KAMPALA – Uganda’s digital space has become a
double - edged sword. It has democratized information, amplified marginalized
voices, and held power to account. But it has also become a theatre of
misinformation, privacy violations, and reckless speech that threatens national
security and social cohesion.
From the social media shutdowns
of the 2016 elections to the 2021 electoral violence, from the MV Templar
tragedy to the recent passing of Afrigo Band legend Moses Matovu, the conduct
of online users has repeatedly tested the limits of Uganda’s laws and values. It is time for
comprehensive best practices and guidelines for all registered online media
users—bloggers
included.
The Pattern: When Online Speech
Becomes Harmful
Elections 2016, 2021, and looking
to 2026
During the 2016 general
elections, the government ordered a four-day shutdown of Facebook, Twitter,
WhatsApp, and mobile money services, citing security concerns. The Uganda
Communications Commission (UCC) had earlier cautioned broadcasters against “negative and unprofessional
trends such as lack of balance, sensationalism, incitement, abusive language
and relying on unauthorized and unreliable sources”.
While legitimate concerns about
electoral integrity existed, the shutdown demonstrated the government’s willingness to restrict digital
spaces when perceived threats emerge. Yet the shutdown also revealed a deeper
problem: the absence of shared standards for online conduct that could
distinguish legitimate political speech from incitement and manipulation.
By 2021, online spaces had become
even more polarised, with bloggers and anonymous accounts spreading unverified
claims about electoral fraud, violence, and government conduct. As Uganda
approaches the 2026 elections, the risks of unregulated online speech—misinformation, incitement, and
foreign interference - are greater than ever.
MV Templar and Drowning Incidents
When the MV Templar vessel
capsized on Lake Victoria in November 2018, killing dozens of revelers, online
spaces became flooded with graphic images of victims, unverified casualty
figures, and speculative narratives about negligence. Families of the deceased
learned of their loved ones’ deaths through social media before official
confirmation.
This pattern repeated during
subsequent drowning incidents. The rush to publish graphic content and
unverified information prioritised clicks over dignity. Uganda’s Data Protection and Privacy Act
explicitly prohibits the collection and processing of personal data without
consent and requires that data be “complete, accurate, up-to-date and not misleading”. Yet these principles are
routinely ignored online.
Attacks on Government Programs
Online campaigns targeting
government programs - from immunization drives to infrastructure projects—have spread false claims that
undermine public health and development. Anti-vaccination misinformation,
fabricated corruption allegations, and coordinated attacks on public officials
have become commonplace.
The Computer Misuse Act criminalizes
cyber harassment, including “threatening to inflict injury or physical harm to
the person or property of any person”. But enforcement has been selective, and the law
does not address the broader ecosystem of misinformation and coordinated
inauthentic behavior.
The Death of Moses Matovu
The recent death of Afrigo Band
leader Moses Matovu illustrated yet another dimension of the problem: the
invasion of privacy in grief. Within hours of his passing, unverified details
about his medical condition, family disputes, and financial affairs circulated
widely online. Bloggers and social media users appropriated his death for
clicks, disregarding the privacy and dignity of his family.
This is not journalism. It is
appropriation - the use of personal tragedy for commercial or ideological gain
without consent or ethical justification.
Uganda’s Legal Framework: Present but
Incomplete
Uganda has a robust legal
framework governing online conduct, but it is fragmented and under enforced:
The Data Protection and Privacy
Act, 2019 governs the collection and processing of personal data. The Personal
Data Protection Office (PDPO), operationalized in August 2021, is responsible
for enforcement. The PDPO has demonstrated its willingness to act against
foreign entities, ruling against Google LLC in July 2025 for failure to comply
with registration and data transfer requirements.
The Computer Misuse Act, 2011 criminalizes
cyber harassment and unauthorized access to computer systems. However, it does
not address misinformation, disinformation, or coordinated inauthentic behavior.
The Press and Journalist Act,
1995 established the Media Council of Uganda to “regulate the conduct and promote
good ethical standards and discipline of journalists” and to arbitrate disputes
between the public, the media, and the State. But the Council’s jurisdiction over online media
remains unclear, and it lacks the resources and mandate to address the unique
challenges of digital speech.
The Anti-Terrorism Act, 2002 (as
amended) criminalizes acts of terrorism and provides for the freezing and
forfeiture of funds linked to terrorism. The definition of “services” includes “communications equipment” and “expert advice or assistance” provisions that could apply to
online coordination of violent activities.
The Access to Information Act,
2005 guarantees public access to information held by public bodies. But it does
not address the responsibilities of online users who publish information.
The Gap: No Standards for Online
Media Users
Traditional media in Uganda
operates under a licensing and regulatory framework. Broadcasters pay licensing
fees, journalists are expected to adhere to the Media Council’s ethical standards, and the UCC
monitors content compliance. Online radio providers are even required to obtain
authorization (at UGX 100,000 annually).
