Working Paper
In the preceding stages I have established the normative case for the ninth dimension and defined its content. Algorithmic accountability, understood as the degree to which the systems that constitute individuals as political agents are subject to the justificatory obligations those individuals are owed, identifies a structural gap that existing democratic measurement frameworks do not reach and that existing regulatory frameworks have not closed. Before assessing what the dimension requires, it is necessary to ask how that gap came to exist. In this stage I examine the historical and regulatory record to establish two things: first, that the principle the ninth dimension rests on, that private actors, whether individuals, organised groups or commercial platforms, exercising power over the public sphere generate democratic obligations, is not new but has been displaced rather than applied at the architectural level; and second, that the pattern of displacement, along with the consequences of its absence, look different depending on the democratic context in which platform power operates. My analysis explores four registers: the phenomenal surface of the developed West, the regulatory object-error of emerging democracies, the political closure of hybrid states, and the citizen-side preconditions found within digital education.
The underlying principle is not new. Democratic states have long acknowledged that private actors operating within the public sphere generate democratic obligations. In the UK context, this is reflected in media plurality rules and restrictions on ownership, designed to prevent excessive concentration of influence over public political life. The infrastructure through which political communication occurs has, in this sense, never been treated as entirely neutral or purely market-driven.
The Telegraph sale, which concluded in April 2026 when Axel Springer acquired the Telegraph Media Group (Nandy, 2026), illustrates both the reach and the limits of existing regulatory principle. The process generated two public interest intervention notices, issued in November 2023 and January 2024 (Secretary of State for Culture, Media and Sport, 2023; 2024), each grounded in the plurality considerations set out in section 58(2A) of the Enterprise Act 2002, the need for accurate presentation of news and free expression of opinion. Ofcom and the Competition and Markets Authority were required to assess market share and consider the broader democratic implications of ownership concentration. The regulatory framework demonstrated the power to block acquisition by a UAE-backed entity on plurality grounds, even at the cost of considerable commercial and diplomatic friction: the offer was higher than the final sale and the UAE are considered allies of the UK (Digital Markets, Competition and Consumers Act 2024; House of Commons Library, 2024). However, that same framework offers no equivalent mechanism for contesting the architectural logic of the platforms that shape what UK citizens encounter as political reality. Foreign-owned recommendation systems operate at a scale, and with a constitutive reach over political agency, that no single newspaper ownership structure could match, and they attract none of the democratic scrutiny the Telegraph process required. The plurality of the information environments those systems create, and the algorithmic processes through which the state itself increasingly makes decisions about citizens, is not subject to equivalent scrutiny. Intervention notices have not been issued, largely because no mechanism exists to trigger one. The principle that control over the public sphere carries democratic responsibility is embedded in existing regulatory practice. What the Telegraph process confirms is that the principle operates only at the level of ownership and editorial identity, not at the architectural level at which the conditions of political agency are increasingly constituted. Where ownership is deemed a threat to national sovereignty or democratic governance, access to UK consumers can be blocked.
The same displacement of principle from architecture is visible in data protection law, where the historical record is instructive. The Data Protection Act 1984 was enacted at the start of significant digital storage becoming possible, reflecting an early recognition that digital systems could be weaponised against individuals and that legislative protection was required. Successive revisions, culminating in the GDPR and its domestic incorporation through the Data Protection Act 2018, have retained and deepened that core commitment to the individual as a data subject with rights over how their personal data is collected, stored and processed. This represents a meaningful protection of informational privacy. However, the framework carries a structural bypass. At the platform interface, GDPR compliance frequently renders the source of data collection opaque rather than transparent, presenting citizens with terms and conditions that nominally satisfy the consent requirement while obscuring what is actually being agreed to. The data harvested under that consent is then aggregated to feed the very algorithmic architecture the regulation does not reach. GDPR regulates the exchange of data, but the exchange it regulates is the mechanism through which the conditions of political agency are shaped, not the protection of those conditions. The legislation addresses the transaction and leaves the architecture untouched.
