Deepfake and Electoral Crimes: Criminal Law Perspectives from Indonesia, India, Pakistan, and the U.S.

Deepfake technology, an advanced AI-driven tool capable of creating hyper-realistic synthetic media, provides significant challenges in political campaigns and election integrity. As the use of deepfakes in elections rises, concerns about their potential to spread misinformation and manipulate voter perception become increasingly urgent. This study examines the criminal law approaches to deepfakes in political campaigns across Indonesia, India, Pakistan, and the United States. Using a normative legal research method, this paper analyzes relevant laws, regulations, and legal frameworks governing deepfake misuse in elections. A comparative approach is employed to assess legal responses in different jurisdictions, identifying gaps and challenges in addressing the issue effectively. Findings reveal that while Indonesia relies on broader legal provisions, such as the ITE Law and Personal Data Protection Law, there are no specific regulations targeting deepfake manipulation in elections. Similarly, India and Pakistan address deepfake-related offenses through existing cyber and penal laws, whereas the U.S. has taken a more proactive approach with state-level legislation criminalizing deepfake election interference. This research highlights the need for more comprehensive legal frameworks to mitigate the risks of deepfakes in electoral processes and ensure democratic integrity.