Introduction

Digital technology is having a great impact in the continued evolution of a digital economy around the world. The growth of digital technologies is resulting in the digitalisation of processes and systems by governments to provide efficient and fast delivery of services to citizens and people around the world (Hulko et al., 2025). As digital infrastructures become increasingly embedded across sectors of the economy, they are no longer merely tools but rather socio-technical systems that shape practices and innovation (Tilson, Lyytinen & Sørensen, 2010; Star and Ruhleder, 1996). They are integral to the way companies, governments and societies function and access information, underpinning platforms and institutions alike (Plantin et al., 2018; Edwards et al., 2009).

This transformation alludes to the growing need for digital autonomy, whereby nations seek to assert control, ownership over digital tools, data and storage (Castells, 2010). This has contributed to the emergence of digital sovereignty which has been defined as “the ability of a state or region to manage and regulate its own digital infrastructure, data management and technological development, while protecting the rights and interests of its citizens in the global digital ecosystem” (Hulko et al., 2025). This is not a neutral concept but has been contested by competing political agendas; for example, the Snowden revelations in June 2013 where the Guardian disclosed thousands of classified documents, which uncovered several mass surveillance programmes run by the National Security Agency (NSA) in the United States (Von Solms et al., 2015). This indicated the breach of citizen privacy and misuse of data however, with a political agenda that the government justified as security reasons. This paper is a comparative study of the U.S. and China perspectives on digital sovereignty and how it has contributed to severing political and international relations between the two nations. The discussion will focus on security, data localisation, technological advancement, rights and freedoms of citizens and global governance as depicted within the two countries. 

Literature Review

This literature review explores the different ways that countries navigate digital sovereignty with a focus on the U.S. and China. The literature will highlight each country’s dynamics, their strategies politically and technologically, and how they compare and or contrast. In this paper, we cover: firstly, technological advancements and sovereignty between the U.S. and China; secondly, the unique approaches of each country; and finally, human rights, and digital citizenship.

Technological Advancements and Sovereignty Dynamics in the U.S. and China

In the United States, digital sovereignty is mainly viewed as protecting American technology and ensuring the country stays a global leader (Roberts et al., 2023). The U.S. policy tools are used to express digital sovereignty such as cybersecurity statutes, export controls on technology and regulatory scrutiny of major tech firms. A prominent example is the CHIPS and Science Act of 2022, which appropriates around US$52.7 billion to bolster domestic semiconductor research and manufacturing (Ezell & Bean, 2024; Wikipedia, 2025). Semiconductors – tiny chips powering everything from smartphones to aeroplanes – are central to leading technological advancement (Ezell & Bean, 2024). This shows that U.S. digital sovereignty is predominantly about staying competitive and safe, while keeping the internet mostly open for trade and communication (O’Neil, 2023). 

While the United States takes on a market-driven and security-focused path to digital sovereignty, China’s strong government controls shape its digital future. China has a stricter view of digital sovereignty, often called cyber sovereignty (Zeng, 2018; Creemers, 2020). For example, the Cybersecurity Law of 2017 requires important data to stay inside China and not be stored in other countries (Creemers, 2017). China also has plans like Made in China 2025, which focuses on building its own advanced technology such as robots, artificial intelligence (AI) and semiconductors (Hong, 2017). Beyond its borders, China promotes the Digital Silk Road, part of its Belt and Road Initiative, by selling Chinese-built internet and communication systems to other countries (Shen, 2018). 

Comparing the U.S. and China shows two different approaches to technology and sovereignty. Around the world, technology has been advancing quickly, reshaping societies, economies and politics on a global scale, with the International Telecommunication Union (ITU) reporting that about two-thirds of people on Earth had access to the internet, though poorer countries are still behind (ITU, 2023). The rise of mobile broadband (fast internet on phones) and cloud computing (storing and using data online instead of only on personal devices) has made communication and work easier for billions of people (International Telecommunication Union, 2022; Marston et al., 2011). Artificial intelligence is also transforming sectors like healthcare, finance and education (OECD, 2020). Studies show that the need for data is just as important as shipping goods like oil or cars for trade (Manyika et al., 2016). However, the benefits are not equal everywhere: some countries have fast digital progress, while others are slowed down by weak internet and high costs (OECD, 2020). Researchers argue that most new technology is centred in North America, Europe and East Asia, leaving other regions behind (Qureshi, 2022).

