SOCIAL MEDIA AS A HABITAT FOR HYBRID THREATS: A COMPARATIVE ANALYSIS OF COMMUNICATION MODELS FOR PLATFORM REGULATION IN THE EU, THE U.S., AND CHINA

Abstract

Social networks are increasingly viewed not as a neutral channel of communication, but as a structurally vulnerable media environment in which their architectural features – engagement algorithms, cross-border infrastructure, and minimal barriers to publication – facilitate the spread of manipulative content. This communicative vulnerability makes platform regulation not an optional tool of media policy, but a structural necessity. The aim of this article is to conduct a comparative analysis of three models of platform governance – those of the European Union, the United States of America, and the People’s Republic of China – through the lens of media theory, public sphere theory, and the communicative power of platforms. The study reveals that despite fundamental differences in approaches – the EU’s rights-based media policy, the U.S.’s security-oriented logic, and China’s sovereignty-based control – all three models face a common structural deficit: regulatory mechanisms systematically lag behind the pace of transformation in communication practices and technologies of manipulative influence. The article proposes a typology of communicative regulatory models (rights-based, security-based, and sovereignty-based) and argues that none of them eliminates the fundamental asymmetry between the speed of technological change and the speed of institutional response to these changes, but merely distributes the associated communicative risks and costs in different ways. The findings of this study are significant for the development of media policies in countries that, like Ukraine, are simultaneously targets of hybrid information threats and actors in shaping their own architecture of the digital communication space.