The Online Safety Act 2023 represents an attempt to address platform power within existing UK regulatory frameworks. The Act introduces a duty of care framework requiring platforms to conduct risk assessments in relation to illegal content and content harmful to children, making Ofcom the regulatory body responsible for overseeing compliance (Online Safety Act 2023a; Ofcom, 2024). However, the risk assessments the Act requires are conducted by the platforms themselves, resulting in the governing logic of the architecture being evaluated by those who designed and profit from it, without any requirement to make that logic externally contestable or independently verifiable (Ofcom, 2023). The Act is directed at identifiable harms at the level of individual pieces of content or categories of users. It does not require platforms to justify the recommendation and curation logic that determines which content reaches which citizens, or to make that logic open to challenge by those subject to it. The House of Commons Science, Innovation and Technology Committee concluded in July 2025 that the online safety regime has major problems and is already out of date, identifying a specific regulatory gap in relation to recommendation algorithms and finding that the OSA fails to address the algorithmic amplification of content in ways that endanger public safety (House of Commons Science, Innovation and Technology Committee, 2025). What the Online Safety Act regulates is the surface at which harm becomes legible. The architectural conditions under which citizens are constituted as political agents, and under which some content reaches citizens, remain outside the accountability relationship the Act creates.
Most recent announcements regarding the Children’s Wellbeing and Schools Act 2026 extends the OSA’s reach by granting the Secretary of State powers to restrict children’s access to specified platforms and features (Children’s Wellbeing and Schools Act 2026). Announcements in June 2026 of a ban on social media for under-16s from Spring 2027 represents the most direct intervention yet in the relationship between citizens and platform architecture (HM Government, 2026). Yet the concern driving these measures remains one of access and content exposure rather than architectural accountability. The question being asked is which citizens should be permitted to enter the architecture, not whether the architecture itself is subject to democratic justification. Harmful algorithmic recommendations are identified as a concern in Ofcom and ICO enforcement letters to platforms (Ofcom and ICO, 2026), but the remedy proposed is restriction of access, not contestation of the governing logic. This is the most ambitious child protection intervention in a generation, but remains directed at the phenomenal surface. The architectural level at which the conditions of political agency are constituted remains unaddressed.
The Digital Services Act represents the European Union’s most ambitious attempt to reach platform power at a structural level. Its provisions on very large online platforms impose risk assessment obligations under Article 34 and mitigation duties under Article 35, with the European Commission holding enforcement powers that can reach up to six per cent of a platform’s global annual turnover (Regulation (EU) 2022/2065). The Commission’s preliminary findings of 6 February 2026 against TikTok mark a significant regulatory moment. For the first time, enforcement action focused not on illegal content, data protection or competition, but on the addictive design features of the platform architecture itself, including infinite scroll, autoplay, push notifications and highly personalised recommender systems (European Commission, 2026), the same features that informed the UK government’s June 2026 announcements on children and social media. The Commission found that TikTok had failed to adequately assess how those features harmed the physical and mental wellbeing of its users, particularly minors and vulnerable adults, and had disregarded indicators of compulsive use including the time spent on the platform at night. Even here, however, the accountability relationship runs between the platform and the regulator, assessed by reference to risk to individual wellbeing rather than to the democratic conditions of political agency. The DSA reaches the architecture. It does not yet reach the question of whether that architecture is subject to the justificatory obligations it owes to those whose conditions of political reasoning it constitutes.
