The geopolitical dimension of digital communications has become a central conceptual framework for interpreting global transformations including the governance mechanisms of cyberspace, concepts of digital sovereignty, and memorial constructs of the “free internet.” The triad of leading actors — the United States, the People’s Republic of China, and the European Union — shapes the architecture of technological identity. These powers exert influence through media discursive practices with journalistic representations. The epicenter of this confrontation lies in its antagonistic narrative constructs. The libertarian concept of open cyberspace clashes with the doctrine of cyber sovereignty and digital protectionism, which are transforming into the normative foundation of many authoritarian and semi-authoritarian political regimes.
Technological Identity and Media Strategies
The construction of the technological identity of national entities is carried out through media strategies, where techno nationalist concepts gain hegemonic positions. The American model of constructing the narrative of a “free network” was based on the ideologemes of innovative autonomy, startup enthusiasm, and market self-regulation. Media structures and platform ecosystems cultivated the representation of the internet as a de-territorialized space, removed from the jurisdiction of state institutions, allowing American IT corporations to consolidate their positions as global moderators of the digital world order. The Chinese state apparatus distances itself from the paradigm of openness by implementing a vertically integrated model of digital communications administration, i.e., Cyber Sovereignty. This doctrine, supported by the infrastructure of the “Great Digital Wall,” methodically limits cross-border information flows, building an architecture of permanent surveillance.
Journalistic institutions function here as instruments of legitimization. They themselves sanction the transition to a sovereign paradigm through media campaigns that articulate the imperatives of control and security. Platform layers, namely conglomerates like WeChat and Alibaba, are transforming into identification mechanisms. Their goal is largely driven by the consolidation of state governance of cyberspace as a whole. Evidence of this transformation is China’s National Cyber ID System, launched in July 2025, which encompasses more than 50 major platforms. It, in turn, already includes WeChat and Taobao, which are currently in beta testing. Under this system, users must register through a police-administered app and provide facial scans with identification documents. These procedures are largely used to obtain a unique virtual ID that platforms can verify without direct access to sensitive personal data. The system operates on the principle of “usable but invisible” (可用不可见), ensuring that even when platforms receive verification status, the state retains centralized control over identity data. The approach itself is based on the 2017 Cybersecurity Act and the Telecommunications Fraud Control Act, which legally obligate platforms to implement real-name registration. It also includes the ability to grant government agencies unlimited access to user verification data. By 2020, the predecessor of the CTID system was already processing 15 million verifications daily, demonstrating the scale of the state-controlled digital identification infrastructure.
The European Union, in its attempts to occupy a “third position,” has constructed specific regulatory regimes that can be broken down into provisions such as the GDPR, the Digital Markets Act, and the Digital Services Act, which reinforce value imperatives such as transparency, ethical norms, and personal rights. Bureaucratic mechanisms, as well as the media landscape, are focused on synthesizing innovative processes with democratic principles, institutionalizing the “Brussels effect,” that is, through the extrapolation of regulatory standards beyond the jurisdiction of the union.
Cultural Memory: “Open Internet” vs “Digital Sovereignty”
Characteristics of the memorial constructs of the “open internet” emerge through journalistic practices, platform narratives, and detailed media activities that preserve reminiscences of communicative autonomy. These motifs are gradually being replaced by an alternative discourse, namely the term “digital sovereignty,” which correlates with security and infrastructure control — the Russian Federation and the PRC demonstrate how protectionist narratives dominate digital sovereignty discourse. For example, the Russian context articulates digital sovereignty through the prism of national security or protectionism, and media structures intensively implement the concept of the need to protect against exogenous threats by restricting foreign platforms. The Chinese specificity is characterized by an emphasis on economic leadership and the export of digital infrastructure (the Digital Silk Road), where media messages function as tools for constructing foreign policy or even domestic governance models.
The European Union, mentioned earlier, preserves the memorial structures of the “free internet” while intensifying regional control trends, especially after scandals involving privacy and manipulative practices (the TikTok and Huawei cases). EU journalistic institutions are transforming into an arena of debate between the imperatives of the digital market and ethical obligations to citizens.