Due to this, “digital sovereignty” has become important, and countries want to decide how their data is accessed, stored and used to protect citizens, innovations and their industries (Milan & Treré, 2019). These strategies reflect concerns of privacy, national security and economic competitiveness (Bradford, 2020). Looking at these global trends, it becomes clear that the U.S. has played a major role in pushing technological progress forward. The United States has been a leader in technology for decades; in the 1960s, the government created DARPA (Defense Advanced Research Projects Agency), which helped fund the early internet (Mowery, 2010). Today, American universities, research centres and private companies drive progress in artificial intelligence, cloud services and semiconductors (O’Neil, 2023). The U.S. has also built exascale supercomputers – machines so powerful they can do more than a billion calculations each second (Shalf, 2020). These computers help with research in science, weather prediction and national security. At the same time, the U.S. faces debates about the power of its biggest tech companies, such as Google, Microsoft and Amazon (O’Neil, 2023). Other scholars warn that if too few companies control most digital services, it could harm competition and give them too much influence (Stucke, 2021). Overall, the U.S. approach to technology combines government support, private business innovation and new laws to secure supply chains. This balance allows the U.S. to keep its leadership role, but it also creates challenges about how to regulate companies and protect national security.

China has rapidly caught up and, in some areas, even pulled ahead. Its rise as a global tech powerhouse shows how state planning and massive investment can reshape the global balance of innovation (Zenglein & Holzmann, 2019). China has developed its technology over the last two decades, mostly through government planning and strong domestic companies (Lee, 2018). The Made in China 2025 programme aims to upgrade industries like robotics, semiconductors and electric vehicles so China does not depend on foreign technology (Zenglein & Holzmann, 2019). Research shows this plan has also encouraged “green technology”, meaning more energy-efficient and environmentally-friendly industries (Li, 2020). China also promotes its influence abroad through the Digital Silk Road, which builds internet infrastructure, fibre-optic cables and 5G networks in partner countries (Shen, 2018). This helps spread Chinese technology and strengthens global trade connections. Another major achievement is the BeiDou Navigation Satellite System, which became fully operational in 2020. BeiDou is China’s own version of GPS which gives China independence in global navigation and security (Yang et al., 2021).

Within China, the government enforces its idea of cyber sovereignty through the Great Firewall. This system blocks foreign websites such as Google and Twitter, while supporting the use and adoption of Chinese platforms like WeChat and Baidu (Creemers, 2017). While this gives the government control and stability, it also limits free access to information outside China (Hong, 2017). In short, China’s advances are not only about building new products but also about creating a full digital system that is self-reliant and extends its power and autonomy beyond its borders (Zenglein & Holzmann, 2019).

Different countries handle digital technology in very different ways, often depending on whether their government is more democratic or authoritarian. In democratic countries like the United States, the focus tends to be on protecting citizens’ digital rights, such as privacy and freedom of expression, even though governments still monitor some online activity for security reasons (Abbas et al., 2025). On the other hand, authoritarian countries like China often prioritise control and surveillance over individual digital rights (Chin & Li, 2021). The government closely monitors internet use, filters content and enforces strict rules on online speech to maintain social stability and political control (Chin & Li, 2021). For example, platforms like TikTok and WeChat must comply with government regulations that allow authorities to track data and manage information flows (Su & Tang, 2023).

