Who Controls the Digital Agora? Social Media Governance in the European Union, United States, and Turkey

This study explores how the European Union, the United States, and Turkey regulate social media in the face of disinformation, political polarisation, and the erosion of democratic norms. It argues that regulatory responses are not solely technical adjustments but reflect deeper ideological orientations, revealing whether states conceive the digital sphere as a deliberative public arena or as a domain to be governed through security and control logics. Using qualitative document analysis, the research examines 38 key policy and legal documents issued between 2016 and 2024. A thematic and comparative framework is employed across five dimensions: platform accountability, content governance, data privacy, enforcement mechanisms, and user rights. The analysis is informed by Habermas's theory of the public sphere, Foucault's concept of governmentality, and broader media governance scholarship. Findings indicate that the EU promotes a rights-based, deliberative model; the U.S. advances a market-oriented logic privileging platform autonomy, while Turkey exhibits a hybrid regime marked by formal pluralism and increasing state intervention. These divergent models not only reflect contrasting political cultures but also reveal how digital governance becomes a key site where state power, democratic values, and technological agency intersect.