The role of comparative law in the fight for digital sovereignty

The article examines the ongoing regulatory dialogue in the field of digital technologies. Scrutinising the main narratives of the three leading global actors, it particularly focuses on the role of comparative law as a critical factor in the fight for digital sovereignty. With local laws regulating a global phenomenon and competition among regulatory actors concerning the scope of application of laws and their institutional competencies, comparative law is crucial to justify stra-tegic choices and characterise distinct legal cultures, giving a unique physiognomy to the legal systems that express them. Yet, an analysis based on legal formants reveals how all these global actors strike a remarkably similar balance between competing reasons related to individual rights, free market, and security.