Data Localisation as a Dimension of Digital Sovereignty

THE CHINA STRATEGY

Data localisation is defined as “a policy implemented by a state that requires entities to store data within its sovereign territory” (Cambridge University Press, 2024). For data localisation to work, technological companies must comply with local data collection laws by ensuring the personal data of its users or customers is stored within a country’s borders (Cambridge University Press, 2024). In China, the country has several localisation laws, including the Cybersecurity Law which dictates how enterprises manoeuvre networks and control data usage (Hong, 2017), and the Data Security Law and Personal Information Protection Law, which regulate how data is classified, processed and protected both within and beyond China’s borders (Roper, 2025). It is a strategy implemented with national security in mind as localising data can alleviate the risk of “foreign surveillance, cyber-attacks and unauthorised data access, safeguarding national sovereignty and sensitive information” (El Kadi, 2025).  This strategy may be counter intuitive as Wayan Vota (2024), in his article on digital localisation and politics, argues that data would be infinitely safer in international centres, protected by thorough physical and digital security measures, than in unsecure physical government locations.

An economic dimension also plays an important role in driving data localisation efforts. Many countries view the restriction of cross-border data flows as a strategic tool that “reduces dependency on foreign providers” and limits international competition (El Kadi, 2025). By keeping data within national borders, governments aim to foster the growth of local businesses and service providers, create high-skilled jobs and stimulate innovation within domestic technology industries (Zenglein & Holzmann, 2019). These policies are framed as part of economic development strategies intended to build competitive, self-sustaining digital economies (Vota, 2024). When it comes to cross-country negotiations, data localisation can also serve as a significant asset for countries that have implemented it. Vota continues to assert that by controlling and housing their own data, these nations gain leverage in international discussions on trade, privacy standards and digital governance. The ability to manage and secure domestic data infrastructure not only enhances national security but also strengthens a country’s bargaining position in shaping the global digital economy (Segal, 2021). However, many developing countries may face significant barriers when it comes to hosting their own data due to factors such as unreliable power supply, limited digital infrastructure and the cost of setting up a data centre (Folashadé, 2024); for example, Africa “accounts for less than 1% of the world’s data centre capacity” (Goko, 2025). Despite the struggles, countries have started drafting data protection laws and relying on external help, like the World Bank Organization in its aid to the continent of Africa through financial interventions (Goko, 2025) and the United Nations in its guidance on handling data responsibly (World Privacy Forum, 2020).

Keeping abreast of China’s approach to digital sovereignty, one would argue that it is grounded in the principle of digital authoritarianism – “the use of technology by authoritarian governments not only to control, but to shape, the behaviour of its citizens through surveillance of usage and censorship” (Khalil, 2020). The result of digital authoritarianism can be widespread misinformation, the violation of human rights such as freedom of expression and privacy, and consolidation of political control (Feldstein, 2019; Diamond, 2021). It creates a climate of fear and a significant reduction in the civic space for open debate and participatory decision-making (Repnikova, 2017). 

In China, digital authoritarianism is exercised through strict regulation and data localisation, with the goal of prioritising political stability and regime security (Creemers, 2020; Segal, 2020). An example of the China strategy is the “Social Credit System”, a complicated and evolving initiative aiming to monitor and gauge the trustworthiness of mostly businesses and government entities, but occasionally individuals (Dai, 2018; Liang et al., 2018). The initiative was formed in 2002 under President Jiang Zemin, but traces back to the 1990s originally meant as a “self-enforcing mechanism to discipline market behaviour in the absence of a functional legal system” but evolving to include broader social and moral dimensions (Cambridge University Press, 2023). According to the Cambridge University Press (2023), the system is undergoing modifications and aims to enhance trust within society and companies, by discouraging corruption, scams and tax evasion, and to promote responsible decision-making in accordance with the Chinese Communist Party values.

The social credit system is not a widespread digital framework; different cities, local governments and companies have their own policies, all under different names (Kobie, 2019). The system, “still a work in progress and far from [a] nationwide implementation”, works by collecting data from diverse platforms, including online banking apps, financial records and government records, and accumulating them for analysis (Feng, 2022). A score is then created for individuals and entities, either in a letter grade or numerical score, who then receive rewards like loan waivers or punishments like limited transportation access (Kobie, 2019). Local governments have been more ambitious in their efforts and have piloted more advanced versions, meshing financial credit scoring with social and moral evaluation to regulate behaviour and promote government objectives (Yu, 2023). 

