Hate speech: Comparing the US and EU approaches (Think Tank, European Parliament)

Distinct legal traditions underlie the US and EU’s differing approaches to regulating online platforms: the US provides nearly unrestricted free speech under the First Amendment, while the EU permits limitations to safeguard the public good and makes hate speech directed at protected groups illegal. The emphasis has moved to platform responsibility due to the emergence of social media. The EU mandates that platforms remove hate speech after being alerted, in contrast to the US, which does not impose any removal responsibilities on businesses. Additionally, both areas depend on community norms that allow platforms to self-regulate.

https://www.europarl.europa.eu/thinktank/en/document/EPRS_BRI(2025)772890 (News)
https://www.europarl.europa.eu/RegData/etudes/BRIE/2025/772890/EPRS_BRI(2025)772890_EN.pdf (Briefing)