Platform Accountability, Communication Governance, and Democratic Resilience: AComparative Institutional Analysis of the European Union Digital Services Act andthe United Kingdom Online Safety Act

Abstract

This article examines how contemporary platform regulation reshapes communication governance, media
institutional accountability, and democratic development through a comparative analysis of the European
Union Digital Services Act and the United Kingdom Online Safety Act. The study argues that platform
governance has become a central institutional arena in which democratic societies negotiate the relationship
between communicative freedom, algorithmic power, public trust, and social protection. Using comparative
policy analysis and socio-technical institutional analysis, the article investigates regulatory design,
institutional coordination, transparency obligations, risk-assessment mechanisms, media-system implications,
and developmental outcomes. The comparison reveals that the European Union model emphasizes systemicrisk governance, transparency, researcher access, and public accountability across very large online
platforms, whereas the United Kingdom model prioritizes harm prevention, illegal-content duties, child
protection, and regulator-led compliance through Ofcom. Both regimes represent a shift from platform selfregulation toward hybrid public-private governance, yet they diverge in their treatment of democratic
communication, public-interest journalism, algorithmic accountability, and civic participation. The findings
indicate that effective communication governance depends not only on statutory obligations but also on
institutional capacity, regulatory independence, data access, media literacy, civil-society participation, and the ability to connect platform accountability with broader democratic and developmental goals. The article
contributes to communication and media studies by theorizing platform regulation as a developmental
infrastructure of the digital public sphere.