President-elect Donald Trump and his allies have vowed to squash an online “censorship cartel” of social media firms that they say targets conservatives.

Already, the president-elect’s newly chosen regulators at the Federal Communications Commission and the Federal Trade Commission have outlined plans to stop social media platforms like Facebook and YouTube from removing content the companies deem offensive — and punish advertisers that leave less restrictive platforms like X in protest of the lack of moderation.

“The censorship and advertising boycott cartel must end now!” Elon Musk, the owner of X, whom Trump has appointed to cut the federal budget, posted on his site last month.

In Europe, social media companies face the opposite problem. There, regulators accuse the platforms of being too lax about the information they host, including allowing posts that stoked political violence in Britain and spread hate in Germany and France.

Trump’s return to the White House is expected to widen the speech divide that has long existed between the United States and Europe, setting up parallel regulatory systems that tech policy experts say could influence elections, public health and public discourse. That’s putting social media companies in the middle of a global tug of war over how to police content on their sites.

“What you are seeing is conflicting laws emerging from the world’s democracies, and consumers in the end suffer,” said Kate Klonick, an associate professor of property and internet law at St. John’s University School of Law. The result could be a fractured internet experience where people see different content based on the laws where they live, she said.

Free speech is core to making America great, said Morgan Ackley, a spokesperson for Trump. “President Trump is committed to protecting this right for all Americans,” she added.

The cross-Atlantic regulatory clash stems from distinctly different global views on free speech. The United States, which has the First Amendment, also passed a law in 1996, known as Section 230, that shields companies from liability for content posted online — meaning it is largely up to social media sites to decide what to remove.

In Europe, unfettered free speech is considered a potential threat to democracy. Historical moments like the rise of Nazism inform policy, and freedom of expression is balanced against the potential harm to the public, particularly when it comes to religious or racial minority groups.

This summer, the British government imprisoned people for social media posts encouraging violence during riots intensified by misinformation about the murder of three young girls. German authorities raid people’s homes over allegations of antisemitism, insults and other harmful social media behavior. France arrested Telegram’s CEO, Pavel Durov, for his failure to rein in illicit content on the messaging app.

In the European Union, the Digital Services Act, passed in 2022, requires companies to quickly remove illicit content or face fines of up to 6% of their total revenue. Britain passed a similar law last year to regulate online speech, particularly content seen as harming children or encouraging terrorism.

In the United States, speech is restricted only when it comes to imminent threats, like falsely shouting that there is a fire in a theater, said Daniel Holznagel, a German appellate judge in Berlin who helped draft that country’s online hate speech law. “In Europe, it’s not only a fire-in-a-theater standard, but also hate speech, incitement to hatred and more.”