Outside of the country, China holds a significant influence over international digital spaces. A prominent example is TikTok, the viral video-sharing app owned by Chinese tech company ByteDance, which has rapidly become one of the most downloaded apps globally and has raised concerns and debates over data governance, security and cultural influence (Kaye, 2022; Chen et al., 2022). Although TikTok operates internationally and has made efforts to present itself as a global platform with localised operations, concerns persist about the Chinese government’s indirect influence over the app (Scharre, 2023). 

There have been numerous instances of political censoring, including posts under #GeorgeFloyd and #BlackLivesMatter, a viral video criticising Chinese treatment of Muslims, clips of “tank man” (the anonymous protester who stood in front of a column of tanks during the 1989 Tiananmen Square massacre in Beijing) and content relating to the Houston Rockets basketball team, whose general manager has publicly sided with Hong Kong protestors (Scharre, 2023). It is important to note that TikTok is not available in mainland China. Instead, Chinese users have access to Douyin, its counterpart that is regulated separately and is also developed by ByteDance (Associated Press, 2023). These incidents point to a broader concern that China’s influence can shape or censor political narratives even on platforms used predominantly outside of China (Chen et al., 2022). 

In the United States, there have been fears over data privacy following arguments that TikTok could be used as a tool of surveillance by the Chinese government and the possibility that data of American users could be accessed (New York Times, 2025). The New York Times reported that American officials insist that the app “poses a threat to national security” and as a result, there have been efforts by the U.S. to buy the app or to ban it completely (New York Times, 2025).

SECURITY THROUGH ACCESS: THE U.S. STRATEGY

The United States takes a different approach to digital governance and sovereignty compared to China, advancing what can be described as the “security through access” model (Delev, 2025). The U.S. relies on openness in cyberspace, underpinned by its tech institutions and what scholars have termed “digital solidarity.” This practice reflects a strategy of soft sovereignty in which influence is exerted through global market leadership and technological integration, rather than strict state control. 

In effect, the U.S. promotes and operationalises an open digital order through its policy orientations and the global reach of its corporate actors – for example, the CLOUD Act of 2018, a document that shapes the premise of U.S. cross-border data sharing and collection. The Act was updated to reflect on the U.S. data sovereignty stance (Floridi, 2020): a call for “access to data held by U.S.-based technology companies, regardless of where that data is physically stored in the world” (Ortiz, 2025). 

Since the early 2000s, U.S. tech companies such as Meta, Amazon, Microsoft and Alphabet have undergone exponential growth, cementing their role as architects of the digital ecosystem. For example, Microsoft achieved a market valuation exceeding US$2.5 trillion within just 15 years (Armstrong, 2021). As of January 2025, numerous U.S.-based tech corporations have become some of the “most valuable internet company by market capitalisation worldwide” (Petrosyan, 2025).

DIGITAL PUBLIC INFRASTRUCTURE AND ITS IMPACT IN PROMOTING A DIGITAL ECONOMY

Digital public infrastructures (DPIs) are foundational digital systems like digital IDs, payment platforms, data exchange layers and authentication systems that enable participation in the digital economy and governance, fostering the need for digital sovereignty (UNDP, 2023). In the case of the U.S., there has not been a fully integrated DPI system or model like India’s India Stack or Estonia’s X-Road. This is mainly due to privacy and federalism concerns (Khera, 2022; Cummings, 2021). Instead, the U.S. relies on a fragmented market-driven model with a stronghold in the digital space run through the private actors like Apple Pay, Paypal, Mastercard, Visa and Google Cloud (Aaronson, 2021). Instead of the typical DPI, government infrastructures like Social Security Numbers are more favourable (Paul, 2020). This indicates how the U.S. leverages its tech firms to exercise digital power in the geopolitical space by shaping standards through infrastructure (Farrell & Newman, 2019). 

