The national security law for Hong Kong: a corpus-driven comparative study of media representations between China's and Anglo-American English-language press

Hong Kong has been granted significant authority and a capitalist system and own institutions for 50 years under a unified China since July 1, 1997 when the Joint Declaration was signed. The handover of Hong Kong from Britain's colonial rule to China's control has brought about enhanced political awareness and involvement for the Hong Kong people. The passage of the National Security Law (NSL) has brought about another significant change in the political psychology of the Hong Kong people and the way Hong Kong is governed. Formally gazetted for promulgation, the NSL took effect on June 30, 2020, one day before the 23rd anniversary of Hong Kong's handover to Chinese sovereignty. The enactment of the NSL is publicly acknowledged as a result of the political unrest of massive street protests in Hong Kong in 2019 after its government proposed a law allowing the extradition of defendants to mainland China to stand trial or serve criminal sentences. The protests continued in some violent clashes between students and police though the Hong Kong government withdrew the proposal. In light of this background, the NSL is publicized with the legislative purpose to promote a safe society in Hong Kong. The Chief Executive of the Hong Kong Special Administrative Region stated that the legislation aims to prevent, curb and punish acts of secession, subversion of state power, terrorist activities, and collusion with foreign or external forces to endanger national security and to maintain Hong Kong's long-term stability and prosperity. In contrast, critics say the NSL devastates Hong Kong's autonomy and threatens the territory's independent press and democratic opposition. China's enactment of the NSL in Hong Kong has amplified the limelight of the world and has made widespread news headlines through journalism. To enhance more understanding about the issue, this paper seeks to compare relevant news reports between China's and Anglo-American English-language media and to observe how Chinese geopolitical orders are playing out in Hong Kong through the NSL. This paper provides rigorous linguistic evidence to the study of new politicized Hong Kong by contextualizing the inquiry within reference to journalism associated with the NSL. It contributes towards a wider understanding of China's NSL for Hong Kong under the background of the city's high degree of autonomy and the One Country, Two Systems principle.

There has been burgeoning literature regarding the impact and role of the NSL, which can be disaggregated into two strands. First, it investigates wide criticism associated with controversial aspects of the NSL and how it threatens to erode Hong Kong's One Country, Two Systems principle, including threats to Hong Kong's legislative process and framework, anxieties related to Hong Kong's resinicisation, protesters' opposition demands, widespread interference by China's central government, loss of separate legal system for Hong Kong and Hong Kong's truncated autonomy and controls over the society, education and the judiciary. Second, numerous Chinese scholars have conducted extensive research on the nature, cause, characteristics, and significance of the NSL, arguing it safeguards rights and interests, ends turmoil, reduces security risks, and integrates constitutional principles with Hong Kong's legal system. Prior studies have largely focused on socio-political and legal impacts rather than linguistic evidence from journalism. This study differs by adopting a corpus-driven phraseological analysis to critically compare how the NSL is discursively represented between China's and Anglo-American English-language press. The analytical frameworks draw on Sinclair's extended-unit-of-meaning model and co-selection categories (core, collocation, colligation, semantic preference, semantic prosody), and framing theory to detect key semantic categories and frames in media discourse.

