This study uses a normative juridical method with a legislative and comparative approach. This method was chosen to examine and compare legal regulations on cyberbullying across three countries: Indonesia, South Korea, and Japan. The legislative approach examines the positive legal norms applicable in each country, particularly those that regulate the protection of victims of bullying in the digital space. Meanwhile, the comparative approach is used to examine the substance of the law, enforcement mechanisms, and the effectiveness of regulations across countries, to identify best practices that can be adapted to the Indonesian legal context. This study uses legal data in the form of primary and secondary legal materials. Primary legal materials comprise national legislation regulating cyberbullying, including laws, government regulations, and official policies, in Indonesia, South Korea, and Japan. Secondary legal materials include academic literature, scientific journals, and legal publications relevant to cyberbullying and legal protection. All legal materials are analyzed qualitatively, using a systematic and grammatical approach, to reveal the structure, substance, and legal implications of each regulation. The analysis was conducted to answer the main research question: How are legal rules on cyberbullying implemented in Indonesia, South Korea, and Japan, and to what extent are they effective in providing legal protection for victims? This methodology was chosen because it enables an in-depth examination of various legal systems and provides a solid foundation for recommending legal reforms in Indonesia, drawing on effective practices from other countries.

Each country's historical background plays an important role in shaping its current legal system. Indonesia adopted a legal system influenced by colonial experiences and the process of legal modernization. Indonesia inherited the Dutch legal system, which emphasizes codification and legal formalities ( Juwana, 2014). Indonesia has undertaken significant legal reforms to modernize its legal framework while preserving its nationality ( Setyowati & Toengkagie, 2009). This reform included modifications to laws, regulations, policies, legal institutions, and judicial procedures. At the same time, Japan adopted a unique blend of influences from the European Continental, Anglo-American, and indigenous Japanese traditions. This hybrid structure reflects Japan's historical and cultural evolution, particularly its post-World War II reconstruction. Meanwhile, South Korea's legal system is heavily influenced by European continental law, particularly German law, through Japan, which colonized Korea from 1910 to 1945 ( Youm, 2013). South Korea's legal framework is based on the 1987 Constitution, which establishes Korea as a democratic republic with three branches of government: executive, legislative, and judicial.

Indonesia and Japan tend to maintain the Criminal Code as the main instrument for enforcing laws against cyberbullying. This is because neither Indonesia nor Japan has specific laws that directly address cyberbullying. However, Indonesia faces challenges because the absence of specific laws targeting cyberbullying poses challenges in enforcement and protection ( Putra, 2024; Wahanisa et al., 2021; Chun et al., 2023). Conversely, South Korea has undergone legal transformation following high internet penetration, which has reached almost the entire population due to the high risk of cyberbullying in South Korea. The Korean War has thus resulted in a more progressive and adaptive approach to contemporary issues, including cyberbullying. The regulations implemented in South Korea reflect the response to post-war social dynamics and rapid industrialization, as well as a commitment to protecting children and adolescents in the digital age. Intense social pressure, especially among teenagers and celebrities, regarding academic achievement and physical appearance, exacerbates the situation of cyberbullying. Cyberbullying in Korea initially focused on verbal and sexual forms, but recent amendments have included issues of exclusion and extortion, reflecting a broader understanding of the impact of cyberbullying ( Chun et al., 2023).

Legally, there are fundamental differences in the structure of regulations governing cyberbullying in the three countries. Indonesia relies on Law No. 1 of 2024 on Electronic Information and Transactions (ITE) and the Criminal Code as its legal basis. However, it does not yet have an explicit definition of cyberbullying and still relies on complaint-based offenses. Japan uses the Penal Code of Japan to prosecute perpetrators, with a more flexible approach to law enforcement. South Korea has its regulations through the Act on Promotion of Information and Communications Network Utilization and Information Protection and the Act on Prevention of and Countermeasures Against Violence in Schools, which comprehensively cover both penal and non-penal approaches. Harmonization with international law is also more evident in South Korea, which actively adopts principles from global conventions such as the Convention on the Rights of the Child and the Budapest Convention on Cybercrime. In contrast, Indonesia and Japan still show limitations in this integration.

