In the recently publishedReconsidering the History of South African Journalism: The Ghost of the Slave Press (Routledge, 2025), author and journalism professor Gawie Botma explores the gap in South Africa’s understanding about the complicity of its journalism in slavery.
In the United States and Britain, a few newspapers have issued apologies for their complicity in the slave trade. These include the Hartford Courant in Connecticut, considered to be the oldest continuously published publication in the US. In 2000 it apologised for its complicity in the slave trade nearly two centuries earlier.
The South African media have remained silent about their historical role in Cape slavery. Slavery in the country lasted for more than 170 years between 1652 and 1838. Precise numbers are difficult to calculate, but according to the historian, Robert Shell, approximately 63 000 enslaved people were imported to the Cape from four main areas: the rest of Africa (26.4%); India (25.9%); Indonesia (22.7%) and Madagascar (25.1%).
In 1838 around 37 000 were emancipated.
The first newspaper in the Cape colony – including parts of what are now the Western and Eastern Cape provinces – appeared in Cape Town four decades before slavery was abolished in 1838. No other publishing activities existed in what is now South Africa. The Cape, then a colony of the British Empire, was the only formal European settlement and only a few printing presses operated at scattered mission stations in the interior of southern Africa.
What I found during my research was the sobering fact that several of the owners, editors, publishers and printers of around 16 early newspapers and magazines between 1800 and 1838 were slave owners themselves
In addition, the publications they were involved with regularly published advertisements and notices to enable the slave trade as well as to recapture enslaved people who absconded.
ILLUSTRATION: An advertisement appeared in The South African Commercial Advertiser on 4 February 1824, and was repeated in Dutch in the same edition (South African Library, Cape Town)
These facts are omitted or under-emphasised in academic and popular accounts of how South African journalism was founded. Instead, the focus is often on the establishment of press freedom through the heroic efforts of a few white (British) men.
Who were the early players in the newspaper space?
British slave traders Alexander Walker and John Robertson founded the first newspaper, The Cape Town Gazette and African Advertiser/Kaapsche Stads Courant en Afrikaansche Berigter (CTG/KSC) in 1800. Acccording to historian A.C.G. Lloyd in his book The Birth of Printing in South Africa, Walker and Robertson were ‘men of many interests, who in addition to being wholesale merchants on a large scale, were slave-dealers dealing in as many as six hundred slaves in a single consignment’.
The public received their first copies on Saturday 16 August 1800. Separate, identical editions in English and Dutch were produced. Even the advertisements were translated. The format, which became a template for future newspapers, was a mixture of official government news, commercial advertising and public announcements, with snippets of international and local news.
Enslaved persons worked as assistants of the press.
Twenty-four years later the second paper, The South African Commercial Advertiser, was founded under the editorship of immigrants George Greig, Thomas Pringle and John Fairbairn. Pringle and Fairbairn displayed entrepreneurship as well as idealism about the role of the press. As part of this they rather gradually positioned themselves against slavery.
Opposition to ‘liberal’ ideas inspired the founding of De Zuid-Afrikaan in 1830. The newspaper reported in detail about slavery from the perspective of slave owners. Several prominent individuals involved with this newspaper were the owners of multiple enslaved people. These included the editor (after emancipation), Christoffel J Brand.
After he retired from the editorship in 1845, he became the first speaker of the Cape parliament in 1854 and was later awarded a British knighthood.
The printed press’s relationship with slavery
South African media historiography often cites The South African Commercial Advertiser as the first journalistic enterprise in the country. It also positions the paper as being a ‘liberal champion’ of its time. But on close inspection, this newspaper’s positioning towards slavery is much more complex.
My research shows that the paper actively contributed to the slave trade by allowing the publication of slave advertisements from the start. It continued to do so until slavery was abolished in 1838. The founding owner and editor/printer, Greig, owned at least one enslaved person.
In the telling of the history of the time, comparisons are made between the first two endeavours. On the one hand, CTG/KSC is more generally described as being an outlier as ‘a slave press’ founded by a few ‘bad apples’. The South African Commercial Advertiser is positioned as being a liberal champion of the ‘free press’ and founder of South African journalism.
Media historian Wessel de Kock in A Manner of Speaking, his book on the origins of the South African press, writes, ‘What manner of free press would have emerged from the grubby commercialism of Walker and Robertson instead of the fiery idealism of Pringle and Fairbairn remains an intriguing question’.
But should the ‘grubby commercialism’ of CTG/KSC be regarded as an outlier in the history of the early colonial press? Or did it set a trend which was followed by contemporaries and influenced the development of South African newspapers for decades and perhaps even centuries to come?
The old dictum that the press promotes the views of those who own and support it was as true during slavery and apartheid as it is now.
Past evaluations of De Zuid-Afrikaan as one-sidedly reactionary should probably also be revisited.
For one, slave ownership also existed among other English newspaper pioneers like William Bridekirk, printer and editor of several publications, including The South African Chronicle and Mercantile Advertiser, and Louis Henri Meurant, founder of The Graham’s Town Journal, the first newspaper outside Cape Town.
This too has been largely ignored in established journalism history as the focus for involvement in slavery often remained on the ‘conservative’ Cape Dutch.
The result is that a simple dualistic view of South African newspaper history has been passed down. The two poles are then seen as representative of respectively Afrikaans and English journalism as it developed in the 19th and 20th centuries.
What’s the legacy?
Some elements in the developing press in the Cape colony certainly played a role in the demise of slavery by frequently publishing government announcements, news, editorial and readers’ comments about slavery. They enabled a public debate and the development of a measure of consensus that slavery should be abolished.
Nevertheless, all the papers made compromises as they juggled interests, including political and economic factors. These decisions often worked against liberation. In that case the press was often following and not leading the momentum towards greater civic freedoms.
This was generated elsewhere, such as in the British parliament where the campaign to abolish slavery finally succeeded after decades of struggle.
The Vanishing Lifeline – Policy Solutions for Media Funding Challenges
Overview
Press freedom is a cornerstone of democracy, but it faces growing challenges in G20 countries and beyond – not only from censorship and political interference but also from media financial instability.
The 2025 World Press Freedom Index revealed the dire state of the news economy and its severe effect on editorial independence and media pluralism. According to RSF’s survey, media outlets in 160 out of 180 countries reported achieving financial stability ‘with difficulty’ or ‘not at all’.
Above all, the 2025 RSF’s Index reveals that, while not the most visible challenge facing press freedom globally, media sustainability has, over time, become a significant threat to the very survival of journalism in some parts of the world.
A shortage of adequate resources undermines journalistic independence, fosters editorial bias and creates vulnerability to the capture of media houses by business and political interests, limiting the public’s access to reliable information.
To safeguard press freedom and the right to be informed by a plurality of trustworthy sources of information, governments, civil society and media organisations must rethink how journalism is funded and sustained. This can be achieved through a combination of financial and regulatory support.
The G20 should consider the need for a coordinated response to protect press freedom globally. G20 leaders must recognise that:
free, independent and reliable journalism is essential for society and the economy to function transparently. It supports anti-corruption efforts, informed policy-making and citizen engagement, and
no crisis or challenge identified as G20 priorities – whether health, climate, economic, political or humanitarian – can be addressed without fact-based, independent information at its core. Quality information cannot be produced without journalists getting paid and media outlets generating sufficient resources
Defining the issues and why it is important in a G20 context
Media funding involves several factors and a variety of resources. On the one hand, there are traditional economic resources based on advertising and subscriptions; on the other hand, public or philanthropic financing.
