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Концептуальные основы и правовое регулирование противодействия дезинформации: сравнительный анализ через призму междисциплинарности
Introduction: Disinformation represents one of the most complex challenges for legal regulation. Legal systems worldwide respond differently to this challenge amid heightened geopolitical tensions. The phenomenon of disinformation is examined by scholars across various disciplines; however, from a legal perspective, the concept remains insufficiently studied. Abroad, the term "disinformation" has firmly established itself in legislation and is actively researched not only by legal scholars but also by experts from other scientific fields. Significant emphasis is placed on countering disinformation, with a growing body of jurisprudence—particularly concerning measures to combat disinformation in cyberspace.
Objective: To conduct a comparative analysis of the legislation of the European Union, the United States, and Russia regarding countering disinformation; to determine the legal essence of disinformation; and to identify shortcomings in Russian legislation pertaining to countering disinformation.
Methods: The study employs the comparative legal method, legal hermeneutics, the historical-legal method, and a systemic approach to examine disinformation as a concept that may manifest across various branches of Russian law—criminal, administrative, and information law.
Results: The author analyzes the legislation of the EU, the US, and Russia, along with definitions of disinformation and legal scholars’ approaches to countering it, juxtaposing these with insights from experts in other disciplines.
Conclusions: Current Russian legislation does not fully address the broad spectrum of challenges associated with the spread of disinformation. In this regard, EU legislation proves significantly more effective in combating disinformation through diverse regulatory instruments, precise definitions, and detailed legal provisions. Notably, foreign legislation in this domain is often explicitly oriented toward countering Russian interests, thereby posing an additional challenge to the sovereignty of the Russian Federation.