Manipulation of information as a hybrid threat: EU and the U.S. in comparative perspective

Abstract This paper compares how the EU and the U.S. address hybrid threats, particularly the manipulation of information as a tool to undermine democracies. Hybrid threats include tactics like cyberattacks, disinformation, and electoral interference, often by foreign or non-state actors. The EU has adopted a regulatory approach, notably through the Digital Services Act (DSA) and Digital Markets Act (DMA), which impose duties on large platforms to mitigate systemic risks and enforce transparency. It combines hard and soft law tools, emphasizing human rights and co-regulation. In contrast, the U.S. prioritizes free speech, limiting government action against disinformation due to First Amendment protections. Although federal agencies play a key role in countering foreign interference, recent shifts signal a move away from fact-checking and cyber operations. The EU and U.S. face similar adversaries but diverge significantly in their strategies. This divergence may weaken democratic resilience unless efforts are coordinated and platform accountability is strengthened across both regions.