Canada provides a different but equally instructive illustration of the limits of content-level regulation. The Online News Act 2023 (Bill C-18) attempted to require digital platforms to compensate Canadian news publishers for content distributed through their services. Meta’s response was immediate and architectural: on the day the Act received Royal Assent, the company confirmed it would end news availability on Facebook and Instagram for all Canadian users, implementing the block in August 2023 (Meta, 2023). The platform did not contest the principle. It reconfigured its architecture to exclude the regulated content entirely, rendering the regulation effectively irrelevant in relation to the democratic information environment it was designed to protect. The state had attempted to reach platform behaviour at the level of content distribution. The platform responded by exercising its architectural power at a level the legislation could not reach. As of June 2026, nearly three years after the block was implemented, news has not been restored. The Canadian government remains in negotiations with Meta to persuade the platform to reverse an architectural decision it made unilaterally, with the United States having identified the Online News Act as a trade irritant in bilateral negotiations, a key feature relied on by major platforms when faced with government scale attempts at regulation. The regulator is negotiating with the regulated. Canada’s parallel attempt to introduce a duty of care framework through the Online Harms Act (Bill C-63) compounded the picture. Modelled on the UK’s Online Safety Act, the Bill defined harms as seven specific categories of content, most of which were already illegal, and included a provision requiring removal within twenty-four hours where directed by the Canadian government. This left platforms otherwise free to determine whether content meeting those definitions should be removed (Department of Canadian Heritage, 2024). Even had it passed, the self-regulation status quo would have remained essentially intact at the architectural level (Centre for International Governance Innovation, 2024). The Bill fell twice on the order paper, most recently in January 2025 when Parliament was prorogued following the Prime Minister’s resignation, its failure driven by political circumstance rather than parliamentary opposition to its intent (TechPolicy.Press, 2025a). The Canadian case demonstrates two things simultaneously: that platforms will deploy their architectural power to neutralise regulation directed at the content level and that even the most ambitious content-level frameworks being attempted in the developed West do not reach the architectural conditions under which the democratic information environment is constituted.
Across these Western frameworks a consistent pattern emerges. The principle that private actors exercising power over the public sphere attract democratic obligations is not only recognised but actively enforced at the level of ownership, content and data exchange. The Telegraph process demonstrates that the state will act on that principle even at a considerable economic and diplomatic cost. I argue that what none of these frameworks settle is the architectural level problem: the level at which the conditions under which individuals encounter political reality are constituted before any observable democratic activity takes place. The displacement is not accidental. It reflects the limits of regulatory categories developed before platform architecture existed as a political phenomenon.
The regulatory pattern identified in the developed West is not confined to contexts where sophisticated legal frameworks exist. Globally, democratic states have engaged with platform power in ways that range from the exceptionally stringent to the formative. What is consistent across that range is not the quantity or intensity of regulation but its object: in every case, regulatory effort is directed at the visible outputs of platform power, at content, compliance, data exchange and user identification. In common with Western democracies, the architectural conditions under which political agency is constituted remain unaddressed. The gap my ninth dimension identifies is not a function of regulatory capacity. It is a function of regulatory object. India demonstrates this most sharply: a framework more demanding in several respects than anything the developed West has produced but similarly empty on the architectural level.
India provides the most developed example and in some respects the most instructive one. The Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules 2021, issued under the Information Technology Act 2000, introduced substantive obligations on significant social media intermediaries that have been progressively tightened through four rounds of amendment, most recently in February 2026 (Ministry of Electronics and Information Technology, 2021; 2026).1 In several of its provisions India’s framework is more stringent than anything the OSA, GDPR or the DSA requires. The intensity of regulatory effort is not in question. What the framework does not do, in any of its iterations, is address the recommendation or curation logic that determines which content reaches which citizens and under what conditions of political salience. India demonstrates that a state can construct an exceptionally demanding regulatory apparatus and still not engage with the architectural level, because all of that intensity is directed at what platforms distribute, who produced it and how quickly it can be removed. The conditions under which citizens are constituted as political agents remain entirely outside the accountability relationship the rules create.
