ICT Legal Term Variation in Digital Governance: A Socio-Terminological Analysis Across the Chinese Mainland and Hong Kong

Abstract

Information and Communication Technology (ICT) legislation has expanded rapidly within digital governance, generating increasing variation in legal terminology across jurisdictions. Unlike terminology in relatively established legal domains, ICT legal terminology evolves alongside technological innovation, creating tensions between legal stability and technological adaptability. Existing studies have mainly focused on terminological standardization, legal translation, and conceptual consistency, while paying less attention to how terminological variation reflects different strategies of legal conceptualization and institutional adaptation. This study examines terminological variation in ICT legislation across the Chinese Mainland and Hong Kong from the perspective of socio-terminology, through two case studies of electronic signature and personal information . A three-dimensional analytical framework is developed to examine definitional strategies, conceptualization strategies, and institutional functional equivalence. The findings show that terminological variation reflect different strategies of legal conceptualization rather than incidental lexical choices. While the Chinese Mainland generally adopts broader, function-oriented conceptualizations that preserve regulatory flexibility, Hong Kong favors more technically and institutionally specified conceptualizations that enhance legal certainty and judicial enforceability. The study further demonstrates that cross-jurisdictional mutual recognition can establish institutional functional equivalence, allowing conceptually distinct legal terms to operate as corresponding legal designations in regulatory practice.