Contemporary legal initiatives in the field of digital sovereignty

The article systematizes contemporary legal approaches to digital sovereignty and distinguishes three institutional models: China’s model of “full cyber-sovereignty” prioritizing content and infrastructure control; the EU’s “sovereignty through rules” (GDPR, DSA/DMA, NIS2, 5G Toolbox, European Chips Act); and the U.S. “externally projective” model that combines limited domestic platform regulation (Section 230 CDA) with extraterritorial data claims and techno-containment (CLOUD Act, CHIPS and Science Act, export controls). Using comparative-legal and institutional analysis, the paper shows how Russia develops a framework of “managed connectivity” (Federal Law No. 90-FZ, national routing, DPI/national DNS, import-independence policies) and builds an autonomous service ecosystem. Theoretical contributions include the concepts of “sovereign openness” and a “digital Westphalian compromise,” reconciling security imperatives with global interoperability. Policy recommendations cover algorithmic sovereignty (national data contours and high-risk AI certification), development of national clouds and app stores, stronger procedural safeguards for users’ rights (transparent content moderation, judicial and parliamentary oversight, public reporting), and deeper inter-state cooperation (EAEU/BRICS/SCO) while borrowing the EU’s best enforcement practices.