Data description: Two corpora were compiled: the China Daily corpus (CD) and the Anglo-American media corpus (AA). CD collects related news reports from China Daily. AA consists of reports from The New York Times (NYT) and The Guardian. China Daily represents the Chinese government's stance; NYT and The Guardian are influential US/UK outlets with liberal, market-driven reporting. All texts were collected from May 22, 2020 to July 6, 2020 (pre-enactment hints through peak coverage). Data were gathered via LexisNexis using the query Hong Kong National Security Law; non-relevant materials were removed when the NSL was not the primary topic. Corpus sizes: Number of texts: CD 256; AA split across sources: NYT 85, The Guardian 94. Tokens: CD 121,123; AA: NYT 68,886 and The Guardian 96,561 (AA total 165,447). Reference corpus: NOW (News on the Web) for the same time span (~200 million words/month growth) was used for keyness comparisons. Research design: The study used Wmatrix (USAS semantic tagger) to compute key semantic categories and keywords with keyness against the NOW corpus. Statistical thresholds: only tags with frequency >5 and log-likelihood >10.83 (p < 0.001) were considered; effect size (log ratio) was also applied to mitigate limitations of significance testing. Prominent key semantic categories in both corpora included G (Government & Public), S (Social Actions, States & Processes), T (Time), and A (General & Abstract Terms). Prominent categories and their keywords were examined to establish frames used in representing the NSL. Concordance analyses of keywords helped diagnose central concepts. Keywords were grouped into four framing functions (politics and law; protests and crime; action and future; evaluation) based on shared attributes, following Entman's framing functions (problem definition, causal interpretation, moral evaluation, treatment recommendation). ConcGram 1.0 was used to extract recurrent two- and three-word concgrams to supplement keyword analysis. Frequent two-word concgrams found within stable three-word units (e.g., national security law) were treated as such. The patterns were grouped under the four framing functions. Finally, Sinclair's five co-selection categories (core, collocation, colligation, semantic preference, semantic prosody) guided phraseological analysis of keywords and concgrams to trace journalistic framing across the two media datasets.

Overall frames: Four framing functions were identified and contrasted across media: (1) politics and law; (2) protests and crime; (3) action and future; (4) evaluation. Politics and law: - The concgram national security law occurred 558 times (0.46%) in CD vs 264 (0.16%) in AA, indicating CD's stronger emphasis on publicizing the NSL concept. - CD collocational/coligational patterns around the NSL included protect/protects/protecting/protected (21), tailor/tailoring/tailored/tailor-made (9), peace/peaceful (6), necessary (5), framing the NSL as a tailored legal solution for stability, order, and rights protection by closing loopholes. - AA collocates included sweeping (11), draconian (5), controversial (5), looming (2), depicting the NSL as a barrier to freedom, democracy, and autonomy. - AA favored push (50; 0.03%), move (187; 0.11%), breach (25; 0.02%), often linked to China's/Beijing's/Mr. Xi's actions, constructing the NSL as Beijing's encroachment and breach of commitments (e.g., Sino-British Joint Declaration in 76% of breach uses). - The shared keyword government appeared 611 times in CD and 456 in AA. CD framed the Chinese government as including both central and SAR governments acting jointly; AA framed imposition by the Chinese (central) government. - Legal: CD (252; 0.21%) collocated with system/systems (98), loophole(s) (28), framework (12), rights (7); AA (118; 0.07%) with system (26), experts (22), framework (5), maneuver (4). Both emphasized the legal system, but CD framed legitimacy and closing loopholes; AA stressed threats to the legal system and rule of law. - One Country, Two Systems: 375 (0.31%) in CD vs 101 (0.06%) in AA. CD argued strengthening the principle; AA presented it as ending or being undermined. - Actors: CD highlighted NPC (149; 0.12%) with collocates safeguard, necessary, support, endorse, close loophole, draft/deliberate/review; semantic prosody: responsible, capable, recognized. AA highlighted Communist (208; 0.13%) and Xi's (19; 0.01%), collocating with propaganda, authoritarian, undermining freedoms; Xi's with attempts/actions/decisions/regime, constructing the NSL as Xi's decision. - Interference: CD used interference (81) with external/foreign at N-1 in 71.6%, condemning foreign intervention. Protests and crime: - CD: protests (74; 0.06%) co-occurred with violent/violence, unrest, chaos, threat, etc., in 82.4% of instances, construing protests as disastrous and unlawful. Protesters (45; 0.04%) collocated with radical/violent/anti-government (46.7%) and acts like vandalism, arson. - AA: protests (422; 0.26%) and protesters (364; 0.22%) were far more frequent. In 31.8% of protests cases, verbs like arrest/quash/stop/suppress indicated suppression. Movement (160; 0.10%) and demonstrations (70; 0.04%) often paired with pro-democracy/umbrella/democracy terms, framing protests as a pro-democracy movement. Protesters were portrayed in 97.8% of cases as political dissidents arrested under the NSL; AA did not generally condemn them. - Extradition: CD (27) collocated with triggered by, unrest; AA (60) with protest, sparked by. CD used it to highlight administrative/legal loopholes; AA used metaphors (rifle/machine gun) to dramatize NSL risks. - Dissent (AA 76; 0.05%) collocated with crack down on/silence/punish/suppress/stifle, emphasizing suppression of dissent. Action and future: - Future: CD (55; 0.05%) collocated with confidence/optimistic/prosperous; AA (88; 0.05%) with questions/worries/bleak, indicating divergent outlooks (stability/prosperity vs bleak future). - Sanctions: AA highlighted US-led sanctions (e.g., Hong Kong Autonomy Act) as responses; CD framed such sanctions as double standards and emphasized sovereignty. - CD emphasized safeguard (175; 0.14%) with patterns such as to safeguard national security law (147) and collocates enforcement mechanisms, rights, duty, determination, legal system, responsibility; and protect (97; 0.08%) with protect national security, protect Hong Kong. - AA emphasized bring (45; 0.03%) with change/catastrophe and likely (69; 0.04%) with end/curtail/anger/intensify/worsen, projecting worsening outcomes and political change impulses. - AA also discussed help (47; 0.03%) for Hong Kong people (e.g., BN(O) measures), indicating support/countermeasures. Evaluation: - Quotation-related concgram Hong Kong/said: CD (434; 0.36%) often quoted authorities (Carrie Lam, state officials) with positive semantic prosody (stability, rights, safeguard, freedoms, prosperity). AA (410; 0.25%) quoted Carrie Lam, pro-democracy activists, and US officials (e.g., Mike Pompeo), often framing Lam as aligned with Beijing and highlighting US/western condemnation. - CD used positive evaluatives: improve (52; 0.04%), important (35; 0.03%), necessary (54; 0.04%). AA used negative evaluatives: accused (34; 0.02%), denounced (21; 0.01%), sweeping (62; 0.04%). - AA highlighted criticism (45; 0.03%) in patterns criticism of/from and concerns (59; 0.04%), condemnation (23; 0.02%), stressing local and international criticism. CD emphasized international support, especially from BRI/developing countries (e.g., 53+20 countries at UNHRC expressing support).