Brazil presents a different but equally instructive case. Brazil’s PL 2630, introduced in 2020 and debated across three legislative sessions, is a focused attempt by a democracy to address platform power at the architectural level. Explicitly modelled on the DSA, the bill proposed algorithmic transparency requirements, limits on automated content sharing and independent oversight mechanisms that would have gone beyond mere content removal obligations (Tomaz, 2023, pp. 255–257). Its ambition was precisely what my ninth dimension identifies as necessary: it attempted to make the governing logic of recommendation systems externally contestable rather than trusting regulation of the content those systems amplify. Tomaz concludes, however, that the bill follows a general pattern of platform regulation in that “measures that fail to alter the fundamental business model and dynamics of the firms themselves will leave in place the incentives that drive the problematic practices of surveillance and data mining and negative forms of misinformation and amplification” (Tomaz, 2023, p. 264). The bill was defeated. The way in which it was defeated is analytically significant. Research by NetLab at the Federal University of Rio de Janeiro documented that major platforms including Google and Meta ran campaigns against PL 2630 using the very algorithmic amplification mechanisms the bill was designed to address, promoting content against the legislation through paid promotion and recommendation systems in ways that circumvented their own advertising policies (Global Freedom of Expression, Columbia University, 2023). The architecture was deployed to defeat the legislation that would have made it accountable. The bill died on the order paper at the end of 2024 with no immediate prospect of revival (Internet Society, 2025).
The episode also exposes the limits of the quasi-state governance structures that platforms have developed as alternatives to external regulation. Meta’s Oversight Board, established in 2020 as an independent body to review content moderation decisions, is the most prominent example of this model (Meta, 2020). It positions the platform as a self-governing entity capable of holding its own architectural decisions to account. Yet the Oversight Board had no role in, and no jurisdiction over, the algorithmic campaign Meta ran against PL 2630. The internal accountability structure was entirely irrelevant to the exercise of architectural power that defeated the legislation that would have subjected that power to external justificatory obligations. This is precisely the limitation Forst’s principle identifies: justificatory obligations cannot be discharged by the entity that holds the power, directed at itself, on its own terms. The Brazil case makes that limitation visible not as a theoretical proposition but as a political event with measurable democratic consequences.
Indonesia and South Africa serve to complete an emerging democracies picture. Together they illustrate the range of positions within which the same fundamental gap appears. Indonesia’s Electronic Information and Transactions Law, most recently amended as Law No. 1 of 2024, combined with the Personal Data Protection Law of 2022, creates a layered regulatory framework addressing electronic transactions, content obligations and data protection that is among the most developed in Southeast Asia (Republic of Indonesia, 2022; 2024). The 2024 amendment broadened government oversight powers over electronic system providers and introduced child protection measures in digital environments. Like India’s IT Rules, however, the framework is directed entirely at content categories, data exchange and compliance obligations. The recommendation and curation logic through which Indonesian citizens encounter their political environment remains outside the accountability relationship the law creates.
South Africa represents the earliest stage of the regulatory journey among the four cases examined here. The Protection of Personal Information Act 2013, fully enforceable since July 2021, provides a GDPR-adjacent data protection framework with meaningful enforcement powers, including fines and criminal penalties for serious breaches (Protection of Personal Information Act 2013, s. 4). Section 71 of POPIA addresses automated decision making, providing that a data subject may not be subject to a decision which results in legal consequences or which affects them to a substantial degree, based solely on automated processing of personal information intended to provide a profile of that person (Protection of Personal Information Act 2013, s. 71(1)). This is significant: there must be an individual in the justification process for that process to be valid. Where exceptions apply, the responsible party must provide the data subject with sufficient information about the underlying logic of the automated processing to enable them to make representations (Protection of Personal Information Act 2013, s. 71(3)(b)). Again, this is an attempt to enforce a justificatory process. This provision requires disclosure of underlying algorithmic logic, not merely of the decision itself. Yet the provision applies only where a decision has already been taken and its effects are already legally significant. It does not reach the conditions under which citizens are constituted as political agents before any such decision occurs, and it does not create a contestable accountability relationship between citizens and the recommendation systems that shape their political environment. The Draft National AI Policy opened for public comment in April 2026 signals growing governmental awareness of algorithmic risk, identifying algorithmic bias, accountability in autonomous decision making and transparency as priorities for future legislation (Department of Communications and Digital Technologies, South Africa, 2026). South Africa is building the foundations for architectural accountability.