A comparison of cyberbullying policies in Indonesia, Japan, and South Korea reveals significant differences in legal approaches and socialization strategies. Indonesia uses the Electronic Information and Transaction Law (ITE Law) as the main framework for regulating various aspects of cyberbullying. Its implementation faces challenges and hinders effective handling of cyberbullying cases due to low digital literacy, exacerbating the situation ( Hinduja & Pathin, 2018). Japan emphasizes victim protection and prevention, reflecting a restorative, public-welfare-oriented legal philosophy. South Korea emphasizes intensive socialization campaigns in educational institutions and communities to raise awareness about the harmful effects of cyberbullying. Socialization programs in South Korea aim to encourage more responsible online behavior and build moral awareness about the serious consequences of cyberbullying. Combining the values of justice and social responsibility, with a legal approach that balances law enforcement and education. Indonesia, with its focus on prevention and severe criminal penalties, demonstrates a legal orientation that is still predominantly repressive, but does not yet fully accommodate the principles of victim protection and rehabilitation.

Table 1 shows that South Korea has the most comprehensive regulatory coverage, covering seven of the eight forms of cyberbullying identified globally, as well as sanctions that reflect the country's seriousness in addressing digital crimes. Although it lacks specific legislation, Japan demonstrates effectiveness through rapid law enforcement and strong victim protection. Meanwhile, Indonesia still faces challenges in terms of legal definitions, regulatory coverage, and implementation effectiveness. This includes the need for more technical regulations to address cybercrimes committed outside Indonesia ( Irawan et al., 2025). The reliance on complaint-based violations and the absence of obligations for digital platforms to remove harmful content are significant obstacles in protecting victims. Interpretation of this data shows that the effectiveness of regulations is determined not only by the existence of specific laws but also by the structure of law enforcement, institutional participation, and public awareness.

In the current social and political context, South Korea has successfully built a safe digital ecosystem through a collaborative effort among the government, schools, and digital platforms. Japan relies on bureaucratic efficiency and rapid response from law enforcement agencies, while Indonesia still needs more intensive structural reforms and public education. Japan prioritizes victim protection. The police can act without waiting for reports, removing harmful content immediately. This reflects Japan's more restorative and preventive legal philosophy. South Korea combines penal and non-penal approaches in a balanced manner, reflecting a progressive legal philosophy responsive to digital dynamics. This country has developed various preventive measures and interventions for cyberbullying and other internet-related issues, similar to Japan ( Toda & Oh, 2020). Meanwhile, Indonesia still focuses on deterrence through heavy criminal sanctions but has not yet developed a systematic preventive approach or adequate victim protection.

The phenomenon of cyberbullying in Indonesia has become an increasingly complex social issue as internet and social media usage continue to rise. Historically, the term cyberbullying began to gain widespread recognition in Indonesia in the early 2010s, coinciding with the increasing use of smartphones and social media among teenagers. As one of the countries with the most significant number of internet users in the world, Indonesia faces serious challenges related to cyberbullying or online harassment. This phenomenon includes actions such as harassment, threats, insults, or the unauthorized dissemination of personal information through digital platforms, which have a detrimental impact on mental health, particularly among teenagers. According to a 2019 UNICEF survey, out of 2,777 Indonesian youth aged 14-24, 45% of respondents had experienced online bullying, with a higher reporting rate among boys (49%) than girls (41%). The most common types of bullying, according to 1,207 respondents, were harassment through chat applications (45%), the dissemination of personal photos or videos without permission (41%), and other forms of harassment (14%). To address and prevent the threat of cyberbullying, Indonesia does not have specific laws regulating potential threats. However, developments in regulations regarding cyberbullying are governed by the Law on Information and Electronic Transactions (ITE Law), which has undergone several amendments.

Cyberbullying incidents are often not prosecuted legally due to the lack of clear definitions and boundaries in the regulations, as there are no specific regulations in place. Regulations regarding social media are governed by Law No. 11 of 2008 on Information and Electronic Transactions, which has undergone three amendments: Law No. 11 of 2008 on Information and Electronic Transactions (first amendment), Law No. 19 of 2016 on Information and Electronic Transactions (second amendment), and Law No. 1 of 2024 on Information and Electronic Transactions (third amendment). The Law on Information and Electronic Transactions applies to anyone who engages in legal acts as regulated by this law, whether they are within or outside the legal jurisdiction of Indonesia. Law No. 1 of 2024 on Electronic Information and Transactions regulates cyberbullying in Article 27A, Article 27B paragraph (2), and Article 29. These amendments reflect the evolution of legal understanding of social dynamics in the digital space, as well as the state's response to demands for the protection of individual rights in the technological era.

