CIVIL LIABILITY FOR CYBER HARM: INTERNATIONAL AND COMPARATIVE APPROACHES

Abstrak

This article explores the evolving landscape of civil liability for cyber harm through international, comparative, and national lenses, focusing on developments from 2022 to 2025. It examines how legal systems are redefining responsibility in the digital age, with an emphasis on regulatory obligations, civil remedies, and conceptual innovations. International frameworks like the EU’s DORA, CRA, and NIS2, along with OECD recommendations, establish risk-based accountability for cyber resilience. Comparative analysis highlights diverse national approaches in Canada, the UK, Singapore, and others—ranging from statutory duties for platform safety to cybersecurity certification regimes. Uzbekistan’s legal transformation is presented as a dynamic case study of emerging liability models in developing jurisdictions. The article also integrates academic theories on digital harm, strict liability, digital fiduciaries, and hybrid regulatory models, revealing a shift toward proactive and preventive legal standards. This synthesis contributes to understanding how legal doctrine, regulatory design, and technology interact to shape a maturing civil liability regime for cyber risks worldwide.