Each of these funding sources faces specific challenges that affect media viability, which is defined in the Media Viability Manifesto as ‘an operational state at the business level where media organisations demonstrate their ability to produce independent journalism that serves the public good whilst also implementing feasible business operations and staying financially afloat’.
While the concept of media viability requires comprehending the broader economic environment in which media outlets operate, this paper focuses on some of the specific challenges affecting various media revenue streams, such as:
The concentration of advertising revenues for digital platforms
Tech platforms use media content to attract users and sell ads, but don’t share the resulting revenues on a fair basis. Digital giants take up to 80% of online ad revenue, leaving legacy and independent outlets with shrinking income streams.
In many regions of the world, media outlets are losing billions following the digital giants’ takeover of online advertising revenues.
The capture of advertising revenue by digital giants reinforces their dominance and diverts the financial resources needed for journalism. This puts the media’s dependence on precarious models.
Platform dominance and market power
The United Nations Global Principles for Information Integrity recognise that the current business models of dominant platforms — which are built on the attention economy — have led to a prioritisation of content designed to polarise and produce strong emotions in a bid to maximise users’ engagement and related revenue.
This has been to the detriment of quality, informative, trustworthy content on social media, making it harder for them to reach audiences organically.
Furthermore, several reports have estimated that 80% of the media’s organic online traffic comes from the services of two companies (Google and Meta) – and this flow is declining drastically due to the rise of generative AI services, which send much less traffic on to the websites from whence they scrape their content.
Market concentrationand political, or oligarchic, capture of media
The RSF Index has shown that media markets are highly concentrated in a great number of countries. In 46 of them, a majority of respondents say that the media market is highly concentrated, or entirely controlled by the State. In countries like Turkmenistan, Eritrea and Vietnam (which stand at the bottom of the 2025 ranking), where only State-owned media outlets are allowed, political control undermines editorial independence, leading to censorship, propaganda and erosion of public trust.
Furthermore, media ownership concentration reduces media plurality and often sidelines smaller, local and non-profit media organisations. This is the result of the concentration of the main media outlets in the hands of a small number of owners who use them as tools for political and economic influence
In many countries, this oligarchic capture has increased, especially as financially struggling outlets accept ownership or funding from vested interests. Combined with a lack of transparency regarding ownership and funding, it hinders new players from entering the market.
Unfair allocation of public subsidies and State advertising
The opaque and discriminatory allocation of public funding is another aggravating factor. In several countries, State advertising or media subsidies are used as a lever to favour pro-government media and punish critical media.
The unequal distribution of the advertising money favours control or manipulation by actors close to the government and economically stifles independent media. Media that are critical of government policies also face the threat of defunding, sometimes under pretexts like misinformation or national security.
Shrinking public funding for media
The succession of economic crises is forcing governments to cut spending, thereby weakening financial support for the media. This is compounded by political decisions that have collateral effects on media funding around the world, such as the current suspension of US development aid.
The Trump administration’s decision to freeze billions of dollars in global aid projects, including over $268-million allocated by Congress to support independent media and the free flow of information, has plunged many NGOs, media outlets and journalists into chaotic uncertainty.
Public broadcasters globally – like the media overseen by the US Agency for Global Media – also face budget cuts and political interference, leading to layoffs, closures and reduced coverage.
Proposals for G20 consideration
While strictly respecting press freedom, independence and pluralism, including journalistic universally-recognised self-regulatory professional ethics, G20 leaders should commit to:
Recognise and protect the added value of trusted, independent journalism for sustainable development and society at large
ensure, protect and promote a free, viable, independent and pluralistic media environment, taking robust measures to safeguard journalists, media workers and fact-checkers
include media funding in G20 communiqués and the agendas of working groups
recognise that press freedom and the right to reliable information are crucial to inform the investment strategies of public development banks, and are a prerequisite for sustainable development, and
embed journalism and media funding issues in broader G20 discussions on democracy, digital regulation and sustainable development, or create a dedicated G20 Media Engagement Group
Prioritise public funding to media that commit to upholding high editorial standards and practices
incentivise media outlets to adhere to globally recognised norms and practices of professional and ethical journalism (through higher direct funding support or forms of indirect support such as tax breaks), emphasising impartiality and independence
provide funding to self-regulatory systems whose purpose is to promote high standards and practices of professional and ethical journalism, such as the Journalism Trust Initiative (JTI, representing more than 2 000 media in 119 countries worldwide), and
ensure transparency and political neutrality in the allocation of public subsidies or State advertising
Develop policies and platform regulations to enable independent and trusted journalism to thrive in digital markets
ensure fair revenue-sharing between platforms and media outlets through the enforcement of applicable competition and/or copyright legislation
require large digital platforms to ensure the due prominence of trusted sources of information – identified as such based on robust, independent self-regulatory systems – on their services
require large digital platforms and other online intermediaries involved in programmatic advertising to adopt globally recognised norms and practices of professional and ethical journalism, such as proposed by the JTI, to enable their advertising clients to allocate spending to independent, public interest journalism. and
in addition to the compensation frameworks mentioned above, implement a digital tax on platforms with part of its revenue earmarked towards the news sector (to this end, watch out for the forthcoming M20 Summit session of the FID on digital taxes to fund quality journalism, scheduled for 1 September)
G20 members are encouraged to also take inspiration from the February 2025 provisional report of the (South African) Competition Commission’s Media and Digital Platforms Market Inquiry.
Create incentives for advertisers to uphold democratic values and to fund journalism
introduce the principle that private companies, and primarily advertising companies, have a ‘democratic responsibility’, on top of their corporate social responsibility, which should lead advertisers to align their advertising spending with the funding of public interest journalism, integrating reliability and journalistic ethics as key requirements in the placement of advertising
encourage advertisers to harness existing media industry standards that support professional and ethical journalism and help to ensure brand safety, and
require ad tech companies to establish and publish principles relating to human rights that a website, social media account or channel must adhere to before they can monetise advertising
Use Official Development Assistance (ODA) funds to resist the emergence of news deserts
recognise that ODA must incorporate support for independent journalism in fragile States as an indispensable asset for economic development and the strengthening of democratic governance
allocate a minimum of 1% of ODA, with full transparency, to offer training and capacity building in digital, information and media literacy programmes in weakened information ecosystems, and
cooperate with developing countries in nationally led efforts to build a stronger and safer environment for the exercise of independent journalism
Proposed text for inclusion in G20 outputs
For the Heads of State (‘Leaders’ declaration’)
‘We recognise the role that journalists and media play as providers of accurate, reliable and independent information, which is essential for the exercise of fundamental rights and freedoms.
‘We note the collapse in business models that support public interest journalism and are aware of the crisis of sustainability for the news media industry as being one of the main causes for the decline of press freedom globally.
‘We agree to commit to supporting efforts that sustain conditions to ensure the financial viability of journalism while ensuring that this support empowers and does not undermine editorial independence and journalistic freedom.’
For the Digital Ministers 2025 declaration
‘In the face of growing threats from mis- and disinformation, we highlight the vital role that independent and financially viable media play in providing trustworthy public-interest information. Strengthening media viability is essential to ensuring information integrity, including in the digital space.
‘We encourage digital platforms and technology companies to recognise the value of self-assessment and independent certification systems, such as the Journalism Trust Initiative, as an indicator of quality journalism and public interest information and potential partners in confronting disinformation
‘Where commercial interests would normally drive curation by online intermediaries, we acknowledge that a “due prominence” obligation is necessary to enhance the findability and visibility of public interest content that is produced with accountability and in line with professional and ethical norms.’
