Dear UNESCO,

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We have been following your efforts to set out Guidelines for Regulating Digital Platforms with increasing alarm.

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As representatives of civil society from across the Asia Pacific region, we have been at the forefront of the very type of abuse these guidelines set out to address. We know better than most the harmful role that tech platforms can play. We also understand how government overreach and over-regulation can result in even greater harm. In our region, these harms often work hand-in-hand, with authoritarianism on the rise and governments turning to tech platforms to advance their undemocratic agendas.

Rather than rein in big tech and safeguard human rights, we fear that the guidelines will:

1. Rubber stamp local over-regulation

In our region, local regulation is regularly used to control and intimidate citizens. In practice, these guidelines will be used to justify increased regulation rather than better regulation.

2. Embolden authoritarian regulators

Our regulators lack independence, capacity and human rights commitments. Empowering these regulators means handing over more power to undemocratic processes.

3. Incentivise platforms to comply with illegitimate government requests

Companies are already caving to our governments regardless of the impact on human rights. The proposed UNESCO model risks accelerating this slide, providing companies greater cover to comply.

It does not appear that UNESCO has considered safeguards to protect against these significant risks.

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We have raised our concerns with UNESCO, as have many of our peers - to no avail. Our voices are not getting heard.

We therefore urge UNESCO to:

1. Pause the current timeline.

2. Undertake an independent human rights impact assessment of the guidelines, inclusive of views and perspectives from civil society in authoritarian contexts.

We stand ready to engage with this assessment and explore safeguards and alternatives.

In anticipation of your response.

Sincerely,󰎉

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