>As an American (the horror, I know, that I deign to comment on something British), I'd love to know where your freedom of speech is codified and what a government would have to do if they wanted to change what counts as speech, what doesn't, and what's protected and what isn't. I suspect that you and I have very different definitions of what qualifies as free speech.

There is nothing easy to point to, like the first amendment to the US constitution, but it probably wouldn't matter anyway.

The key differences between the UK and US, particularly in this area are that:

1) Governments in the UK tend to have large parliamentary majorities - the current government has a majority in excess of 150 seats. So if there was some sort of written constitution guaranteeing Free Speech, and it required a supermajority to change, it's likely that many UK governments would easily be able to do that.

2) Politicians and the public at large in the UK have very different attitudes to Free Speech (or rather, they take a more pragmatic approach to things and can see the need to compromise). Polling has shown that the Online Safety Act has over 70% of the public supporting it. Parts of the act see even higher support than that. Consequently, most of the major political parties support the act or even think it should go further.

This is in deep contrast to the US, where imagining a scenario in which you could amend the constitution would be virtually impossible in the current climate.