Acknowledgements and call for comments
This Policy Brief was commissioned within the framework of the M20 ahead of the G20 Summit.
The M20 initiative is a ‘shadow’ parallel process set up to intersect with the G20 processes. The M20 seeks to persuade the G20 network of the most powerful global economies to recognise the news media’s relevance to their concerns.
As a collaborative M20 document, this paper is a working, live document. Share your suggestions or comments for consideration to [email protected]
For more information about the G20 process, which is hosted by South Africa in 2025, visit the website here
This policy brief can be republished under Creative Commons licence, provided that you credit the source, indicate any changes to the text, and link back to the original article on the M20 site
Escalating Assaults on Journalists’ Safety are a Threat to Democracy
Overview
Attacks on journalists worldwide are a monstrosity for democracy’s existential commitment to information integrity. Solidarity is needed with the frontline fighters for information integrity. Sustainability is required so they can do their work without fear, and equality is necessary so that journalists have the right to justice and there is an end to impunity for those who violate human rights.
The M20 is an opportunity to ‘showcase’ to the G20 the increase in killings, murders, kidnappings and detentions of journalists around the world – especially in war zones such as Gaza, Sudan, Ukraine, Syria, DRC, among others. These increases have been noted this year by organisations that include the Committee to Protect Journalists (CPJ), Reporters Sans Frontières (RSF) and UNESCO.
Powering the surge in attacks is the 20-year trajectory (from 2006-2024), where 1 700 journalists were killed. The majority of these crimes – 85% – go unpunished. The second monstrous layer of the anti-democracy trajectory is online bullying of women journalists (especially black, and LGBTQI+), consisting of intimidation, harassment, doxxing and trolling, threats of rape and murder in the cyber sphere – such as on social media – which is an emotionally violent zone.
Therefore, this year’s G20 themes of solidarity, equality, and sustainability must apply directly to stop attacks on journalists. These G20 ideals cannot be realised unless journalism as a public good, which values information integrity, is fought for and protected as a treasure to democracy.
Alliances with civil society (and governments whose values align for a more peaceful and just world), and international collaboration are needed. While signing multilateral agreements on occasions like World Press Freedom Day is a valuable start, there is a pressing need to take concrete action beyond symbolic gestures
Proposal to the G20
The proposal to the G20 is to hear, discuss, acknowledge and act against the ever-increasing killing of journalists, as well as online sexual violence against women journalists.
The Rio G20 leadership declaration says: ‘Acknowledging that gender-based violence, including sexual violence against women and girls, is alarmingly high across public and private spheres, we condemn every form of discrimination against women and girls and recall our commitment to end gender-based violence, including sexual violence and combat misogyny online and offline.’
Women journalists are adversely affected by bots, trolls and politicians on platforms that are adversarial by algorithmic design and by an absence of content moderation, and which seem to contain no discussion or nuance.
They spread hatred of a sexualised nature, often spilling over into real life space, as in the case of journalists Maria Ressa and Ferial Haffajee.
In the G20 interpretation of equality, solidarity and sustainability, neither equality (for all genders), solidarity (with all those suffering from war mongers) nor sustainability (healing the planet and ending poverty) can be reached without freedom to do journalism as a public good. Therefore, journalists’ safety, protection and acknowledgment of their role in democracy should be an urgent M20/ G20 goal.
This Policy Brief argues that signed agreements must be followed through with action against perpetrators involving new levels of co-operation between civil society, governments, international and continental agencies such as the United Nations, African Union and European Union, as well as between media freedom and journalist safety networks and advocacy organisations such as the International Centre For Journalists (ICFJ), the Journalist Safety Network and SANEF.
Defining the critical issue and role of the G20 and key issues
The global state of press freedom is now classified as a ‘difficult situation’, according to the RSF 2025 report. This is the first time this has been the case in the index’s history. While one of the main reasons was due to the ‘economic factor’ – the sustainability of journalism – RSF noted that physical attacks continue.
The United States is leading the economic depression, while it is also recognised as a global leader in Silicon Valley for AI and social media apps. Similarly, online attacks – enabled by Big Tech billion-dollar profit-making companies such as Alphabet (Google’s parent company), Meta (Facebook’s parent company) and platforms like X and TikTok – operate with little to no accountability or regulation concerning journalist safety.
The situation in Palestine (163rd on the RSF index) is disastrous; in Gaza, the Israeli army has destroyed newsrooms and killed nearly 200 journalists. As of 16 June 2025, CPJ’s preliminary investigations showed at least 185 journalists and media workers were among more than tens of thousands killed in Gaza, the West Bank, Israel and Lebanon since the war began, making it the deadliest period for journalists since CPJ began gathering data in 1992.
As BBC News, Agence France-Presse (AFP), Associated Press (AP) and Reuters have noted, those reporting the conflict from Gaza now face ‘the same dire circumstances as those they are covering’. That is, engineered starvation.
This unprecedented extreme violence against journalists in conflict zones takes place against a broader assault on journalists globally. For over a decade, research has shown that women and journalists of colour are particularly targeted. Seventy percent of women journalists experienced online and offline threats, harassment, or attacks, and a third have considered leaving the profession as a result, according to a 2019 report by the International Women’s Media Foundation.
Africa: Online bullying and cybermisogyny
Women journalists in certain African countries have encountered extreme online harassment due to their journalism and/or for having a public profile, according to a study by Alana Barton (Reader in Criminology in the Department of Law and Criminology, Edge Hill University in Lancashire, UK) and Hannah Storm (award-winning journalist, producer and director).
This has not abated, with 73% of women journalists saying they experienced harassment and bullying on platforms such as X and Facebook, according to 2022 research by Julie Posetti and Nabeelah Shabbir in their study, The Chilling: Global Study of Online Violence Against Women Journalists.
The ICFJ/UNESCO study reveals that deep-dive research into attacks on journalists in African countries includes online harassment, disinformation and smear campaigns, sexist and hateful speech, as well as trolling with threats of rape and death
In some African and other countries, this occurs against the backdrop of authoritarian regimes that place the free press under attack.
Studies reveal patterns vis-à-vis the digital harassment of women journalists on the continent, including self-censoring and exiting the journalistic field. The research found that 75 percent of women journalists surveyed in Kenya experienced online harassment, particularly when covering politics and sport.
Harassment not only leads women to stop using digital tools but also to withdraw from the profession, wrote Moraa Obiria (senior gender writer at Nation Media Group in Kenya). Those who resist face being silenced further.
Globally, cyberspace reflects and amplifies harassment, sexism and other forms of discrimination against journalists, including homophobia, racism, and religious hate speech.
South Africa
In South Africa, women journalists of all races who work in the political reporting and investigative spaces have been targeted with threats of rape and murder, and trolling and doxxing. Journalists include Ferial Haffajee (Associate Editor), Tshidi Madia (political broadcast journalist) and Karyn Maughan (legal journalist).
‘Much like your casual school bully, online trolls will do everything in their power to get under your skin. They will persist despite you ignoring them […]
‘In 2018, when it became manifest that I will not succumb to social media bullying, the efforts to intimidate me became more direct and sinister. In August 2018, I was sent a picture of a gun by an ANC Women’s League leader for sending her probing questions about a meeting she attended.
‘There was an attempt to dox me — an effort to intimidate me by sharing my address — but, thankfully, the post was taken down … There were full-blown threats to rape and kill me by Zuma supporters.
‘While my employer and the South African National Editors’ Forum came to my defence, I never felt more alone in that ordeal. I knew I was not the only one facing this, and I also knew that my seniors did not know how to navigate this terrain.
