The digital era has acted as a catalyst for renewed attention to anti-press tactics. Journalists around the world endure threats, abuse, and disinformation campaigns perpetrated on social media platforms, below-the-line comments on newspaper websites, and other online forums.

The key questions this article seeks to answer are: to what extent do states have positive obligations to protect journalists from online abuse per the ECHR? And do those obligations extend to the regulation of online platforms?

It highlights that journalist safety is protected in the “effective system of protection” and “without fear” principles (in Dink and Ismayilova) but that the ECtHR has not adequately applied those principles to situations of online abuse targeting journalists. It argues that the Court should apply the “without fear” principle, and, in cases concerning abuse targeting journalists, the “effective system of protection” principle, when adjudicating cases concerning platform liability in the Delphi/Sanchez/Google line of cases.

It should likewise apply those principles in prospective cases involving state efforts to regulate or set standards on online platforms, including the UK’s Online Safety Act and the EU’s Digital Services Act and the European Media Freedom Act.

This article is forthcoming in the European Human Rights Law Review (2026).

Ricki-Lee Gerbrandt

r.gerbrandt@ucl.ac.uk