Cullen International's latest Global Trends benchmark for number-independent communications apps regulation found that nearly all of the 13 surveyed jurisdictions around the world provide some legal mechanism to make these apps assist law enforcement in criminal investigations. There are requirements to verify user identities, compel disclosure of stored content, make encrypted content accessible, and duties to detect illegal content within private communications.

Key findings

• Most of the 13 surveyed jurisdictions impose no general identity-verification duty on communications apps.
• Nearly all allow authorities to compel disclosure of stored communications content, but only pursuant to a court order tied to a criminal investigation. The specific legal thresholds vary.
• Compelled accessibility of encrypted content (subject to feasibility and other limits) is the most diverse category of law enforcement cooperation mechanism. For example, India and Singapore impose broad decryption duties, and Korea requires decryption using government-approved technology. Only the EU imposes no decryption obligation at all, while it studies legal alternatives to it. The US and Brazil, on the other hand, remain the most unsettled: neither has yet resolved, through legislation or final court rulings, whether providers can be lawfully compelled to decrypt content.
• Duties to proactively detect illegal content in private communications is another area largely lacking in uniformity across all 13 jurisdictions.

Why it matters

“Lawful access” to messaging app content differs sharply between jurisdictions. For industry, the differences affect compliance costs, product design and regulatory strategy. Faced with such a high level of regulatory divergence from country to country, providers may withdraw services. But there are also downsides for government authorities: different national rules make it hard to obtain data stored abroad. This affects mutual legal assistance, data-sharing agreements and sovereignty arguments.

Background / context

Number-independent communications apps depend on telecoms networks for connectivity but are not generally the providers of the underlying network. They thus have been able to scale without incurring the costs associated with spectrum licences, mobile radio networks, or fixed last-mile infrastructure. This asymmetry has led to debates over regulatory parity between telecoms operators and digital communications platforms.

Scope

Region: Global 
Countries covered: Australia, Brazil, China, the EU, India, Japan, Korea, Malaysia, Singapore, South Africa, Thailand, the UK, and the US.
Policy area: Telecoms, Online platforms
Last updated: October 2026

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Definitions, licensing and interoperability
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Regulatory activity

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