According to Article 27A, a perpetrator of cyberbullying is any person who intentionally attacks the honor or reputation of another person by making an accusation, with the intent for such accusation to be made public in the form of electronic information and/or electronic documents transmitted through an electronic system. Article 29 states that a perpetrator of cyberbullying is any person who intentionally and without authorization sends electronic information and/or electronic documents directly to the victim, where such information and/or documents contain threats of violence and/or intimidation. If we look closely, these three articles can be categorized as formal offenses, which are indeed very different from the criminal acts contained therein, because cyberbullying is a material criminal act. A material offense is an offense that is only considered complete when there are consequences resulting from the criminal act that has been committed.

The existence of the 2024 ITE Law brings changes that clarify the definitions and penalties related to actions. The position of the ITE Law is lex spesialis of the Criminal Code as lex generalis, which makes the articles in the 2024 ITE Law inseparable from the basic legal norms contained in Article 310 of the Criminal Code, where cyberbullying is a complaint offense, namely, the victim of cyberbullying must file a complaint/report of the bullying experienced in order for it to be processed legally as a complaint-based offense. Philosophically, the regulation of cyberbullying reflects the state's efforts to uphold human dignity, the right to privacy, and the psychological well-being of citizens in the digital age. From a legal perspective, protection against online bullying is rooted in the principles of social justice and the protection of human rights as enshrined in the 1945 Constitution, particularly Article 28G (1), which states that every person has the right to protection of their self, family, honor, dignity, and property. In the context of social ethics, cyberbullying contradicts the values of cooperation, tolerance, and empathy that are part of Indonesia's cultural identity. The state has a responsibility to create a safe and humane digital ecosystem where every individual can participate without fear or threat.

Cyberbullying in Japan has begun to receive serious attention with the rise in social media use, especially among teenagers. Japan is one of the countries where cyberbullying is prevalent. Reports on the prevalence of cyberbullying in Japan among 899 high school students, 225 had experienced cyber victimization, while 7.8% admitted to having cyberbullied others. Furthermore, those who engaged in cyberbullying did so for reasons such as: 1) 45% for fun, 2) 38.6% because they hated the victim, 3) 14.3% because they had been bullied before, 4) 10% because they followed their friends, 5) 1.4% because their friends ordered them, and 6) 14.3% for other reasons. In some cases, cyberbullying occurs on social media platforms such as Twitter. Twitter is one of the most widely used social media platforms in Japan. Twitter is used as a medium for casual daily conversations, user interactions, and information sharing (Weller, Bruns, Burgess, Mahrt, and Puschmann, 2014). However, many users exploit Twitter as a platform for engaging in unpleasant activities, including cyberbullying. One tragic case of cyberbullying in Japan involved Hana Kimura, a 22-year-old professional wrestler who took her own life due to psychological pressure stemming from cyberbullying on social media ( Alfaia et al., 2022).

Under Japanese law, cyberbullying is not explicitly regulated by articles; however, acts such as defamation, libel, or online threats can be prosecuted under the Penal Code of Japan (Keihō). Japan has adopted a three-stage model (Sandankai Kōzō) consisting of unlawful acts, fault, and capacity for responsibility as a theoretical framework for evaluating criminal liability, including in cases of cyberbullying. This approach encourages courts to conduct a holistic analysis that considers the moral, social, and psychological dimensions of the perpetrator ( Salah, 2017).

Unlawful acts include actions such as disseminating defamatory or unlawful content, including the dissemination of defamatory or slanderous content through digital platforms that explicitly violate the legal norms of the Penal Code of Japan (Keihō). The concept of fault distinguishes between direct intent and conditional intent, as well as ordinary negligence and gross negligence, providing flexibility in assessing the level of intent and awareness of the perpetrator. Meanwhile, the evaluation of capacity for responsibility, particularly through Article 39 of the Keihō, encourages medical and normative assessments of perpetrators and mental disorders (shinsin sōshitsu), with the option of rehabilitation as an alternative to criminal punishment. Unlike the Indonesian criminal law approach, which emphasizes the objective elements of the act through the Information and Electronic Transactions Law (UU ITE), the Sandankai Kōzō model offers a more contextual and substantively just approach.

