Policy Transfer and Lesson‐Drawing in Online Harms Regulation: From NetzDG to Online Safety

Since Germany's passage of the Network Enforcement Act (NetzDG) in 2017, a growing number of countries have introduced online harms legislation requiring internet intermediaries to remove or address harmful or illegal content. Arguments about Germany's influence on other jurisdictions have relied on an undertheorized notion of policy transfer. We use a multiple streams framework to distinguish two mechanisms of policy transfer: emulation and lesson‐drawing. We then examine the policy processes behind online harms legislation in four liberal democracies (Germany, Australia, the United Kingdom, and Canada). Our findings reveal lesson‐drawing as the primary mechanism: cross‐jurisdictional influence shaped how policy problems and solutions were defined, whereas the politics stream was driven by domestic politics. Lesson‐drawing among liberal democracies should be distinguished from a form of emulation by illiberal states that we call policy camouflage . Understanding these mechanisms is critical for evaluating different approaches to online harms and internet regulation more generally. Related Article Meireles, A.V. 2024. “Digital Rights in Perspective: The Evolution of the Debate in the Internet Governance Forum.” Politics & Policy 52, no. 1: 12–32. https://doi.org/10.1111/polp.12571 . Robles, P. and Mallinson, D.J. 2023. “Catching Up with AI: Pushing Toward a Cohesive Governance Framework.” Politics & Policy 51, no. 3: 355–72. https://doi.org/10.1111/polp.12529 . Manica, L., Damásio, B. and Mendonça, S. 2026. “Institutional Legacies and Governance Models: A Comparative Study of Broadband State Aid in Europe.” Politics & Policy 53, no. 5: e70069. https://doi.org/10.1111/polp.70069 .