The findings confirm a dichotomy consistent with positive self-presentation versus negative-other presentation. The Chinese press communicates the NSL's positive impacts: strengthening One Country, Two Systems, closing legal loopholes, ending violent protests, restoring order, safeguarding national security, and ensuring a brighter future. The Anglo-American press frames the NSL as a political move that breaches commitments, undermines One Country, Two Systems, threatens Hong Kong's legal system and autonomy, suppresses pro-democracy movements, and provokes international condemnation, darkening Hong Kong's future. These representations are shaped by socio-political contexts: strong state influence over Chinese media content helps explain minimal dissent in CD, while Anglo-American negativity aligns with long-observed anti-China narratives. Hong Kong functions as a frontline in a new geopolitical cold war between China and Western powers; the NSL is seen by China as consolidating sovereignty and order, and by the West as illegitimate and destabilizing to regional balance. The law's impact on One Country, Two Systems illustrates divergent emphases: intensifying the One Country principle versus blurring Two Systems' boundaries. The evaluative divergences also reflect broader US-China tensions over ideology, regional security, and global governance, with the NSL perceived by the US as a new challenge amid strategic competition and BRI-driven shifts.

Using a corpus-driven approach to phraseology and key semantic domains across news texts, the study reveals distinct frames and entrenched ideologies in Chinese versus Anglo-American media representations of Hong Kong's NSL. While both adhere to factual boundaries, they emphasize different aspects, reflecting ideological divides and geopolitical tensions. The study elucidates positive self-presentation and negative-other strategies, socio-political conditioning, geopolitical implications, and the NSL's role in influencing the One Country, Two Systems framework and escalating China-US tensions. The comparative corpus-driven phraseological methodology offers a lens for the linguistic turn in analyzing social issues and media discourse. Data availability: Datasets are available from the corresponding author on reasonable request.