‘What do you do in this instance? Do you send legal letters to thousands of bots? By this time, attacks on female political journalists in South Africa had become far, far worse.’
Journalists should not simply ‘suck it up’, says Hunter, who links mental health to safety and media freedom in the book. Her vocal advocacy for mental health awareness in journalism earned her the prestigious Nat Nakasa Award for Courageous Journalism in 2019.
Collaborations needed to enforce platform accountability
Platforms such as X and Facebook have permitted sexism in a vile fashion, and have failed to prioritise dealing with threats against women journalists. Reports of cybermisogyny on social media across the continent indicate that harassment, such as threats of rape and murder, often leads women journalists to leave social media or the industry altogether.
According to one report on women journalists and safety, there is a complete lack of accountability. South African women describe it as a free-for-all, saying they are advised to report incidents to the police – but when they do, the officers appear unfamiliar with terms like ’emotional violence’ or ‘cybermisogyny’.
It is the responsibility of traditional and Big Tech, as well as governments and civil society, to take action and effect change. Early warning systems need to be developed to monitor, predict and prevent online violence escalation
Research on cyberbullying in South Africa, as referenced in this Policy Brief, also indicates that currently, only NGOs in the civil society space and some news organisations fully recognise the importance and nature of physical violence against journalists, and are attempting to effect change.
But they cannot act alone. Governments on both the continent and globally must hold Big Tech accountable to curb unregulated online bullying. Pressure needs to be applied for companies to take coordinated action in stopping harassment, identifying offenders and ensuring they face criminal consequences.
Urgent continental, intercontinental and global collaborations are needed to tackle Big Tech companies for regulation, naming, shaming and sanctions.
Other recommendations, outlined in The Chilling, include the adoption of a more inclusive approach to recognise and call out the intersectional nature of online violence, and for law enforcement agencies to develop gender-sensitive skills to be equipped to tackle these cases.
Proposed text for inclusion in G20 output
For the Heads of State (‘Leaders’ declaration’):
‘We recognise with deep concern the unprecedented rise in physical and online assaults on journalists, and we unequivocally condemn such acts as grave violations of international law and fundamental human rights.
‘We call on governments to demand immediate protection for targeted journalists and unimpeded humanitarian access.
‘We call upon all governments to strengthen and enhance efforts to ensure the safety and protection of journalists, uphold freedom of the press, and foster an environment where media professionals can carry out their vital work without fear or intimidation, let alone being targeted in war and subjected to generalised starvation.
‘We recognise the sizeable role played by large technology and social media companies in the proliferation of online harassment, particularly targeting women journalists.
‘We call on governments to develop and implement robust regulatory frameworks that ensure accountability of digital platforms for protecting safety and human rights online, including of journalists, and empower state organs to effectively respond to online criminal acts.’
Recommendations and opportunities for G20 media
A joint campaign opportunity awaits: civil society, with progressive democratic governments, journalist organisations, and international agencies can collaborate to stop physical violence against journalists, as well as emotional online
The media need co-operation and alliances (with international agencies and national governments) to hold Big Tech accountable
Safety measures and equipment need to be provided to journalists in conflict areas and war zones, and there can be no impunity for perpetrators who fail to respect reporters as civilians
News organisations need to develop gender-awareness protocols to respond to online violence, to stop victim-blaming, and not to feel restricted or silenced in their response
Acknowledgements and call for comments
This policy brief was commissioned within the framework of the M20 ahead of the G20 Summit.
The M20 initiative is a ‘shadow’ parallel process set up to intersect with the G20 processes. The M20 seeks to persuade the G20 network of the most powerful global economies to recognise the news media’s relevance to their concerns.
As a collaborative M20 document, this paper is a working, live document. Share your suggestions or comments for consideration to [email protected]
This Policy Brief can be republished under Creative Commons licence, – i.e. provided that you credit the source, indicate any changes to the text, and link back to the original article on the M20 site.
In 2022, the European Union approved the Digital Services Act (DSA), legislation promising to protect user rights and placing a regulatory requirement on platforms to identify and mitigate risks resulting from their online services.
Crucially, the DSA stipulates that online platforms, including social media companies, must ‘give particular consideration’ to freedom of expression when deciding how to address the serious harms to society identified under this framework.
Since these platforms published their first assessments in late 2024, several challenges to this aim are becoming apparent, some derived from the ambiguity of the DSA’s key terms, others from missed opportunities to integrate global human rights standards into these assessments.
Building on the work of many organisations active in this field, the Oversight Board believes it is crucial that human rights, particularly freedom of expression, are placed at the core of systemic risk assessments.
In that spirit, this paper sets out four focus areas that could help to enhance platform accountability and improve how content is governed, as part of a consistent and effective rights-based approach:
Clarify the meaning of systemic risks. Ambiguity over this DSA term could leave the door open for overbroad interpretations, potentially incentivising restrictions on speech
Draw on global human rights standards. Fully integrate such standards across all categories of risk assessment for more consistent reporting. Mainstreaming global human rights is more effective than treating them as a standalone category
Embed stakeholder engagement into identification of risks and design of mitigations. By following the practices set out in the United Nations Guiding Principles on Business and Human Rights (UNGPs), platforms can more meaningfully show how stakeholder engagement shapes their responses to risk
Deepen analysis with data. Quantitative and qualitative data are equally valuable to reporting. Companies should more openly use appeals data supported by insights from external oversight mechanisms to show whether mitigations are effective in respecting freedom of expression and other human rights
Introduction
Recent EU regulation of online platforms introduces a new, risk-based approach to online services, focusing on how platforms may create or amplify certain types of harm. The DSA seeks to regulate social media to establish ‘harmonised rules’ for a ‘trusted online environment’ in which human rights are respected.
It requires Very Large Online Platforms (VLOPs) to disclose the steps they are taking to prevent their services from harming people and society.
The early ‘systemic risk assessments’ published by VLOPs provide insights into how platforms identify, evaluate and mitigate risks – including to human rights – arising from the design and use of their systems, as required by DSA Articles 34 and 35.
Although the DSA has the potential to enhance transparency and support human rights, the incentives it creates could also lead to excessive restrictions on freedom of expression globally.
Reconciling risk mitigation and respect for freedom of expression
Many of the risks the DSA addresses reflect the issues the Board has prioritised in its cases. For example, the DSA Recital 86 requires platforms to ‘give particular consideration to the impact on freedom of expression’ when choosing how to mitigate systemic risks.
This consideration is closely linked to the Board’s mandate, which centers on ensuring respect for freedom of expression and identifying when speech restrictions may be justified to protect other rights or interests.
Our decisions, which are binding on Meta, tackle the most challenging content moderation issues, and examine how Meta’s policies, design choices and use of automation impact people’s rights. These decisions provide insights into how to reconcile the identification and mitigation of risks on Meta’s platforms with respect for freedom of expression and other human rights
The Board emphasises that systemic risk assessments must include greater focus on respect for human rights, including freedom of expression, if they are to enhance meaningful platform accountability to users and improve content governance in line with the DSA’s objectives.
Drawing on this work and its close analysis of the first systemic risk assessments, the Board offers the following reflections.
Clarify the meaning of systemic risks
The first reports are limited by the lack of a shared understanding of what the term ‘systemic risks’ means. It is not defined in the DSA and is not rooted in global human rights law.
While the Board acknowledges the DSA’s deliberately flexible approach of allowing the meaning to develop over time, this shifts the responsibility over to platforms to thoughtfully interpret the concept.
