World Defamation Laws by Country

Defamation laws vary dramatically from one country to the next. Some countries treat defamation purely as a civil wrong settled with damages, while many still make it a criminal offence that can carry fines or even imprisonment. This hub maps how libel and slander are handled across more than 80 countries and links a detailed, citation-backed guide for each.

The map below shows at a glance where defamation is purely civil, where it remains a criminal offence, and where the picture is mixed. It is a general guide, so always check the country guide for the detail.

Civil versus criminal defamation around the world

In a civil defamation system, the person defamed sues for a remedy such as damages, a correction, or an injunction, and the state is not involved. In a criminal defamation system, defamation is an offence the state can prosecute, and a conviction can mean a fine or imprisonment. Many countries have both tracks running at once. Criminal defamation remains common across much of the Middle East, Asia, Africa, Latin America, and Europe, although a number of countries that keep it have removed the possibility of prison and left only fines. There is also a clear decriminalisation trend: courts or legislatures have struck down or repealed criminal defamation in Zimbabwe (2014, confirmed 2016), Kenya (2017), South Africa (2024), Ghana (2001), Norway (2015), Cyprus (2003), Ukraine (2001), Romania, and Estonia, among others.

Watch out: a law on the books is not the same as a law in force. Some countries with criminal defamation statutes rarely prosecute, while others enforce them actively, so the practical risk depends on the jurisdiction and the context.

The United Kingdom is three legal systems, not one

There is no single "UK" defamation law. England and Wales apply the Defamation Act 2013 (serious-harm threshold, public-interest defence, single-publication rule). Scotland has its own Defamation and Malicious Publication (Scotland) Act 2021. Northern Ireland never adopted the 2013 Act, so its core rules come from the common law plus the Defamation Act 1996, modernised in part by the Defamation Act (Northern Ireland) 2022. Read the guides for England & Wales, Scotland, and Northern Ireland. The Republic of Ireland is a separate country with its own defamation law; see Ireland defamation laws.

Australia, the United States, and other major systems

Australia uses uniform Model Defamation Provisions enacted as a Defamation Act 2005 in each state and territory, with 2021 reforms adding a serious-harm element in most jurisdictions; see the Australia guide. The United States sits at the opposite end of the spectrum: under New York Times Co. v Sullivan, a public figure must prove "actual malice," and there is no general serious-harm statute, which makes a claim that succeeds in London often unwinnable in New York. For a state-by-state breakdown, see the United States defamation cluster.

Defamation laws by country

Browse every country we cover below. Civil-only jurisdictions are marked green, mixed or partial systems amber, and those with criminal defamation in force red. Select a country for its full guide, including the governing statute, defences, penalties, limitation period, and how a claim is brought.

Europe(34 countries)

Asia-Pacific(17 countries)

North America(1 country)

Central & South America(12 countries)

Middle East & North Africa(12 countries)

Sub-Saharan Africa(10 countries)

Before You Sue: Cease and Desist & Pre-Action Letters

Many countries expect, or require, a formal letter before you can sue (Australia mandates a concerns notice; England and Wales expects a letter of claim). See defamation cease and desist and pre-action letters around the world.

Frequently Asked Questions

Is defamation a crime or a civil matter?

It depends on the country. Many countries treat defamation as both a civil wrong (you can be sued for damages) and a criminal offence (the state can prosecute). A smaller group treats it only as a civil matter after abolishing criminal defamation.

Which countries have abolished criminal defamation?

Among those covered here, Ireland, New Zealand, Norway, Romania, Estonia, Cyprus, Ukraine, Ghana, Kenya, South Africa, and Zimbabwe have abolished criminal defamation and now treat it only as a civil matter. Each country guide explains the reform and its date.

Can you go to prison for defamation?

In many countries that retain criminal defamation, imprisonment remains a possible penalty, though a number of countries have reduced the punishment to fines only. The country guide states the specific penalties and whether prison is available.

Is truth always a defence to defamation?

Truth is a defence in most systems, but not always a complete one. Some countries also require the statement to serve the public interest, and a few (such as South Korea) can penalise even true-fact defamation in narrow circumstances.

How is online defamation handled?

Many countries apply their general defamation law to online posts, and increasingly layer on separate cybercrime or platform-liability laws that can carry their own, sometimes heavier, penalties. The country guide flags the relevant online statute.

Why is defamation so much harder to prove in the United States?

The First Amendment and the actual-malice standard from New York Times v Sullivan require public figures to prove the publisher knew the statement was false or acted with reckless disregard for the truth, a far higher bar than in most other countries.