The International Discourses and Governance of Fake News

Since the 2016 US presidential elections, fake news and misinformation have been recognised as a major problem of the modern, connected world. However, this increased salience has been accompanied by an expansion in voices articulating different approaches towards the issue. This article presents an examination of the range of societal discourses of fake news advanced by four types of hegemonic societal actors: international organisations, states, civil society and large business interests, focusing on the following. First, how do existing discourses conceive of the nature of fake news and the societal objects it threatens? Next, what are the solutions proposed? Through an analysis of policy interventions and texts, this article presents a taxonomy of the current most salient understandings of fake news, showing that present conceptualisations of the issue can be categorised into three competing discourses: discourses constructing fake news as an existential threat, a political problem or a minor issue. The analysis highlights important variations in how different regimes conceptualise fake news, revealing how authoritarian governments have sought to construct fake news as a security threat in order to justify constraints on free speech. On the flipside, leaving fake news completely unregulated leads to conflict-of-interest issues and an accountability gulf implicating ‘Big Tech’. This article calls for more analytical focus on the discourses of fake news, which constitutes a significant but under-examined factor in comprehending the long-term consequences of the problem of fake news.

Policy Implications

  • Fake news is not a static, singular phenomenon, but one over which many important stakeholders in society compete against to define and propose solutions for. The solutions advanced by these groups have different societal consequences and often diverge radically – from banning false information outright to completely leaving private technology companies to self-regulate.
  • Different categories of fake news discourses appear to have achieved societal hegemony in different geographies of regime types, in which authoritarian governments are shown to be more inclined to define fake news as a national security threat. While fake news and misinformation can have potential implications for national security, top-down attempts to frame the issue as a national security threat and legislate directly on it risks violating the freedom of expression and other important civil liberties.
  • On the other end of the spectrum, liberal democracies in the EU and Australia/New Zealand have been more cautious in legislating on the issue, with many countries choosing to protect the freedom of expression and not criminalising information simply because they are untrue. Especially in the case of USA however, this gives rise to a separate set of issues, including whether fake news has inhibited access to quality information – a fundamental tenet for democracy – as well as the lack of oversight over powerful technology companies, who may not have the right incentives to fairly regulate and protect the public from the worst effects of fake news and misinformation.
  • Ultimately, the long-term societal consequences of fake news would be shaped not just by its actual empirical effects, but also by how hegemonic societal actors frame and discursively construe the issue. Given that the way the public understands the severity of fake news as an issue is influenced heavily by elite discourse, this study calls for a renewed examination on how leading actors discursively define fake news, and especially what kind of related legislations are passed, how they have been justified, and who benefits from them.


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