Although Japan does not yet have specific legislation on cyberbullying, the application of articles in the Keihō demonstrates the adaptability of the criminal justice system in dealing with technology-based crimes. Article 222 regulates threats with a maximum penalty of two years' imprisonment or a fine of up to 500,000 yen. Article 230 addresses defamation, with penalties of up to 3 years' imprisonment or a fine of up to 500,000 yen, and Article 231 addresses insult, with fines of up to 10,000 yen or detention for up to 30 days. Furthermore, the 2021 amendment, which imposes harsher penalties for online defamation, including imprisonment of up to 1 year or a fine of up to 300,000 yen, reflects a proactive response to the increasing prevalence of cyberbullying ( Fukurai & Miyazawa, 2018). This approach promotes effective law enforcement without requiring special legislation, which is often delayed due to the dynamic nature of digital technology. This contrasts with Indonesia, where the ITE Law regulates similar actions through Article 27(3) on online defamation, but its implementation tends to be rigid and dependent on victim complaints. This can hinder swift responses to cyberbullying cases. Japan's flexibility in utilizing existing legal frameworks demonstrates its advantage in addressing modern crimes without requiring extensive legislative reforms.

One aspect that distinguishes the Japanese legal system is its rehabilitative approach, particularly in dealing with juvenile offenders and individuals with mental disorders. According to Shōnen Hō, children under 14 cannot be criminally charged; instead, they are referred to rehabilitation programs focused on guidance and prevention (Tegih, 2010). These programs are designed to address the root causes of behavioral issues through education, counseling, and social support, thereby reducing the risk of recidivism. Additionally, the Act on Medical Care and Treatment (2005) provides specialized care mechanisms for offenders with mental disorders, subject to strict medical evaluations by Article 39 of the Keihō. This approach reflects a legal paradigm that not only aims to impose sanctions but also facilitates the reintegration of offenders into society. In contrast, Indonesia's juvenile justice system, based on Law No. 11 of 2012, tends to be limited to light sanctions or diversion, without adequate rehabilitation infrastructure. The lack of focus on the psychological evaluation of offenders in Indonesia can hinder the effective handling of cyberbullying cases involving children or individuals with mental health conditions.

Japan's law enforcement system stands out for its efficiency, particularly through the police's proactive approach, which avoids waiting for victims' reports. Cooperation between legal authorities and digital platform providers facilitates the swift removal of harmful content, thereby minimizing the psychological and social impact on victims ( Fukurai & Miyazawa, 2018). This approach differs significantly from Indonesia, where law enforcement is often hindered by the need for formal complaints and lengthy bureaucratic processes, thereby prolonging the victim's suffering. Additionally, Japan's evaluation of perpetrators' capacity for responsibility, which includes medical and normative assessments of their mental condition, offers a more detailed approach compared to the general standards applied in Indonesia. This mechanism ensures that penalties or interventions are commensurate with the perpetrator's level of responsibility, thereby enhancing procedural and substantive justice.

The Japanese legal philosophy in addressing cyberbullying is grounded in the principles of substantive justice, social restoration, and the protection of human dignity. The rehabilitative approach is particularly prominent, especially in dealing with child perpetrators and individuals with mental disorders. Under the Juvenile Law, children under 14 are not subject to criminal penalties; instead, they are directed toward rehabilitation programs and counseling. Additionally, the Act on Medical Care and Treatment for Persons with Mental Disorders (2005) provides mechanisms for medical evaluation and treatment for offenders with mental disorders by Article 39 of the Keihō. This approach demonstrates that Japanese law aims not only to punish but also to rehabilitate and reintegrate offenders into society. Proactive and collaborative law enforcement between authorities and digital platforms accelerates the removal of harmful content, minimizes the psychological impact on victims, and reflects a legal philosophy oriented toward social welfare and the protection of human rights.

