A/78/538 of Action, para. 10). Provisions protecting this fundamental freedom, in particular article 19 of the International Covenant on Civil and Political Rights and article 5 (d) (viii) of the International Convention on the Elimination of All Forms of Racial Discrimination, are central to how States approach preventing and addressing online racist hate speech. This is not to say that ensuring full respect for freedo m of opinion and expression and addressing online racist hate speech are easy tasks. There is, however, relevant guidance in international human rights law to help navigate such challenges and complexities. 37. The progressive interpretation of article 19 (3) of the International Covenant on Civil and Political Rights by the Human Rights Committee, including in paragraphs 22–36 of its general comment No. 34 (2011), as well as the work of the Special Rapporteur on the right to freedom of opinion and express ion, has made clear that measures to restrict freedom of opinion and expression must meet the criteria of legality, necessity, proportionality and legitimacy. 38. The provisions under article 19 of the International Covenant on Civil and Political Rights are complemented by those in article 18 thereof. Article 18 protects the right to freedom of thought, conscience, religion or belief. In article 18 (3), it is stated that: “Freedom to manifest one’s religion or beliefs may be subject only to such limitations as are prescribed by law and are necessary to protect public safety, order, health, or morals or the fundamental rights and freedoms of others.” 39. As indicated in paragraph 19 of general recommendation No. 35 (2013) of the Committee on the Elimination of Racial Discrimination, article 4 of the International Convention on the Elimination of All Forms of Racial Discrimination explicitly establishes that all measures taken to eliminate incitement and discrimination must afford due regard to the principles embodied in the Universal Declaration of Human Rights and the rights expressly set forth in article 5 of the Convention. As elaborated on above, article 5 (d) (viii) of the Convention includes the right to freedom of expression and opinion. Vague or overly broad restrictions on freedom of expression are open to abuse and risk undermining the rights of groups protected by the Convention. It is those already facing discrimination and exclusion who are the most vulnerable to the effects of restrictions on freedom of expression that do not meet the criteria of legality, necessity, proportionality and legitimacy ( A/74/486, para. 34). 38 Moreover, as indicated in the above-mentioned general recommendation and the Durban Declaration and Programme of Action, freedom of expression and opinion, including in an online context, play an important role in addressing harmful racial stereotypes and racial hatred. 40. As racist hate speech can amount to incitement to hostility, discrimination or violence, the Rabat Plan of Action provides additional guidance on the relationship between freedom of expression and the prohibition of incitement to hatred. The Rabat Plan of Action is the outcome document that followed a series of regional workshops organized by the Office of the United Nations High Commissioner for Human Rights in 2011. In paragraph 20 of the Rabat Plan of Action, it is recommended that distinction be made between three types of expression: expression that constitutes a criminal offence; expression that is not criminally punishable but may justify a civil suit or administrative sanctions; and expression that does not give rise to criminal, civil or administrative sanctions, but still raises concern in terms of tolerance, civility and respect for the rights of others. According to the Rabat Plan of Action, a high threshold is set for defining restrictions on freedom of expression, incitement to hatred, and for the application of article 20 of the International Covenant on Civil and __________________ 38 23-20290 See also general recommendation No. 35 (2013), paras. 28 and 29. 13/22