This policy brief is accompanied by an in-depth research paper analyzing existing scholarship and an event held in December 2024 on social media and democracy in Uganda.

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ganda's 2026 elections present an opportunity to not just refine but revolutionize how social media can support democratic participation. Platforms like YouTube, WhatsApp, and X have become essential tools for information dissemination, civic engagement, and activism. With 78% of Uganda’s population under 30 years old, the digital space is a significant venue for youth-driven democratic participation. Yet, these opportunities are overshadowed by amplified challenges such as disinformation, data misuse, hate speech, and restrictions on digital freedoms. These issues are exacerbated in an environment where existing legal frameworks and regulatory mechanisms struggle to keep pace with the complexities of digital campaigning. 

This policy brief analyzes Uganda's legal frameworks, including the Data Protection and Privacy Act (2019), Electoral Commission Act, Uganda Communications Act (2013), and Computer Misuse Act (2022), assessing their ability to address ethical digital campaigning and preserve digital freedoms.¹ The brief juxtaposes these frameworks against global best practices and calls for actionable steps to enforce the ethical use of social media in political campaigning and preserve digital freedoms to ensure democratic integrity in Uganda's evolving digital landscape. 

Policy Analysis 

Data Protection and Privacy Act (2019) 

The Data Protection and Privacy Act aims to protect individual privacy by regulating personal data collection, processing, and use. Key provisions, such as Section 7, require explicit consent for data processing, while Section 15 emphasizes data accuracy and security. However, the Act's exemptions for national security and public duties (Section 7[2]) create vulnerabilities that could allow data misuse during elections. Additionally, while the Act broadly ensures data transparency, it lacks explicit provisions regulating the use of personal data in political campaigning, such as targeted advertising or disinformation. 

When benchmarked against international standards, such as the European Union's General Data Protection Regulation (GDPR), Uganda's Act must include more transparency in using personal data for electoral purposes.² The GDPR mandates disclosures regarding how political data is collected, processed, and shared—a critical gap in Uganda's legislation. 

Electoral Commission Act 

The Electoral Commission (EC) is legally mandated under Section 12 of the Act to ensure free and fair elections and to promote civic education. While these provisions provide the Commission with broad regulatory authority, the Act does not include specific guidelines for managing digital campaigning or regulating disinformation. For example, the Act must be more active in monitoring and addressing disinformation campaigns or enforcing transparency in online political advertisements. 

Lessons from Uganda's 2021 “scientific elections,” a term used to describe the elections held during the COVID-19 pandemic with strict health and safety measures, underscore these gaps. During this period, misinformation and disinformation proliferated across digital platforms, undermining trust in the electoral process. Although the EC has the authority to expand its role in regulating online campaigns, there is no evidence of detailed implementation or enforcement mechanisms addressing digital content. 

Uganda Communications Act (2013) 

The Uganda Communications Act empowers the Uganda Communications Commission (UCC) to regulate communication services and enforce content standards. Sections 31 and 32 outline provisions to curb harmful or misleading content, offering a framework to address disinformation. However, the Act does not explicitly address political campaigning on social media platforms, leaving a critical gap in regulating digital electoral activities. 

Moreover, enforcement challenges limit the UCC's capacity to effectively oversee global platforms like Facebook, X, and YouTube. Unlike the European Union’s Code of Practice on Disinformation, which outlines collaboration frameworks with social media companies, Uganda's regulatory approach needs mechanisms to engage these platforms in combating disinformation.³ 

Computer Misuse Act (2022) 

The amendments to the Computer Misuse Act strengthen the legal framework against cyber threats, including misinformation and hate speech. Section 26A criminalizes hate speech, while Section 26C prohibits transmitting malicious information through digital platforms. However, the Act's broad definitions risk infringing on freedom of expression, mainly when applied during politically sensitive periods. 

Furthermore, while the Act holds individuals and organizations accountable for social media misuse, it lacks initiative-taking provisions for educating the public or fostering digital literacy—essential components in mitigating the spread of harmful content. 

Internet Shutdowns and Digital Freedoms 

The government's frequent internet shutdowns during election periods, such as the five-day nationwide shutdown during the 2021 general elections, significantly undermine digital freedoms. While such shutdowns are justified on national security grounds, evidence from 2021 showed how they disrupted economic activities, education, and healthcare, to say nothing of the apparent disadvantages opposition party campaigns incurred. NetBlocks estimates the financial cost of the 2021 shutdown to be $10 million, illustrating the broader societal impact of these actions.⁴ The United Nations Educational, Scientific and Cultural Organization (UNESCO) Internet Universality Indicators, which promote the principles of human rights, openness, accessibility, and multistakeholder participation in the development and use of the Internet, reflect the broad international consensus that such disruptions undermine freedom of expression and access to information.⁵ 

Recommendations 

Election and Communication Regulators in Uganda 

The 2026 election roadmap is an opportunity to include clear guidelines for political campaigning on social media platforms, voter education initiatives, and timely, accurate dissemination of election-related information. The Electoral Commission (EC), Uganda Communications Commission (UCC), and the National Information Technology Authority Uganda (NITA-U) should establish a “Digital Election Integrity Task Force" that is fully developed and operational at least 12 months before the 2026 elections to develop and enforce a framework for monitoring and regulating social media use during political campaigns. This framework should adopt key elements of the European Union’s Code of Practice on Disinformation, including transparency reporting by platforms and collaboration with fact-checking organizations. With a long-term goal of creating an independent oversight body to function as a multi-stakeholder initiative, including representation from civil society, regulators, and the private sector, to balance enforcement with preserving digital freedoms.  