South Korea is one of the leading countries in materials technology. This country, South Korea, has the world's fastest internet connection, with an average speed of 105.62 Mbps. This incredible speed, far exceeding the average in many other countries, makes South Korea a digital world pioneer ( Song & Seo, 2024). South Korea's rapid digital development is faced with serious problems related to cyberbullying. South Korea is one of the Asian countries with the highest internet speeds. problem worrying about cyberbullying ( Lee et al., 2021). Heavy use of social media, fast internet connection, and pressure from big social media in public become reasons for the rise of cyberbullying, especially among teenagers and celebrities ( Jeong & Park, 2024).

The discrimination that occurs among South Korean youth is based on various factors. Factors such as gender, academic achievement, appearance, and economic status ( Lee & Yi, 2022). In LPA (Latent Profile Analysis), it was proven that factors such as appearance, educational background, and social status often overlap (intersectionality). Lee et al. (2017) In his research on adolescents, he demonstrated a link between appearance (lookism) and discrimination in Korea. Weinstein (2021) emphasized that adolescents who experience discrimination in the form of online and offline bullying experience a loss. The negative impact of bullying is also a risk factor for suicidal ideation, which is common in South Korea ( Assari et al., 2017; Kim & Ko, 2021). According to 2020 South Korean Statistics data, the number of adolescent deaths caused by discrimination and bullying reached 41.1%. This means that suicide risk factors are positively associated with cyberbullying ( Lee et al., 2021).

The tragedy of cyberbullying cases in South Korea that led to suicide can be seen in the death of Sulli, a K-Pop idol who hanged herself in her home. Sulli was found by her manager on Monday, October 14, 2019, at 3:21 PM local time. Sulli experienced stress due to insults from the public and netizens. Many negative comments flooded Sulli's social media, which had an impact on psychological stress and ended in suicide ( Khasanah, 2019; Park & Kim, 2021). This problem was also emphasized by Park (2025) that bullying victimization influences suicidal ideation indirectly, through the mediation of anxiety or depression. Not long after Sulli's case, the extraordinary impact of cyberbullying was also experienced by Korean artist Goo Hara who was found dead by suicide on Sunday, November 24, 2019, at her home in the Gangnam area, Seoul ( Kang et al., 2022). Goo Hara suffered from depression and had survived a suicide attempt in May 2019. Previously, Goo Hara was involved in problems with her ex-boyfriend, Choi Jong Bum, who threatened to spread an intimate video that happened to Hara. As a result of this case, Hara was attacked by negative and malicious comments on social media ( Kurnia, 2021).

Handling cyberbullying in South Korea is based on the Act on Promotion of Information and Communications Network Utilization and Information Protection or known as the Network Act. Lee, Song and Park (2021) explained, this legal umbrella was created in 2001 with the aim of contributing to improving the lives of citizens and increasing public welfare by facilitating the use of information and communication networks, protecting the personal information of users of information and communication services, and developing an environment where users can utilize information and communication networks in a healthier and safer way (Article 1). This law is managed by the Korea Communications Commission (KCC) and the Ministry of Science and ICT and has been amended to adapt to technological developments and social needs. In the Network Act, cyberbullying is explained in Article 44 paragraph (1): 1-3, Article 44 paragraph (2): 1-4, Article 44 paragraph (3), Article 44 paragraph (6) and Article 44 paragraph (7): 1-9. The criminal provisions resulting from cyberbullying are explained in Article 70 paragraph (1-3), Article 70-2, Article 71 paragraph (11), Article 72 paragraph (1): 2, Article 73 paragraph (7), and Article 74 paragraph (1): 2-3.

Article 44 paragraph (1) explains that every user is prohibited from disseminating information that violates the human rights of others, including violations of privacy and defamation through information and communication networks. If inappropriate information is disseminated, a request for deletion of the information can be submitted to the information service provider as explained in Article 44 paragraph 2.

“Where information provided through an information and communications network purports to be made public intrudes on other persons' privacy, defames other persons, or violates other persons' rights otherwise, the victim of such violation may request the provider of information and communications services who manages the information to delete the information or publish a rebuttable statement (hereinafter referred to as “deletion or rebuttal”), presenting explanatory materials supporting the alleged violation.”

Further procedures regarding the technical application for deletion of information are explained in detail in Article 44 paragraph (2): 2-6 and Article 44 paragraph (3). Then, if any person suspects that there is information published or distributed by a particular user that has disturbed his privacy, defamed him, or violated his rights, he can file a lawsuit with the Defamation Dispute Conciliation Division as explained in Article 44 paragraph (6) regarding the technical application for filing a lawsuit regarding the provision of user information.