Given this, it is understandable that platforms often default to a narrow, compliance-focused approach, which can hinder a meaningful understanding of systemic risks developing.
The result is the reduction of systemic risks analysis to a checklist exercise, as largely seen in the initial publication of platforms’ risk assessments in 2024.
Most platform reports refer only to the DSA’s listed systemic risk categories (‘illegal content’, ‘negative effects’ on ‘fundamental rights’, democratic processes, public security, ‘gender-based violence’ and the protection of minors) and its 11 mitigation measures (e.g., ‘adapting’ and ‘adjusting’ design choices and ‘recommender systems’).
Platforms are largely silent on whether their assessments identified new risks or led to the rollout of new mitigations, and do not challenge presumed connections between their platforms and specific risks. This ambiguity, in turn, may facilitate platforms missing or obfuscating new threats and emerging trends.
Incentivising speech restrictions
From a freedom of expression perspective, ambiguity over the term’s meaning may lead to overbroad interpretations and arbitrary enforcement, incentivising excessive restrictions on speech. This could stifle diverse opinions and potentially chill platforms’ commitments to providing spaces for open discourse on challenging and sensitive topics.
Consequently, this could deter users’ freedom to express themselves on these platforms. It has also the potential to undermine some of the benefits that the DSA may bring in terms of greater access to user remedy and increased transparency
The DSA treats human rights as a standalone category rather than integrating it across risk areas, leading to fragmented approaches on how platforms identify, assess and mitigate risks. This is especially problematic given the DSA’s novel standard that mitigations must be ‘reasonable, proportionate and effective’, which lacks clear implementation guidance.
By placing human rights in a standalone category, the DSA misses the opportunity to integrate human rights considerations comprehensively into systemic risk governance.
This prompts platforms to prioritise certain rights over others and discourages them from assessing how each risk area or ‘influencing factor’ may affect human rights as a whole.
Recent research from the CELE, the Argentina-based NGO, argues that the risk-based approach ‘pushes rights out [from] the centrestage of Internet governance, and may create a logic of “symbolic compliance” where [the] governance role of rights is further diminished’.
Drawing on global human rights standards could support a more consistent and rights-based approach to systemic risk reporting, helping align methodologies while ensuring a common framework for assessing impacts on rights.
This fragmented treatment becomes particularly evident in the context of freedom of expression. While standalone reporting may cover concerns about content moderation practices, account suspensions or misinformation, it often overlooks more nuanced issues
For example, it may fail to consider how other risk areas like ‘illegal content’ or ‘influencing factors’ like automated detection, recommendation algorithms or search functionalities can have systemic impacts on freedom of expression, even when these effects initially seem limited. Or, in another instance, when platforms cooperate with governments on content takedowns, it is often unclear how such requests are made, recorded or acted upon.
This lack of transparency has been a recurring issue identified in the Board’s case work, which has examined the opaque and inconsistent nature of state requests (see Shared Al Jazeera Post,UK Drill Music and Öcalan’s Isolation decisions), and their potential to suppress freedom of expression.
Platforms also rely heavily on automated systems to detect and remove content, which can, on the one hand, lead to the overenforcement of political and counter speech. On the other, reducing reliance on automation can also carry risks, with uneven consequences for different users.
The Board recently recommended that Meta examine the global implications of its decision, announced on 7 January 2025, to reduce reliance on automation for some policy areas.
Mainstream human rights
To mainstream human rights as a cross-cutting issue, platforms could benefit from greater clarity and implementation guidance on how to identify and assess risks through a rights-based framework with clear and consistent criteria.
While many platforms have developed their own approaches, they often reference a variety of frameworks in their reports, from the UNGPs to risk models from unrelated fields like finance and climate change. This leads to inconsistent evaluation of factors such as scope, scale, irremediability and likelihood of potential adverse impacts.
All this hinders the ability of stakeholders to compare risks across services, and assess industry-wide harms and limitations on users’ abilities to speak freely.
Drawing upon guidance from international treaties and the UNGPs could help ensure that efforts to identify and assess systemic risks do not unduly infringe on human rights.
The UNGPs offer a structured approach for assessing human rights impacts, emphasising stakeholder engagement, context and attention to vulnerable groups. They involve well-established guidance on evaluating the scope, scale, irremediability and likelihood of potential adverse impacts on human rights.
Using the UNGPs would enhance cross-platform comparability and ensure that risk assessments go beyond what is immediately visible or quantifiable, capturing broader and longer-term impacts embedded in platform design and operation.
Distinguish between risks and mitigation measures
To navigate these challenges, platforms also need a structured way to distinguish between prioritising risks and determining mitigation measures. A rights-based approach could help platforms apply carefully calibrated measures, rather than oversimplifying assessments based on risk prioritisation.
This approach should include an evaluation of the impacts of mitigation strategies themselves, using clear, rights-specific criteria. For example, measuring the effectiveness of content moderation would require assessing content prevalence, volume of decisions, enforcement error rates and appeal outcomes.
This would ensure that responses to risks do not generate new or disproportionate impacts, while resulting in more granular transparency and access to data to support third-party research into moderation trends.
While the DSA aims to establish a framework for evaluating mitigation measures by requiring them to be ‘reasonable, proportionate and effective’, it lacks clear implementation guidelines. As with risk identification and assessment, this leaves much to the discretion of platforms and results in the use of divergent methodologies, which can affect the quality, effectiveness and timeliness of these mitigations
Clearer guidance on how to evaluate and implement mitigation measures could be achieved by drawing on existing global frameworks for evaluating restrictions on speech: namely, the three-part test for legitimate restrictions on freedom of expression, based on Article 19 (3) of the International Covenant on Civil and Political Rights (ICCPR), and its relevance to companies under the UNGPs.
This would allow platforms to better evaluate mitigation strategies by integrating speech concerns and other legitimate aims. Another benefit would be ensuring that freedom of expression and civic discourse are not treated as a standalone ‘risk’ area, but mainstreamed as a cross-cutting issue.
Organisations that bridge the gap
Embracing existing frameworks would challenge assumptions that freedom of expression is always in tension with respect for other human rights and societal interests, and encourage innovative approaches to risk mitigation.
The Board applies this three-part test in all our cases to assess whether Meta’s speech interventions meet the requirements for legality, legitimate aim, and necessity and proportionality. This provides a transparent and replicable model for rights-based analysis that platforms can adopt in their own mitigation efforts.
A consistent global response
Systemic risk frameworks designed under regional regulatory regimes, such as the DSA, could end up shaping regulatory approaches in other regions. Therefore, it is crucial for the regulator to clarify the cross-cutting role of human rights across all risk areas and for platforms to adopt frameworks rooted in global human rights standards to ensure their systems effectively mitigate risks in regional jurisdictions, while maintaining global consistency.
As the Board’s extensive work demonstrates, relying on global standards requires consideration of local and regional contexts, both when identifying risks and designing mitigations. While harms to individual rights may manifest differently in different regions, applying a global framework can ensure that a company’s response is consistent and grounded in respect for freedom of expression.
Embed stakeholder engagement into assessments and mitigation design
Although all platforms refer to stakeholder engagement (such as civil society, academia and marginalised communities) in their reports, there is limited insight into how this input informs systemic risk assessments.
While platforms set out their consultation processes in detail, they do not clearly draw connections between the outputs of those consultations and their analysis of risk or evaluation of mitigations.