Taken together, these four democratic cases establish that the pattern identified earlier is not a product of the specific regulatory culture of the developed West. It is a structural feature of how democratic states engage with platform power regardless of their institutional context. The most ambitious attempt, Brazil’s PL 2630, failed in part because the architecture it sought to regulate was deployed against it. The most stringent emerging democracy framework, India’s IT Rules, has been amended repeatedly without ever reaching the architectural level. Indonesia’s layered framework follows the same content-level logic despite its sophistication. South Africa is building the foundations of a regulatory response that has not yet arrived at the architectural question. The democratic challenge posed by platform architecture is global. The regulatory gap the ninth dimension identifies is equally global. Its consequences, however, are not uniform: they are severest where the compensating mechanisms of institutional oversight, judicial independence and civil society capacity are weakest. Such weaknesses provide opportunities for platforms to weaponise their architecture against state intervention.
Alongside the issue of states wrestling control from algorithmic systems are the ability of states to engage in undemocratic activity. The most severe instances of architectural power over democratic agency are found in hybrid and autocratising states where platform architecture interacts with, or is actively aligned with, state-directed political closure. Here the absence of architectural accountability is not just a regulatory problem but a condition that accelerates democratic collapse. I use three cases to illustrate different modalities of the same fundamental problem: architecture operating without justificatory obligation in contexts where the democratic stakes are highest.
Myanmar provides one of the most extensively documented cases for the ninth dimension’s argument. The UN Independent International Fact-Finding Mission on Myanmar concluded in its September 2018 report that Facebook had been a useful instrument for vilifying the Rohingya, noting that for most users in Myanmar, Facebook was the internet (UN Human Rights Council, 2018). The Mission found that the role of social media was a significant element in the atrocities perpetrated against the Rohingya and called for senior military officials to be investigated and prosecuted for war crimes, crimes against humanity and genocide. Amnesty International’s 2022 report went further, establishing through analysis of internal Meta documents that the platform’s algorithms proactively amplified and promoted content inciting violence, hatred and discrimination against the Rohingya (Amnesty International, 2022). The architectural logic went beyond failure to remove harmful content (an act of omission). It actively constituted the political environment within which genocide became possible. An illustration of this dynamic occurred when civil society activists launched the Panzagar, or flower speech, initiative in 2014, encouraging users to post counter-speech stickers in response to anti-Rohingya content. Facebook’s engagement-based algorithms interpreted the stickers as a signal that users were enjoying the posts and further amplified the hate content they were designed to counter (Amnesty International, 2022). The architecture was constitutive of the conditions under which violence reached political scale. There was no accountability relationship between those whose democratic and human conditions were being shaped and destroyed and the systems doing the shaping.2 The architecture was not contested because it was not recognised as contestable.
Ethiopia illustrates the same pattern in a conflict context where the architectural failure is documented and its consequences traceable to an identifiable individual. The Tigray conflict was characterised from its outset by the use of Facebook to spread hate speech and incite ethnic violence (TechPolicy.Press, 2025b). Frances Haugen told the US Congress in 2021 that Facebook was fuelling ethnic violence in Ethiopia’s civil war. Amnesty International’s October 2023 report documented how Facebook’s algorithmic systems supercharged the spread of harmful rhetoric targeting the Tigrayan community, while the platform’s content moderation systems failed to detect and respond appropriately to such content (Amnesty International, 2023). The report established that these architectural failures contributed directly to the killing of Professor Meareg Amare, a Tigrayan chemistry professor at Bahir Dar University, who was targeted in Facebook posts on 3 November 2021 containing identity and location details, with false claims that he was a supporter of the Tigrayan People’s Liberation Front. His son told Amnesty: “I knew it would be a death sentence for my father” (Amnesty International, 2023). The posts were algorithmically amplified before any moderation response was triggered. The Meta Oversight Board’s engagement with an Ethiopian case in October 2022, in which it upheld the removal of a post from the Tigray Regional State’s Communication Affairs Bureau, illustrated simultaneously the potential and the limits of internal governance: the Board’s jurisdiction extended to individual content decisions, not to the algorithmic architecture that determined the reach and amplification of content across the platform as a whole (Global Freedom of Expression, Columbia University, 2022). The governing logic of the system remained outside any accountability relationship.