Forms of information that are prohibited from being disseminated are explained in Article 44 paragraph (7) which consist of (1) Information containing child pornography in the form of codes, words, sounds, images, or moving images; (2) Information whose content can defame another person by spreading a fact, false news, or committing an unlawful act openly and intentionally to lower someone's reputation; (3) Information whose content can cause fear or worry because it can reach other people repeatedly in the form of codes, words, sounds, images, or films; (4) Information that has content that can damage, destroy, change, or falsify an information and communication system, data, program, or the like or that disrupts the running of a system, data, program, or the like without justifiable reason; (5) Information that contains content that is considered unhealthy media for children based on the Child Protection Law and that is provided to gain profit without fulfilling obligations and responsibilities in accordance with statutory regulations, including the obligation to verify the age of the other party and the obligation to include a label; (6) Information whose content includes speculative activities prohibited by statutory regulations; (7) Information whose content reveals secrets stipulated by laws or regulations of other countries; (8) Information whose content involves carrying out acts prohibited by the National Security Law; and (9) Other information whose content includes attempting, assisting, or encouraging the commission of a crime.

According to the Act on Promotion of Information and Communications Network Utilization and Information Protection, the primary penalty for cyberbullying is imprisonment with labor or a fine. South Korea imposes a maximum prison sentence of 10 years and a minimum of 1 year, while the maximum fine is 70 million won and a minimum of 10 million won. These criminal penalties are a form of legal or penal sanction. In addition to the implementation of criminal or penal law, the handling of cyberbullying acts in South Korea also has special regulations related to bullying in schools, namely through the Act on the Prevention of and Countermeasures Against Violence in Schools (Act on Prevention and Countermeasures Against Violence in Schools). In this regulation, the South Korean government pays great attention to the victims, the majority of whom are school students, so the regulation includes an understanding of bullying behavior both directly and in cyberspace.

Article 2 of the Act on the Prevention of and Countermeasures Against Violence in School explicitly explains that cyberbullying is any form of constant or repeated action in which students cause emotional harm to other students by using the internet, mobile phones, or other information and communication devices to reveal personal information about certain students or to spread lies or rumors about certain students, and then cause suffering there. The prevention of cyberbullying in the legal regulation is more preventive in nature in the form of the formation of a regional committee to address violence in schools and actions for victims and perpetrators using a non-penal approach.

Article 17 of the Act on the Prevention of and Countermeasures Against Violence in School explains the administrative sanctions for perpetrators of cyberbullying crimes in the form of: 1.

Order to provide a written apology to the victim student;

Referring to the two legal instruments used by South Korea to address cyberbullying, namely the Act on Promotion of Information and Communications Network Utilization and Information Protection and the Act on the Prevention of and Countermeasures Against Violence in Schools, it appears that the country has adopted two approaches to addressing and preventing cyberbullying. These two regulations complement each other in responding to various forms of digital violence, both in online public spaces and in educational settings. The Network Act provides a legal basis for addressing content containing slander, insults, and privacy violations online, and empowers authorities and digital platforms to remove harmful content. Meanwhile, the Act on the Prevention of and Countermeasures Against Violence in Schools specifically regulates the prevention, handling, and rehabilitation of victims of bullying in educational settings, including in the form of cyberbullying.

Preventive measures undertaken by Indonesia, South Korea, and Japan constitute digital citizenship education. Frau-Meigs et al. (2017) state that the idea of digital citizenship is a set of transversal characteristics that combine the values, skills, attitudes, knowledge, and critical understanding needed by citizens in the digital age. Digital citizenship education supports affective, behavioral, and cognitive outcomes ( Webster, 2025). Webster (2025) explains that examples of affective digital citizenship education include beliefs about interactions with digital technology; behavioral refers to the use of social media and technology integration by teachers; and cognitive digital citizenship education is based on pre/post test scores, measured on a citizenship scale. In this context, digital citizenship education is seen as an effective long-term solution in preventing cyberbullying, because it focuses on the formation of positive digital character from an early age.

