A Comparative Study of Regulating the Filtering of Cyberspace in the US, the EU and China; Proposals for Policymaking in Iran

The crucial role of cyberspace attracted the special attention of the governments in different countries, which consider it both as a challenge and an opportunity. One of the key policies and preventive measures adopted concerning the challenges posed by the cyberspace is it regulation. In fact, there are only a few states have not taken any steps in regulating their cyberspace. This paper seeks to demonstrate a set of policy proposals for the Islamic Republic of Iran through the study of three leading but different precedents in regulating the cyberspace, including the United States, the European Union, and China. This study employs a descriptive-analytical model, which recommends placing the main investment in and concentration on the final user, employing economic strategies, special attention to governmental and public institutions, prioritizing content removal over blocking, negotiating an agreement with Foreign Service providers, drafting a content rating system, and using international capacities for cooperation.Accordingly, the final policy proposals for the Islamic Republic of Iran would be decentralization, user-oriented decisions, prioritizing removal over blocking, and monitoring over filtering.