Platform Accountability  

A collaboration between Uganda’s Electoral Commission (EC) and social media platforms is essential to ensuring transparency and accountability in political campaigning ahead of the 2026 elections. To achieve this, the EC, with support from the Uganda Communications Commission (UCC) and the National Information Technology Authority Uganda (NITA-U), should initiate direct engagements with Meta, X, YouTube, and TikTok within the next six months. This can be done by formally reaching out to the regional public policy teams of these platforms through government-led diplomatic channels, leveraging existing contacts within these companies' Africa-based operations. The EC should negotiate Memoranda of Understanding (MoUs) with each platform to ensure: 

1. Mandatory political ad transparency, requiring platforms to label political content and disclose funding sources. 
2. Dedicated reporting mechanisms, providing the EC with direct access to platform representatives for flagging election-related misinformation. 
3. Strict enforcement of platform-specific election integrity policies, ensuring global standards apply to Uganda’s elections. 

The recommended Digital Election Integrity Task Force should oversee the execution of these agreements and track platform compliance. These measures will ensure that social media companies proactively regulate political content before the peak of the election season. 

Meta’s collaboration with the EC should focus on applying its guidelines for political ads and page verification to Ugandan political entities.⁶ This can help identify and label campaign content, ensuring it is clearly marked as political communication and accompanied by source disclosures. These measures will enhance voter trust and align with Meta’s global standards for advertiser authorization. Similarly, X and TikTok should ensure that political content is clearly marked and labeled under the X political campaigning rules and TikTok’s Government, Politician, and Political Party Accounts (GPPPAs) guidelines, enhancing transparency in political campaigns shared on their platforms.⁷

YouTube’s collaboration with the EC should center on popularizing its policies designed to safeguard election integrity and promote responsible political discourse through clear guidelines addressing voter suppression, candidate eligibility, incitement to interfere with democratic processes, and manipulated or misattributed content, particularly within Uganda's diverse linguistic landscape.⁸ Given that much of the misleading content on YouTube is in local languages, the EC’s involvement will empower users to assess such material critically, reduce its influence, and report it to the platform for further action. This approach can mitigate the impact of harmful content and build user awareness and confidence in the platform’s guidelines. 

US Policymakers 

As part of the US’ investments in technology and innovation, the US should consider establishing a Digital Innovation Fund.⁹ This initiative would prioritize public awareness campaigns to educate Ugandans on identifying and countering disinformation, with an emphasis on critical thinking and fact-checking before sharing information. Leveraging existing civil society networks across 146 districts, these campaigns can reach diverse communities and build a more digitally resilient electorate. This effort can be complemented by engaging Uganda’s youth—empowering young leaders, bloggers, and content creators with the skills to use their platforms responsibly with advanced tools for responsible reporting, countering the rapid spread of disinformation, and promoting ethical online behavior. 

The US should also facilitate structured dialogue between Ugandan stakeholders and global platforms like Meta, X, YouTube, and TikTok to promote policy implementation, ensuring alignment with Uganda’s unique digital and democratic context. Moreover, investment in internet infrastructure development in underserved regions will expand digital access and amplify the impact of peer-driven fact-checking initiatives, fostering greater inclusivity and civic engagement. 
 

1. Uganda Legal Information Institute. https://ulii.org.
2. European Union, “General Data Protection Regulation (GDPR).” https://gdpr-info.eu.
3. European Union, “Code of Practice on Disinformation” 2022. https://commission.europa.eu/strategy-and-policy/priorities-2019-2024/new-push-european-democracy/protecting-democracy/strengthened-eu-code- practice-disinformation_en.
4. Association for Progressive Communications. “Uganda 2021 General Elections: Internet Shutdown and Its Ripple Effects.” Association for Progressive Communications, 2021. https://www.apc.org/en/news/uganda-2021-general-elections-internet-shutdown-and-its-ripple-effects.
5. United Nations Educational, Scientific and Cultural Organization (UNESCO) Internet Universality Indicators. https://www.unesco.org/en/internet-universality-indicators.
6. Meta, “Ads About Social Issues, Elections or Politics.” https://transparency.meta.com/en-gb/policies/ ad-standards/siep-advertising/siep/.

7. X, “Ads Policies, Political Campaigning” https://business.x.com/zh-cn/help/ads-policies/ads-content- policies/political-campaigning.

8. YouTube. “How YouTube Responsibly Supports Elections and Civic Engagement.” Accessed December 2024. https://www.youtube.com/howyoutubeworks/our-commitments/supporting-political- integrity/.
9. US Embassy in Uganda. 2023 Report to the Ugandan People. Kampala: US Embassy, 2023. https://ug.usembassy.gov/wp-content/uploads/sites/42/2023-Report-to-Ugandan-People.pdf.