It is important to note that, as a market leader, the United States positions digital solidarity as a central component of its digital strategy (U.S. Department of State, 2024). Far from being a rhetorical device, digital solidarity operates as a geopolitical instrument that reinforces U.S. market dominance in cyberspace while shaping the terms of global digital competition (Nye, 2010; Farrell & Newman, 2019). The U.S. and other countries like those in the European Union rely heavily on technological giants to shape the national and international cyberspace (Pohle & Thiel, 2020).

Contesting Sovereignty: Digital Technologies and Shifts in Global Political Dynamics

The United States and China’s approach to digital sovereignty through governance models, regulations and data localisation strategies are clearly diametrically opposed. China mainly prioritises state control over utilising free-flowing digital infrastructures through their use of strict censorship, regulations and policies that maintain the government’s prominent digital authority within China. In contrast, the United States has a primarily opposite strategy, embodying an open digital market approach, encouraging international data flow and technological innovation. 

Nonetheless, both states deem national security to be of equal importance and consider it a key aspect to take into consideration when creating legal frameworks to regulate their digital sovereignty. It is evident that digital sovereignty stretches beyond internal domestic policies and legislation and farther into the international realm (Jansen, 2023). Global disputes often arise due to emerging technologies as they serve as an instrument of influence on geopolitical power (Friis & Lysne, 2021). An example is 5G, which is not only about faster internet – it also underpins emerging technologies like AI, IoT, autonomous vehicles, smart cities and digital finance (GSMA, 2023). Whoever leads in 5G has geopolitical leverage, as countries supplying the technology may shape global standards and dependencies (Jansen, 2023).

The U.S.-China dominance in digital sovereignty is an indication of the influence of technology. In the case of China, Huawei and Zhongxing Telecommunication Equipment Corporation (ZTE) became major global suppliers of 5G infrastructure which raised security, surveillance and dependency concerns in Europe and the U.S. (Hung, 2025). As a result, the U.S. restricted Chinese firms from accessing its markets and tried to exert pressure on their allies to limit Huawei’s involvement in framing 5G. In response to this, China found a way out by exporting tech products and solutions to Africa and now has a huge market base in the continent, increasing the continent’s dependency on China (Cambridge University Press, 2025).

The 5G rivalry is an example that demonstrates how control of digital infrastructures can reshape international power dynamics and grant countries significant advantages over the other (Musoni et al., 2023). For these reasons, nations devote extraordinary amounts of time, money and resources into advancing their own hardware technologies, particularly semiconductors which are the backbone of digital infrastructures (Roberts, 2023).

Human Rights, Digital Citizenship and Inclusion 

SOVEREIGNTY FOR EMPOWERMENT OR EXCLUSION

In China, the understanding of “cyber sovereignty” positions the state as the primary rights-bearing actor in cyberspace, prioritising territorial control, information security and regime stability over individual liberties (Gao, 2022; Hulvey, 2022). This agenda legitimises extensive infrastructural and discursive controls, from content moderation and real-name registration to data localisation and platform responsibility for “harmful” speech that condition digital citizenship on alignment with state priorities (Moynihan & Patel, 2021). Cases like the Digital Silk Road and multilateral venues show China reframing sovereignty as a universal value to attract support for rules that normalise tighter content and data controls (Hulvey, 2022; Moynihan & Patel, 2021). Emerging research in global internet governance similarly observes China’s boundary-work in International Telecommunication Union (ITU) processes and related forums that centre state competencies over multistakeholder approaches (Guangyu Qiao-Franco, 2024). In this context, we can see how China is consolidating authority by legitimising and broadening power on digital governance. 

