COMPARATIVE REGULATORY APPROACHES OF PLATFORM ACCOUNTABILITY AND CONTENT MODERATION IN KENYA, NIGERIA, AND INDONESIA

Abstract

The global expansion of social media platforms and digital intermediaries has intensified regulatory challenges relating to platform accountability and content moderation across developing economies. This paper undertakes a comparative legal and policy analysis of regulatory frameworks in Kenya, Nigeria, and Indonesia three democracies in the Global South that exhibit comparable digital transformation trajectories but divergent regulatory outcomes. Despite broadly similar exposure to platform-related governance challenges, Kenya and Indonesia have developed relatively functional accountability regimes, while Nigeria has struggled to translate extensive statutory frameworks into effective regulatory practice. Drawing on primary legislation, policy instruments, secondary scholarship, and documented enforcement outcomes, the paper argues that Nigeria’s regulatory deficiencies are not primarily attributable to legislative inadequacy. Instead, they arise from structural weaknesses in institutional coordination, enforcement credibility, political interference, and the absence of effective multi-stakeholder governance mechanisms. The 2021 suspension of Twitter (X) in Nigeria is analysed as a paradigmatic case illustrating the disconnect between formal regulatory authority and effective governance outcomes. The paper concludes that effective platform accountability is contingent less on regulatory proliferation than on institutional coherence, credible enforcement, and rule-of-law–anchored governance systems, and offers reform-oriented recommendations tailored to the Nigerian context.