But bloggers, social media
influencers, and citizen journalists operate in a regulatory vacuum. They are
not licensed, not registered, and not subject to any enforceable code of
conduct. This allows a small number of bad actors to poison the information ecosystem
for everyone.
Comparative Perspectives: What
Other Countries Do
Germany enacted the Network
Enforcement Act (NetzDG) in 2017, requiring social media platforms with over 2
million users to remove “manifestly unlawful” content within 24 hours or face
fines up to €50 million. The law has been criticized for
over-censorship, but it established that platforms bear responsibility for the
content they host.
Kenya has the Computer Misuse and
Cybercrimes Act, 2018, which criminalizes false publications and cyber
harassment. The law has faced constitutional challenges, but it represents an
attempt to extend traditional media standards to online spaces.
Rwanda requires online publishers
to register with the Rwanda Media Commission and adhere to a code of ethics.
The regulatory environment is restrictive, but it provides a model for
accountability.
Singapore enacted the Protection
from Online Falsehoods and Manipulation Act (POFMA) in 2019, which allows
ministers to order corrections to false statements. The law has been criticized
for potential political abuse, but it creates a mechanism for correcting
misinformation without criminal prosecution.
A Way Forward: Guidelines That
Work
Uganda needs a balanced approach
that protects free expression while addressing genuine harms. The following
framework is proposed:
1. Registration and Transparency
All online media users who
regularly publish content to the public—bloggers, influencers, citizen journalists—should register with the Media
Council of Uganda. Registration should be free, simple, and online. It should
require a real name, contact details, and an undertaking to adhere to a
published code of conduct.
Anonymous
accounts would still be permitted for personal use, but accounts with
significant public reach (e.g., over 5,000 followers) would be required to
disclose their identity or operate through a registered entity.
2. A Code of Conduct for Online
Media
The Media Council should develop,
in consultation with bloggers, technologists, and civil society, a Code of
Conduct for Online Media. Key principles would include:
· Accuracy: Verify information
before publication. Correct errors promptly.
· Privacy: Do not publish personal
data without consent, except where there is a clear public interest.
· Dignity: Avoid graphic or
sensational coverage of death, tragedy, and suffering.
· Transparency: Disclose sources
of funding, conflicts of interest, and the use of automated accounts.
· Accountability: Respond to
complaints and participate in mediation through the Media Council.
3. Platform Responsibility
Social media platforms operating
in Uganda should be required to:
· Maintain a local point of
contact for law enforcement and regulatory authorities.
· Publish transparency reports on
content moderation and government requests.
· Implement mechanisms for users
to report violations of the Code of Conduct.
· Cooperate with the PDPO on data
protection compliance, as demonstrated in the Google ruling.
4. Digital Literacy and Media
Education
The government, in partnership
with civil society and educational institutions, should invest in digital
literacy campaigns that teach citizens to identify misinformation, protect
their privacy, and engage constructively online. NITA-U’s mandate to “promote and provide technical
guidance”
for e-services should be extended to include digital citizenship education.
5. Proportional Enforcement
Enforcement should be graduated
and proportionate:
· First instance: Education and
warning.
· Repeated violations: Mediation
through the Media Council.
· Serious violations:
Administrative fines or, in cases of incitement to violence or terrorism,
criminal prosecution under existing laws.
The Computer Misuse Act should be
amended to address misinformation and coordinated inauthentic behavior, with
clear definitions and robust safeguards against political abuse.
6. A Multi-Stakeholder Oversight
Body
A Digital Media Standards
Committee should be established under the Media Council, comprising
representatives from government, bloggers, civil society, academia, and the
private sector. This body would oversee the Code of Conduct, handle complaints,
and recommend policy reforms.
Conclusion
Uganda’s online media landscape is at a
crossroads. The choices made now will determine whether the digital space
becomes a driver of democratic accountability or a source of division and harm.
The 2016 shutdowns demonstrated
that the government will act when it perceives a threat. But shutdowns are
blunt instruments that punish the many for the sins of the few. A better
approach one that upholds Uganda’s constitutional commitment to freedom of expression
while addressing genuine harms is to establish clear, enforceable standards for
all online media users.
This is not about censorship. It
is about responsibility. It is about ensuring that the same standards that
apply to traditional media accuracy, fairness, privacy, dignity apply in the
digital space. It is
about protecting Ugandans from misinformation, invasion of privacy, and
manipulation.
The death of Moses Matovu, the MV
Templar tragedy, and the electoral turmoil of 2016 and 2021 are reminders that
words and images have consequences. It is time for Uganda to act not with
shutdowns, but with standards.
Walukamba Aldon is a media
consultant working with the Government of Uganda. The views expressed are his
own and do not necessarily reflect official government policy.