In contrast, the United States’ liberal approach, historically anchored in the First Amendment and the platform-liability shield of Section 230, creates private ordering of online speech (Goldman, 2022; Dickinson, 2025). Yet this empowerment is uneven with the corporate “platform rule” marginalising users through opaque content governance and data extraction. The absence of a comprehensive federal privacy statute weakens user control over personal data (Kohl, 2025). Moreover, extraterritorial surveillance and evidence-gathering powers under the CLOUD Act reassert state prerogatives in ways that could conflict with foreign privacy laws and digital rights aspirations, raising inclusion and reciprocity concerns for users outside the U.S. (Bilgiç, 2018; Cochrane, 2022). In short, both models mobilise sovereignty to structure the citizen-state-platform triangle, but with different default beneficiaries. China’s configuration privileges state cohesion over dissenting user agency, while the U.S. configuration privileges private intermediaries and freedom of speech, sometimes at the expense of privacy, transparency and equitable participation.

IMPACTS ON PRIVACY, FREEDOM OF EXPRESSION AND ACCESS TO INFORMATION

The political agendas of China and the U.S. translate into distinct digital rights outcomes for their citizens. In China, restrictions on online expression, supported by pervasive automated and human moderation, systematically narrow the space for contestation and collective organisation, with negative effects on minorities and dissidents (Moynihan & Patel, 2021). Access to information is curated through a complex regime of filtering, licencing and intermediary liability (Gao, 2022). In the case of the U.S. model, it protects expression against state interference, and Section 230 of the Communications Decency Act of 1996 historically insulated platforms from most publisher liability, facilitating pluralism and user-generated production of knowledge (Dickinson, 2025). In reference to digital citizenship, the Chinese approach conditions rights on civic conformity within a securitised information order, while the U.S. approach presumes liberty of speech but delivers uneven privacy and due-process protections in predominantly private spaces. From a wider viewpoint, both systems risk reproducing inequality: through political conformity in China and through market-driven, data-extractive infrastructures and uneven redress in the U.S. (Musoni, 2023).

INTERNATIONAL BODIES: RULE SHAPING AND VENUE SHOPPING

International bodies like the UN and ITU play a pivotal role in shaping digital sovereignty by setting global standards that facilitate and advocate for democratic and inclusive governance, hence the involvement of China and the U.S. in different capacities in these agencies (Rikap, 2024). It is therefore important to consider China and the U.S.’s influence on these institutions. At the ITU, China has advanced proposals aligning technical standards with sovereign control and state oversight, sometimes drawing votes from states favouring order and development narratives over openness (Hulvey, 2022). Within the UN system more broadly, Chinese diplomacy has promoted expansive “cyber sovereignty” framings that soften commitments to freedom of expression in digital contexts (Moynihan & Patel, 2021). Such initiatives recalibrate the baseline against which human rights are weighed, especially in international organisations that are prominent in setting international laws where private and civil-society voices are weaker.

Both the U.S. and China have different levels and ways in which they could influence digital sovereignty within international agencies like the UN and ITU. For instance, the U.S. government influences UN agencies primarily through their substantial financial contributions and participation in governance and policy activities (CFR, 2025), which makes it the single largest donor and a powerful stakeholder across the UN system with more than a quarter of funding donated for UN programmes. This is evident in the recent reduction of funding by the U.S. government in the sector of international development which has affected humanitarian projects across the globe. This financial influence allows the U.S. to drive priorities and shape digital policies that allow their dominance on digital sovereignty through big tech companies.

Conclusion

From digital authoritarianism with a goal of expanding its reach to a digital democracy trying to foster connections while dominating the market, the Chinese and U.S. approaches to digital sovereignty and governance seem as if they could not be further apart. After both countries faced a surge in their digital structure quality and internet market value, their differing political agendas and visions for the future began to clash with one another even more. On one hand, the PRC opts for a strict and unyielding approach to their digital sovereignty, compromising individual privacy rights for the sake of high cybersecurity on a national level. On the other hand, the United States remains far more liberal in their approach, relying almost exclusively on their big tech corporations to not only monitor the cyberspace, but also capitalise the global market. These two polarised systems have largely impacted not only politics but also human rights in the cyberspace, leading global institutions and regulatory bodies to have to pick one side or the other. With both parties finding it increasingly challenging to not only align their digital policies but also engage in diplomatic dialogue on digital sovereignty, questions regarding a deeper, larger scale conflict between the two parties arise.  

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