This reporting on stakeholder engagement also fails to align with the good industry practices outlined in the UNGPs. Specifically, with the lack of clarity on how engagements are structured, which stakeholders are involved and what concerns are raised, it is difficult to understand how stakeholder insights influence platforms’ responses to individual risks, before and after mitigations are applied
Meaningful stakeholder engagement should prioritise the input of individuals and groups most affected by platform decisions by actively seeking expertise and diverse perspectives.
Moreover, this type of engagement is essential for considering regional and global factors when assessing systemic risks and mitigations.
While the DSA emphasises localized risk assessment, current methodologies often fail to account for local diversity (e.g., the EU’s different languages and cultures), since platforms mainly focus on structural issues affecting their systems.
This is exacerbated by a lack of targeted stakeholder engagement, leading to risk assessments that fail to capture the complexity of local contexts.
The Board’s prioritisation of stakeholder engagement in cases and policy advisory opinions highlights how such efforts can increase transparency and participation, and amplify the voices of people and communities most impacted by platform decisions (see the ‘Shaheed’ policy advisory opinion).
Additionally, the work of expert organisations, such as the GNI and DTSP forum, underline how multi-stakeholder consultations with diverse experts can enrich both risk assessments and mitigation strategies, and help platforms align these processes with a rights-based approach.
Deepen analysis with appeals data
Since the first reports by platforms are primarily qualitative, they provide limited insight into the quantitative data used to assess risks and mitigation measures. When cited, metrics are often high level and duplicate pre-existing transparency report disclosures.
Building on the Board’s experience, one way to evaluate the effectiveness of mitigation measures, particularly on freedom of expression and other human rights, is to draw on both qualitative and quantitative assessments of user appeals data, such as on decisions to remove or restore content.
Appeals are not only a mechanism for error correction, they are also a vital safeguard for protecting free speech by revealing which enforcement practices may be suppressing lawful expression
User reports and appeals against decisions to leave content online can also highlight where enforcement practices may be failing to properly curb harmful content.
Appeals can also offer valuable insights into enforcement accuracy and residual risks. For example, data on appeals volume, geographic location, relevant policies, associated risk areas and outcomes can help determine which mitigation measures are effective over time – and which require improvement.
Receiving hundreds of thousands of appeals annually from around the world, the Board’s data could help highlight enforcement trends as potential indicators of risks, such as censorship of journalistic content, and over- or underenforcement of policies during a crisis, as well as help to evaluate the effectiveness of mitigations.
This, in turn, could supplement platforms’ own processes, contributing to independent oversight.
By systematically analysing, openly reporting and meaningfully integrating data into risk assessments, platforms will not only enhance the effectiveness of mitigation but also strengthen trust in their commitment to safeguard human rights.
Conclusion
Now the initial rounds of assessments have been published and as platforms develop their next reports, the time is right to refine methodologies to ensure that products, platform features and content moderation systems are evaluated with greater precision, depth and robustness.
A transparent and multi-stakeholder approach, bringing together diverse expertise and perspectives, is essential to support this endeavour.
It is crucial that human rights, particularly freedom of expression, are placed at the centre of systemic risk assessments to safeguard speech, rather than to serve as a mechanism for its restriction.
By drawing on its expertise, the Board is committed to help develop rights-based approaches that centrally position freedom of expression. Given the iterative nature of assessments, the Board encourages platforms to incorporate feedback and for regulators to take these insights into account when designing guidance for platforms and auditors.
The Board looks forward to working with interested organisations and experts on systemic risk assessments and mitigation.
Media capture happens when media outlets lose their independence and fall under the influence of political or financial interests. This often leads to news content that favours power instead of public accountability.
What is media capture and how has it reshaped itself in recent times?
Media capture describes how media outlets are influenced, manipulated or controlled by powerful actors – often governments or large corporations – to serve their interests. It’s an idea that helps us understand how powerful groups in society can have a negative influence on news media.
While this idea isn’t new, what has changed is how subtly and pervasively it now operates.
These groups include big technology organisations that own digital media platforms – such as X, owned by xAI (Elon Musk), and Instagram and Facebook, owned by Meta. But it’s also important to consider Google as a large search engine that shapes the news content and audience of many other platforms.
This matters because the media are important for the functioning of democratic societies. Ideally, they provide information, represent different groups and issues in society, and hold powerful actors to account.
For example, one of the key roles of the media is to provide accurate information for citizens to be able to decide how to vote in elections. Or to decide what they think about important issues. One big concern, then, is the effect of inaccurate or biased information on democracy
Or it might be that accurate information is harder to access because algorithms and platforms make it easier to access inaccurate or biased information. These can be intended and unintended consequences of the technology itself, but algorithms can amplify misinformation and fake news – especially if this content has the potential to go viral.
So, what’s particular about media capture in the global south?
This is a really interesting question that is still being investigated, but we have some ideas.
First of all, it’s useful to know that media capture scholarship from the global north emerged around the time of the 2008 financial crisis. The influence of financial institutions on business journalists was one of the first areas of study.
Since then, research in the United States has focused on the capture of government-funded media organisations like Voice of America. And on how digital platforms like Google and Facebook can lead to capture.
In the Global South, scholars have drawn attention to the importance of large media corporations in understanding media capture. For example, in Latin America, there’s a high level of what’s called ‘media concentration’. This is when many media outlets are owned by a few companies. These companies often own companies in other sectors, which means that critical reporting on business interests presents a conflict of interest.
But to focus on Africa, scholars have drawn attention to governments as a source of pressure on journalists and editors. This can be through direct pressure or what we might call ‘covert’ pressure. Withholding advertising that helps to fund media outlets is an example, or offering financial incentives to stop investigating certain topics.
Researchers are also concerned about the influence of big tech in Africa. Digital platforms like Google and Facebook can shape the news and information that citizens have access to.
Can you share some of the studies from the book?
Our book includes many interesting studies – from Colombia, Brazil and Mexico in Latin America to Ethiopia and Morocco in Africa. We’ll share a few African cases here to give an overview of the issues.
The book’s contribution on Ghana warns us that although more overt ‘old’ types of media capture may have subsided, transitional democracies can feature messier, more nuanced forms of media control. This can be evident in government pressures and through capture of regulators.
In the Morocco chapter, we see the threat to media freedom presented by digital platforms owned by global tech giants. This is known as ‘infrastructural capture’. It means news organisations become dependent on tech giants to set the rules of the game for democratic communication.
Another compelling case is Nigeria, where researchers explore ties between media ownership and political patronage. The authors argue that the Nigerian press is failing in its democratic duty because of its reliance on advertising and sponsorship income from the state.
Added to this are ineffective regulatory mechanisms and close relationships with some big businesses that own newspapers and printing presses.
How can media capture be resisted in the global south?
The studies in the book show some ways forward and we do think it’s important to be optimistic! Resistance takes many forms. Sometimes it comes through legal and policy reform aimed at increasing transparency and media diversity. In other cases, it’s driven by social movements, investigative journalists and independent media who continue to operate under pressure.
The chapter on Uganda shows that journalist groups working with media advocacy organisations can strategically act to resist government media capture and harmful regulations.
For example, to push back against one legislative change, several groups formed a temporary network called Article 29 (named after the article in the Ugandan Constitution protecting free speech) and the African Centre for Media Excellence produced a report criticising the proposed changes.
One of the chapters on Ghana also shows how networks such as journalists, media associations, human rights groups and legal organisations can mobilise to push back against government influence.
These findings are echoed in Latin America, where research on Mexico and Colombia also found professional journalism to be a strong source of resistance.
The conversation must also include rethinking how we define capture itself. If we frame it only as total control, we risk missing the everyday ways influence operates – and the spaces where it can be resisted.
