policies balancing free speech with counter-disinformation efforts
The EU adopts a regulatory approach with hard and soft law tools focusing on transparency and human rights.
The U.S. emphasizes free speech, resulting in limited government intervention against disinformation.
Divergence in strategies may weaken democratic resilience, highlighting the need for coordinated efforts.

Abstract

Abstract This paper compares how the EU and the U.S. address hybrid threats, particularly the manipulation of information as a tool to undermine democracies. Hybrid threats include tactics like cyberattacks, disinformation, and electoral interference, often by foreign or non-state actors. The EU has adopted a regulatory approach, notably through the Digital Services Act (DSA) and Digital Markets Act (DMA), which impose duties on large platforms to mitigate systemic risks and enforce transparency. It combines hard and soft law tools, emphasizing human rights and co-regulation. In contrast, the U.S. prioritizes free speech, limiting government action against disinformation due to First Amendment protections. Although federal agencies play a key role in countering foreign interference, recent shifts signal a move away from fact-checking and cyber operations. The EU and U.S. face similar adversaries but diverge significantly in their strategies. This divergence may weaken democratic resilience unless efforts are coordinated and platform accountability is strengthened across both regions.

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