Digital citizenship education encompasses the knowledge, skills, attitudes, and values related to digital technology that people need to act as citizens ( Dumbrava, 2017; Frau-Meigs et al., 2017). Ribble (2015) explains that digital citizenship is a concept that helps teachers, technology leaders, and parents understand how to use technology appropriately. Teachers need to be equipped with an understanding of the implications of digital technology on democracy, as well as the ability to integrate digital citizenship into meaningful learning activities ( Örtegren & Olofsson, 2024). Ribble (2015) divides digital citizenship into nine main elements: digital access, digital commerce, digital communication, digital literacy, digital etiquette, digital law, digital rights and responsibilities, digital health and wellness, and digital security. The widespread implementation of digital citizenship education is expected to reduce and prevent cyberbullying behavior among internet users, especially teenagers.

Strengthening digital citizenship education is an urgent need in Indonesia, South Korea, and Japan, as all three countries continue to face a surge in cyberbullying cases, particularly among adolescent social media users. Although all three countries have launched various digital literacy initiatives, the main obstacles remain uneven implementation, limited teacher training, and a lack of a holistic approach involving families, schools, and digital platforms. Research by Choi and Park (2023) in South Korea showed that students who received digital citizenship training had significantly lower levels of involvement in cyberbullying. A study by Ishii, Okabe, and Itou (2020) in Japan found that low awareness of digital ethics is a contributing factor to the high rate of bullying on social media among teenagers. Similarly, in Indonesia, digital citizenship education faces major challenges, including the digital divide between regions and the lack of contextual and sustainable digital citizenship learning modules ( Isabella et al., 2024). Therefore, the implementation of digital citizenship education must continue to be developed and sustained, as crimes in the digital era are increasingly diverse.

Referring to Ribble's theory (2015) in his book, “Nine Elements of Digital Citizenship in School: Nine Elements You Should Know,” a framework can be created for implementing digital citizenship in schools. Schools and classrooms are crucial places in developing digital citizens who are not only technically competent but also ethical, responsible, and legally aware ( Fernández-Prados et al., 2021; Tadlaoui-Brahmi et al., 2022; Milenkova & Lendzhova, 2020). The following framework is designed to support the structured implementation of digital citizenship education in classrooms and school environments.

Based on Table 2, digital access is the full involvement and equality in using digital technology. Inequality of access remains a major barrier to digital education, especially in remote areas. Schools must ensure all students have access to devices and the internet to prevent the digital divide ( Alam & Forhad, 2023; Norman et al., 2022). Digital commerce refers to students' ability to understand and engage in online transactions safely and ethically. This education is essential to prevent students from becoming victims of fraud or bullying in e-commerce ( Jantzer et al., 2025; Barragán Martín et al., 2021). Digital communication teaches students how to communicate effectively, politely, and responsibly in the digital space. Ethical online communication is crucial for building a healthy culture of dialogue on social media, preventing cyberbullying ( Aydınlar et al., 2024). Digital literacy is the ability to search for, evaluate, and use digital information critically. This is crucial in the era of abundant information so that students do not fall prey to hoaxes or misinformation ( Buchan et al., 2024). Digital etiquette refers to polite and ethical behavior when interacting online. This includes how students speak in class groups, comment on social media, and respect differences of opinion. Digital law refers to awareness of regulations, copyright, privacy, and other laws that apply in the digital space ( Soler-Costa et al., 2021). This understanding prevents violations such as cyberbullying, plagiarism, and the spread of hoaxes. In the digital rights and responsibilities element, students need to understand that in addition to having digital rights (privacy, freedom of expression), they also have a responsibility not to spread hatred or harm others ( Soler-Costa et al., 2021). Digital health and wellness encompass the balance between device use and physical and mental health. Excessive technology use can lead to sleep disorders, stress, and screen addiction ( Maurya et al., 2022; Mohd Saat et al., 2024). The digital security element teaches students to protect personal data, use strong passwords, and avoid phishing traps. This is crucial to protect students from cybercrime ( Venter et al., 2019; Alzubaidi, 2021).

As a long-term solution, digital citizenship education needs to be mainstreamed into the national education system. This includes integration into the formal curriculum from elementary school, teacher training on digital ethics and safety, cross-sector collaboration (education, technology, and families), and program adjustments based on the cultural dynamics of each country. These measures have proven more effective than relying solely on law enforcement, as education-based prevention fosters deeper awareness and competency in the younger generation.