We would also say it’s really important that citizens are aware and alert to the issues when they think about how they access news media and what platforms they use. This is sometimes called ‘media literacy’ and is about people being more knowledgeable about where trustworthy new comes from.
Major new research will help experts to counter the spread of misinformation in Africa and understand the causes and consequences of the continent’s growing digital divides.
The project, by researchers from the University of Exeter, will provide crucial information for the UK Government about the role of social media in galvanizing offline protest movements across Africa, and the logic behind foreign-origin disinformation and influence campaigns in the region.
Gadjanova will investigate how the public’s growing access to digital technologies and social media in Africa is influencing politics, parties’ organisational capacity and campaign strategies, electoral integrity, socio-economic inequalities and the nature and spread of misinformation in Ghana, Nigeria, Kenya and Zambia.
She has also studied which social media campaigns become viral and influence offline protest movements.
Gadjanova said: ‘I’m thankful to be awarded this fellowship, a result of my work over several years on the role and impact of digital technologies in Africa while here at Exeter, the research networks I have created across several countries, and experience with engaging with policymakers.’
‘This fellowship will support the [Foreign, Commonwealth and Development Office] FCDO capacity to carry out prompt and in-depth analysis of the various impacts that digital technologies are having on the socio-economic transformation and changing power dynamics in Africa
‘This will ensure decisions reflect the latest research and evidence, and improve the FCDO’s capacity to respond to a fast-moving policy environment.
‘In particular, my research can inform the FCDO’s ongoing work on democracy support, electoral integrity, media freedom and countering the spread of social media disinformation in Africa. It is crucial everyone works together to battle the offline spread of misinformation originating online.
‘Improved digital literacy and institutional monitoring can help to counter the worst online harms. There is also a need to improve party institutionalisation to harness the potential of digital technologies to empower new political actors, increase political trust, and improve government accountability.’
Gadjanova has previously briefed the Foreign and Commonwealth Office on African elections. Findings from her earlier research were cited by the Kenya Human Rights Commission in its evidence of electoral irregularities submitted to the Kenyan Supreme Court in August 2017.
The Innovation Fellowships scheme provides funding and support for established early-career and mid-career researchers to partner with organisations and business in the creative, cultural, public, private and policy sectors, to address challenges that require innovative approaches and solutions. The aim is to create new and deeper links beyond academia.
UNIVERSITY OF EXETER
PICTURE: Social media in sub-Saharan Africa is under the academic microscope (Aeqglobal.com)
AI safety is a theme rapidly gaining traction across the continent and globally. But rather than echoing familiar concerns about rogue algorithms, killer robots, or existential threats to humanity, a webinar held by the University of Cape Town’s Faculty of Health Sciences EthicsLab sought to ask a more situated question: what does it mean to talk about safety in Africa, and for whom is safety at stake?
Our guest speaker, Dr Samuel Segun, Senior Researcher at the Global Centre on AI Governance, offered a panoptic and conceptually sharp overview of current risks, regulatory blind spots and opportunities for African leadership in shaping AI safety.
His framing was especially valuable because it resisted attempts to limit safety to a narrow technical question about models misfiring. Instead, it brought into view the social, political, infrastructural and epistemic conditions that shape how AI is built, used and governed on the continent.
Framing the issue: AI Safety ≠ AI Ethics?
Segun opened by clarifying that AI safety and AI ethics, though often used interchangeably, are not quite the same. Safety tends to ask whether a system will behave reliably and avoid unintended harms. Ethics, by contrast, probes whether systems and the societies that shape them are structured in ways that are just, inclusive and normatively defensible.
Yet in practice, the line blurs.
In Africa, like elsewhere, the harms are not abstract but lived, including manipulated elections, surveillance of activists, online gender-based violence and misinformation campaigns that worsen public health crises
These are not merely questions of safety but equally questions of power. They raise questions about what happens when frameworks of ‘safety’ and ‘risk’ assume a universal subject or an abstract ‘humanity’, and overlook the uneven geographies of exposure, harm, and harm prevention. Specifically, they overlook the possibility that what is safe for some may not be safe for others.
Although Segun drew a distinction between safety and ethics, his broad framing of safety ended up encompassing many classic ethical concerns like justice, labour exploitation, human rights and environmental harm.
Jantina de Vries’ intervention pointed to the risks of this move, asking if ethics loses its critical edge when absorbed into safety. We may come to see political problems as technical ones or assume that preventing harm is the same as enabling justice.
While AI safety tends to focus on preventing harm or managing risk, ethics asks deeper questions about how technology shapes the way we live, who is included or excluded, and what values guide these choices
De Vries sought to direct attention not just to how systems work, but to how people use them, and to the social conditions that make some groups more vulnerable than others.
Three risk zones
Segun drew on the three broad categories of risk identified in the International AI Safety Report (2025) which include malicious use, malfunction and systemic harm. Each is worth unpacking.
Malicious use
includes deliberate weaponisation of AI technologies: surveillance tools used to monitor dissent, deepfakes deployed during elections and voice-cloning scams targeting vulnerable users.
African cases abound, from Zimbabwe’s use of facial recognition cameras to Uganda’s police profiling of activists to cybercriminals in Ghana impersonating relatives for mobile money scams. In these cases, AI becomes less a tool for liberation and more a tool for control and deception.
Malfunction
refers to unintended but no less harmful failures: biased algorithms trained on non-African data, healthcare chatbots that provide dangerous advice, systems that ‘hallucinate’ but are treated as infallible.
The data scarcity in African languages and contexts makes such errors more likely, and the consequences more severe, especially when users are structurally positioned to trust or rely on the system.
Systemic risk
looks at the bigger picture. What happens when AI accelerates job displacement, undermines already fragile labour markets or amplifies environmental harm? What futures are being made impossible or foreclosed?
As Segun noted, Africa’s developmental trajectories, especially around tech-enabled outsourcing, may be prematurely cut off by automation. And as data centres expand, their energy and water demands threaten communities already grappling with scarcity
These risks are neither hypothetical nor are they evenly distributed. As I noted in our discussion, a critical question in assessing these AI safety risks is
who bears the brunt of these harms?
whose access to water is diverted to cool a data centre?
whose job disappears in the integration of chatbots in call centres?
who is profiled, monitored, or manipulated, and
who is shielded from those effects?
AI safety and risk is never just about technical systems; it is always about people, positioned differently in power and precarity.
Regulating in a global ecosystem
One recurring question in the discussion was whether Africa can meaningfully regulate AI in a world where much of the technology is developed elsewhere. Segun argued that AI regulation cannot be siloed from broader data governance.
Foundational protections like privacy, data ownership, and consumer rights are often cited as prerequisites for meaningful AI regulation. But perhaps the more urgent question is: who decides what counts as foundational?
In African contexts where precarious labour conditions and environmental vulnerability are already widespread, is it clear that privacy should always be the primary or starting concern? Shouldn’t protections for workers, energy security, or environmental commons be just as foundational given the ways AI technologies intersect with these spheres?
What’s at stake, in other words, is not only how we regulate, but which harms we centre in our regulatory imagination.
Some participants pointed to the European Union’s Artificial Intelligence Act as a possible model, but Segun cautioned against transplanting frameworks without adaptation. Legislation without enforcement, he reminded us, can offer the illusion of protection while leaving underlying harms intact. What is needed is not just policy, but capacity to audit, to adapt and to govern.
Encouragingly, there are efforts underway. Several African countries are drafting AI strategies. Kenya, Segun tells us, is part of the international AI Safety Institute Network (though it does not yet have a domestic institute). But continent-wide coordination remains limited and uneven.