Nigeria presents a third and differently structured modality. Where Myanmar and Ethiopia illustrate architecture operating without accountability in contexts of communal and ethnic violence, Nigeria illustrates what happens when a platform applies its own content rules to a head of state and the state responds with architectural suppression. On 5 June 2021, Nigerian authorities directed internet service providers to block access to Twitter after the platform deleted a tweet by President Muhammadu Buhari for violating its rules on hateful conduct. The government’s justification was the platform’s persistent use for activities capable of undermining Nigeria’s corporate existence, a formulation sufficiently vague to encompass any political content the government found inconvenient (Electronic Frontier Foundation, 2022). The suspension lasted 222 days and was lifted in January 2022 after Twitter agreed to register a legal entity in Nigeria and comply with local content requirements. The ECOWAS Community Court of Justice subsequently ruled the suspension unlawful as a violation of freedom of expression under the African Charter on Human and Peoples’ Rights and the International Covenant on Civil and Political Rights (SERAP and Others v Federal Republic of Nigeria, ECW/CCJ/APP/23/21, 2022). The Nigeria case is significant for my argument in a specific way: it shows that the absence of architectural accountability runs in both directions. Platforms can exercise architectural power over citizens without justificatory obligation and states can exercise suppressive power over platforms without justificatory obligation to the citizens whose democratic information environment is thereby destroyed. In neither direction does the accountability relationship the ninth dimension requires exist.
Across these three cases, a pattern distinct from those identified in the Developed West and Emerging Democracies sections emerges. In the former, architectural accountability is displaced by regulatory categories that address the phenomenal surface. In the latter, the same displacement operates with fewer compensating mechanisms. In states where democracy is under pressure or actively retreating, the absence of architectural accountability is not a displacement but a condition of political closure. The architecture operates, is suppressed or weaponised and in each case the citizens whose conditions of political agency are at stake have no standing to contest it. The ninth dimension identifies the gap that exists in sophisticated regulatory frameworks and the democratic floor below which the absence of any such framework allows societies to fall.
Platform-side regulatory obligations, even where they approach the architectural level, are necessary but not sufficient conditions for the kind of accountability the ninth dimension requires. Forst’s principle of justification requires there is somewhere to direct a justificatory claim and that those making the claim have the capacity to form and direct it. A citizen who has never been taught to recognise algorithmic curation as a condition of their own reasoning is doubly disadvantaged: they cannot identify the structural condition and they cannot name an addressee for a claim about it. The question of citizen-side capacity is a precondition for the vertical justificatory accountability the ninth dimension requires to be meaningful in practice.
The UK’s approach to this precondition is partial but instructive. The GCSE syllabus, such as the OCR Computer Science specification, requires all students to engage with the ethical, legal, cultural and environmental impacts of digital technology as a mandatory assessed component, including the purposes of data protection legislation and the impacts of digital technology on wider society (OCR, 2024a). This represents a baseline state recognition that citizens require some capacity to engage critically with the digital conditions of their own lives. At A Level, the OCR Computer Science specification (H446) goes further, requiring substantive engagement with automated decision making, artificial intelligence, algorithmic bias and accountability and the question of who bears responsibility when an algorithm makes a consequential decision (OCR, 2024b). These provisions embed a justificatory logic at the level of secondary education: students are expected to understand not only what digital systems do but who is responsible for what they do and on what grounds that responsibility can be challenged. Statutory grounding for this educational function sits within Ofcom’s media literacy duties under section 11 of the Communications Act 2003, which requires Ofcom to promote and facilitate the development of media literacy among members of the public (Communications Act 2003, s. 11). The Online Safety Act 2023 extended and strengthened these duties, placing specific obligations on Ofcom to produce a media literacy strategy and to take steps to improve public understanding of the nature and impact of regulated content (Online Safety Act 2023b, s. 143). The statutory embedding of media literacy distinguishes the UK’s approach from purely voluntary or market-led educational initiatives and gives it a normative significance for the ninth dimension’s argument.
