Disinformation governance and political expression: Comparative accountability gaps and an extended framework for independent oversight

This article examines three major institutional approaches to disinformation governance (self-regulation, co-regulation and state-centred regulation) and assesses their implications for the protection of political expression. Through a qualitative comparative analysis of the Digital Services Act (DSA) framework in the European Union, Meta’s Oversight Board and the Korea Internet Self-governance Organization (KISO) and South Korea’s state-led regulation, the study identifies recurring accountability gaps across models, using four analytical criteria: authority allocation, independence, transparency and contestability. These weaknesses have become more acute in an environment shaped by generative AI, the politicization of large platforms and the increasing use of disinformation by state actors. Building on prior scholarship and extending existing conceptual work on institutional independence, the article develops a refined framework for independent oversight suited to the contemporary information ecosystem. This framework aims to improve checks and balances, strengthen transparency and offer more credible opportunities for review than current arrangements allow. The findings highlight the need for renewed institutional design to safeguard democratic political expression amidst accelerating technological and political risks.