Toward African-led responses
Segun proposed five directions for action, each of which invites further engagement:
a human rights-based approach to AI governance grounded in principles like non-discrimination, privacy and participation
an African AI Safety Institute as a dedicated space for research, risk mitigation and knowledge exchange across the continent
early detection systems and tools that can flag AI-generated fakes and scaled manipulation, with support for African languages and local contexts
public literacy and capacity-building that includes not only technical training, but critical media and civic education, and
enforcement, not just legislation to ensure that policy frameworks are effectively implemented
Each of these ideas deserves deeper conversation. Who defines what counts as ‘safe’? How do we build detection systems without reinforcing surveillance logics? Can public literacy campaigns avoid becoming top-down digital paternalism?
Closing thoughts: On safety, ethics and imagination
It is clear that the term, ‘safety’, does useful work, alerting us to danger and demanding precaution. But it also has limits. It can drift into technocratic neutrality, obscuring the political choices embedded in design and deployment.
Choices about what gets built, how and where; whose data is used; and which harms are prioritised are always shaped by competing values and interests. Safety, and its proxy of risk, can also flatten difference, treating harms as universal rather than situated
Is it worth building on and pushing beyond safety, toward something like justice or even care?
In a bid to reframe the narrative around labour migration and fair recruitment across West Africa, especially in the media, journalists, trade union leaders, and labour advocates from 12 ECOWAS countries convened in Abuja from 24 to 25 June 2025, for a high-level validation workshop on the ‘Adaptation of the ILO Media Toolkit on Reporting Fair Recruitment and Forced Labour’, published by the International Labour Organisation (ILO).
Representing the ILO’s Country Director for Nigeria, Ghana, Liberia and Sierra Leone, Inviolata Chinyangarara, Specialist on Workers’ Activities (ACTRAV), emphasised the indispensable role the media plays in shaping public perception of migration.
‘By reporting on migrant workers’ experiences, the media can shift narratives from fear and hostility towards empathy and human rights,’ Chinyangarara stated.
‘Ethical and informed journalism can expose human rights abuses, address stereotypes and highlight the positive contributions of migrants. However, negative narratives can also be amplified, leading to prejudice and stigmatisation’
She further described the toolkit as a call to action, one that holds systems accountable and elevates the humanity behind migration, encouraging policies rooted in fairness and transparency.
‘Today, we have gathered not just as professionals, but as advocates for social justice and decent work for all within the ECOWAS space,’ she declared.
The workshop took place against the backdrop of complex labour migration dynamics within West Africa, where individuals cross borders in search of economic opportunity, often facing exploitation, unsafe travel conditions, and policy gaps.
Chinyangarara warned against the dangers of forced labour and unethical recruitment, noting they are not only violations of international labour standards but acts that rob individuals of dignity, safety and access to decent work.
Louis Thomasi, Regional Director of the IFJ Africa office in Dakar, Senegal, stressed that African journalists must rise to the responsibility of ethical, accurate and gender-sensitive reporting, especially in a digital age prone to misinformation and misuse of artificial intelligence in media
‘The Action Plan seeks to ensure the media plays a vital role in promoting the rights of migrants and advancing Africa’s story,’ Thomasi affirmed.
He outlined six major pillars of the Action Plan being developed in partnership with the ILO, which include:
capacity building for African journalists to tell positive, development-oriented migration stories
improving access to accurate, official data on labour migration
adoption of the newly validated Media Toolkit to prevent data falsification
gender-sensitive journalism to foster inclusive narratives
public awareness campaigns on labour migration rights and realities, and
promoting correct use of migration terminology to enhance public understanding
‘Inaccurate, biased media reporting can lead to misinformation, and at worst, may incite discrimination and unfair treatment,’ Thomasi warned.
President of the FAJ, Omar Faruk Osman, in his address, urged media practitioners across the continent to tell Africa’s labour migration story from a national and regional perspective to counter misrepresentation.
‘For African journalists, it is also about extending solidarity to our sisters and brothers who migrate for work within Africa and beyond,’ he said, describing the ILO Media Toolkit as a vital resource designed to support journalists in their pursuit of accurate, in-depth, and impactful migration reporting.
Also speaking, Comrade John Odah, Executive Secretary of OTUWA, called for stronger media-trade union collaboration: ‘This meeting will help to provide more insights on how to address challenges faced by migrants and make them feel at home, especially within the West African sub-region.’
‘We need a strong partnership with the media to push out the real issues in labour migration’
From the business community, Thompson Akpabio, Director at the Nigeria Employers’ Consultative Association (NECA), underscored the importance of accurate reporting in national development.
‘Journalists must not report labour migration from a biased perspective. When the correct position is finally known, significant damage may already have occurred,’ he cautioned. ‘The media toolkit provides a guide to ensure professionalism, counter misinformation and avoid disinformation.’
Ultimately, the two-day event was a reaffirmation of regional commitment to truth-telling, human rights, and development journalism. It concluded with a resounding call for solidarity and greater capacity-building to empower journalists across the ECOWAS region to tell labour migration stories with accuracy, empathy and integrity.
An in-depth examination of Uganda’s media legal and regulatory framework, with a particular focus on its implications for press freedom, democratic engagement, and the overarching vitality of the media sector, has been published.
The report, Vulnerable Media, Struggling Democracy: A Critical Appraisal of Uganda’s Media Legal Framework, is an initiative of ACME and was commissioned with the support of the Ford Foundation.
The regulation of media is a fundamental aspect of modern governance and plays a central
role in shaping the dynamics between the media, the state and society.
At its core, media regulation refers to the processes and mechanisms by which media systems are structured, governed, and monitored, typically through legal or quasi-legal means, to ensure they operate in alignment with public policy goals.
These regulations are designed not only to promote fair and ethical media practices but also to safeguard citizens’ rights, including the protection of public order, national security, and privacy
However, the complex and often contentious nature of media regulation lies in the delicate balance between the need to uphold freedom of expression, which is enshrined as a fundamental human right, and the responsibility to prevent the proliferation of harmful, intrusive, or defamatory content.
This report analyses the landscape of media regulation in Uganda. The aim is to critically assess the current media regulatory framework in Uganda, explore the challenges faced by journalists and media outlets, and evaluate the impact of existing laws and regulations on freedom of expression.
It also seeks to examine the broader implications of these regulations for media practice in the country and provide recommendations for enhancing the regulatory environment to better serve the public interest while safeguarding the rights of media practitioners.
Through this report, ACME hopes to contribute to ongoing discourse surrounding media regulation and freedom in Uganda, with a view to nurturing a media environment that is both free and responsible; one that respects the diversity of voices and upholds the principles of democracy and human rights
This report undertakes a comprehensive examination of Uganda’s evolving legal and regulatory environment as it pertains to the media landscape, with a particular focus on the period spanning from 2019 to the present day (May 2025).
Recognising the foundational constitutional guarantee of freedom of speech and expression, including the freedom of the press and other media, this study analyses the growing body of statutory laws, regulations, and policy directives that appear to increasingly restrict these fundamental rights.
Specifically, the report aims to dissect the inherent contradictions between these constitutional principles and the practical application and interpretation of existing and newly enacted legislation affecting the media.
In doing so, this report seeks to assess the extent to which recent legal reforms, particularly those governing digital expression, online content, and the operation of social media platforms, have impacted the autonomy and operational space of media organisations and individual journalists.
Furthermore, it investigates the broader implications of these legal developments for the health and vibrancy of democratic discourse within Uganda.
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