The digital boundaries of free speech: legal interventions on hate speech and disinformation in the age of social media

In the digital media era, extreme remarks and fake news on social platforms are constantly impacting the limits of freedom of expression. This study selects three jurisdictionsthe European Union, the United States, and Chinato compare and analyze the institutional development of online speech governance. By analyzing the practical conflict between the European Digital Services Act and the First Amendment to the U.S. Constitution, the paper reveals the value gap between protecting freedom of expression and implementing content control in different jurisdictions. Platform content audit data and post-removal appeal cases show that the existing governance system has structural problems such as unclear implementation standards and unbalanced allocation of audit resources. Especially in the interaction between algorithmic recommendation mechanisms and manual audits, users often encounter difficulties such as blocked appeal channels and opaque removal procedures. The research proposes the establishment of a hierarchical and classified content governance framework, the promotion of transnational platforms to establish a traceable audit log system, and the exploration of speech risk assessment models based on cultural context, so as to provide an institutional guarantee for the construction of a digital discourse space with equal rights and responsibilities.