CRIMINAL LIABILITY FOR PAID DISINFORMATION IN THE DIGITAL WORLD: A COMPARATIVE STUDY BETWEEN UAE LAW AND THE EUROPEAN DIGITAL SERVICES ACT (DSA)

Background: With the rapid digital transformation and the extensive use of social media platforms, disseminating various forms of harmful digital content—including illegal content and false or misleading information, particularly when financially incentivised—has become a pressing global challenge. These practices threaten digital trust and pose significant risks to societal stability. Despite the growing legal efforts to address these crimes, a unified and comprehensive legal framework remains lacking. This study examines the criminal liability associated with paid disinformation in the digital world, comparing the legal approach under UAE law with the European Digital Services Act (DSA). While the UAE has enacted specific provisions targeting the monetisation of disinformation, the European framework primarily focuses on the responsibilities of digital platforms without explicitly addressing individual actors involved in such activities. Methods: This study employs a comparative legal analysis, focusing on relevant legislative provisions in both jurisdictions. The research applies an analytical and comparative approach, examining Article 55 of the UAE’s Anti-Rumours and Cybercrime Law, which explicitly criminalises financial incentives for disseminating illegal content. In contrast, the study assesses the European DSA, which primarily regulates platform accountability but lacks direct provisions on individual criminal liability for paid disinformation. The analysis also incorporates doctrinal legal research and case studies to highlight the effectiveness and limitations of each legal system in combating this issue. Results and Conclusions: The study finds that UAE law provides a more structured and detailed legal framework for addressing paid disinformation, offering clear criminal sanctions for individuals engaged in such acts. Conversely, the European DSA adopts a broader regulatory approach, focusing on institutional oversight without directly addressing the criminal liability of individuals involved in monetised disinformation. The research recommends that European legislation adopt a more specific model to combat these crimes, integrating direct criminal accountability alongside platform regulation. Additionally, the study emphasises the need for enhanced international cooperation and regulatory harmonisation to strengthen digital transparency and mitigate the risks posed by financially motivated disinformation.