Practical Cases
The American press is at the epicenter of debates about major digital platforms. For example, investigative reporting on Facebook (META) has repeatedly sparked public debates about privacy violations that have led to manipulative information control techniques. Consequently, these media revelations are shaping a national debate about technology governance, with questions about the appropriateness of market regulation. It is worth noting the post-scandal period of Cambridge Analytica, which was marked by a thorough analysis by the media community of the mechanisms of targeted influence on the electorate through the accumulation and subsequent processing of user data, determining the requirements for transparent management. Amid escalating criticism, the journalistic community interprets the narrative of “defending freedom” as an ideological construct that legitimizes the minimization of state intervention while maintaining the model of digital communications development based on the principles of market self-regulation. In light of this, the emerging paradox manifests itself in growing public distrust of technological platforms and the transformation of the media space into an arena of confrontation between the ideals of openness and the spectrum of total control. This leads to the brief conclusion that American journalism, analyzing the consequences of data leaks with a political marker of influence, is essentially marking a new front in public debate, where the deconstruction of outdated paradigms correlates with attempts to preserve the advantages of an open internet space.
On the other hand, the European Union is constructing a unique trajectory, balancing between the imperatives of innovative development and the subsequent strengthening of digital sovereignty. The implementation of the GDPR Regulation has set a global precedent, expanding the scope of user responsibility and essentially transforming approaches to data storage in all sectors of the digital economy. EU journalism and media institutions function as strategic tools for educating the public about the digital space. This creates an intellectual space for exchange is being created, where multiple discussions address fundamental issues of sovereignty or individuality within the framework of legal protection.
Comparison of Approaches and Political-Legal Implications
Thus, a comparative analysis of models demonstrates visible attempts to balance innovation with openness, which determine the fragmentation of the global digital landscape, where, in turn, the narrative constructs of “cyber sovereignty” and “open internet” are not limited to competition. In essence, they generate differentiated forms of cultural memory linked to identity. All of this is manifested in legislation or media policy. Only the states of the Global South demonstrate hybridization, whereby, under the influence of the “Brussels effect,” elements of European privacy standards are incorporated while simultaneously strengthening the positions of local platforms with the conditions of state digital control strategies.
Brazil’s LGPD, which entered into force in 2020, along with Indonesia’s 2022 Personal Information Regulation, demonstrate the incorporation of European GDPR regulatory frameworks, encompassing the rights of individuals whose data is processed. In its 2025 preliminary opinion on the compliance of Brazil’s jurisdiction with European requirements, the European Commission affirmed the equivalence of the LGPD’s regulatory framework with the EU regulation. At the same time, these countries are strengthening their national digital ecosystems through government technological sovereignty programs.
Kenya’s 2019 Information Security Regulation establishes a legislative foundation alongside the creation of national mechanisms for electronic authentication of citizens. CEPA’s 2025 analytical report documents the adaptation of European regulatory approaches by Brazil, Kenya, India, and Indonesia, driven by a desire to preserve trade opportunities within the pan-European space. Over 160 governments globally, including a significant number of developing economies, have introduced specialized information security regulations, with UNCTAD emphasizing the critical importance of privacy for the technological modernization of peripheral economies. The observed hybrid regulatory processes demonstrate differentiated implementation of European regulations, determined by regulatory feasibility in the context of international political constraints.
The unmentioned but well-known Indian and Brazilian cases illustrate attempts to create original models at the intersection of state interests. The complexity of this process is compounded by the combination of technological identity with everyday user practices, in which cultural memory, reinforced by media platforms, plays a major role.
Conclusion
This analysis demonstrates that the international agenda for digital communications is determined by competition for hegemonic narratives of technological identity, which subsequently manifest themselves through media strategies or legal approaches to Internet regulation. For example, the American model reinforces the image of a “free and innovative network,” the Chinese model introduces the concept of technocratic control with a subsequent transition to expansion, while the European model attempts to harmonize ethical and legal-economic dimensions. Journalistic institutions transmit these narratives by constructing cultural memory and legitimizing normative transformations. Promising research trajectories lie in analyzing cross-cultural media practices and investigating universal models of protection of rights and freedoms amid competing technological futures.
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