What these educational and statutory provisions do not yet do is address the architectural level at which the ninth dimension is directed. The OCR specifications, for example, teach students to recognise algorithmic bias and to understand data protection law. They do not yet give students, or the citizens they will become, the structural standing to contest the governing logic of the systems that curate their political environment, or to direct justificatory claims at the persons or bodies responsible for those systems. Ofcom’s media literacy strategy addresses how citizens engage with content, but does not address how citizens might contest the architectural conditions under which that content is selected and prioritised. The citizen-side precondition is being partially addressed. The architecture-side obligation identified by the ninth dimension remains largely unmet. The gap between what existing provision supplies and what architectural accountability would require on the citizen side is precisely what the research agenda developed next addresses.
Across all four registers I have examined, a consistent pattern emerges. The principle that private actors exercising power over the public sphere attract democratic obligations is not new. It is embedded in media plurality law, as the Telegraph process demonstrates; in data protection regulation, as GDPR and POPIA illustrate; in content governance frameworks, as the OSA, the DSA and the IT Rules 2021 confirm; and in statutory media literacy duties, as Ofcom’s obligations under the Communications Act 2003 and the Online Safety Act 2023 establish. What has not been achieved, in any democratic context, is the application of that principle at the architectural level: the level at which the conditions of political agency are constituted before any observable democratic activity takes place.
In the developed West, the principle is recognised and enforced at the level of ownership, content and data exchange, but consistently displaced from the architectural level. The Telegraph process evidences that the state will act on plurality grounds even at economic and diplomatic cost, yet offers no equivalent mechanism for contesting the governing logic of recommendation systems that shape political reality at far greater scale. GDPR regulates the exchange of data but leaves intact the architectural logic that determines what individuals encounter as political reality before any data exchange occurs. The OSA and DSA, the most ambitious frameworks yet produced, reach further than anything before them but still fall short: the TikTok preliminary findings of February 2026 represent the furthest point any regulatory framework has reached and the accountability relationship they create runs between platform and regulator rather than between platform and citizen. Canada demonstrates that platforms will deploy their architectural power to neutralise legislation directed at the content level, while Brazil shows that even legislation explicitly targeting the architectural level can be defeated by the architecture it seeks to regulate.
In emerging democracies, the same displacement operates with fewer compensating mechanisms and in some cases with greater regulatory intensity directed at the wrong object. India’s framework is more stringent, in many respects, than anything the developed West has produced, but equally silent on the architectural level. Brazil came closest to addressing the architectural question directly only to be defeated by the architecture it sought to regulate. Indonesia and South Africa illustrate respectively a sophisticated content-level framework and the earliest stage of a regulatory journey that has not yet arrived at the architectural question.
In states where democracy is under pressure or retreating, the absence of architectural accountability is not a displacement but a condition of political closure. Myanmar demonstrates that platform architecture can actively constitute the conditions under which genocide becomes possible. Ethiopia demonstrates that those consequences can be traced to identifiable individuals. Nigeria demonstrates that the accountability deficit runs in both directions: platforms exercise architectural power over citizens without justificatory obligation and states suppress platforms without justificatory obligation to the citizens whose democratic information environment is thereby destroyed.
The citizen-side dimension, examined through the UK’s educational and statutory provision, confirms that the gap is not only a platform-side or state-side failure. Even where states are building the citizen-side preconditions for justificatory accountability through curricula and media literacy duties, those provisions address how citizens engage with content rather than how they might contest the architectural conditions under which that content reaches them.
The ninth dimension identifies this consistent gap across varying states of government and, crucially, how education can be used to tackle some of the epistemic requirements. It does not offer a specific regulatory solution. That is the task of the research agenda the final stage develops. What I have established through this analysis is that the gap is real and that it is structural rather than incidental, continuing to cause deadly harms. The displacement of democratic principle from the architectural level is not a recent failure. It is a structural feature of how states have engaged with private power over the public sphere, now made more consequential by the scale and reach of the architecture through which that power operates.