Over the last year, Substack has ridden a wave of subscription newsletter frenzy in the U.S. media industry, successfully poaching reporters from outlets like The New York Times and Buzzfeed News to start their own publications on its platform. Now, the San Francisco–based company is setting its sights abroad. After raising an additional $65 million from investors, in recent months it has begun recruiting journalists in places like Romania, Brazil, and India, raising questions about how the company plans to navigate threats to press freedom as it grows internationally.

Like many content platforms, Substack occupies a murky space between software provider and full-blown publisher, though it’s often denied sharing much in common with the latter. Anyone can start a newsletter on Substack, and the company says writers retain total editorial independence, although the company collects a 10% flat fee from each paid subscription. But as the service enters countries where journalism can be dangerous, it may be forced to decide how much responsibility it’s willing to take for reporters and their work.

“When Substack is supporting local writers elsewhere, there’s some financial support, some income for you to write,” said Kirsten Han, a Singaporean freelance journalist who hosted her newsletter We, The Citizens on Substack until earlier this year. “But what happens if you say you’re being called in for an investigation? What happens if you are detained? What happens if you’re being harassed in your country?” (Han has previously contributed to Rest of World.)

In an emailed statement, a spokesperson for Substack said the company is “adamantly committed to free press and while we can’t control the actions of foreign governments, we staunchly defend press freedom on our own platform and with our own policies.”

Through a series of incentive programs, Substack is already providing some writers outside the U.S. with a number of different editorial resources. Rest of World spoke to current and former Substack contributors in Nigeria, Brazil, India, Singapore, and China, many of whom said it had awarded them grants as well as hired freelance editors, copy editors, designers, and mentors to shepherd their newsletter growth. That support staff is typically based in the U.S. and employed as contractors directly by Substack.

One reporter benefiting from some of these initiatives is Brazilian journalist Gaía Passarelli, who left her job as editor-in-chief of Buzzfeed Brazil this spring and recently launched a newsletter called Paulicéia, which documents life and culture in São Paulo in the wake of the pandemic. Passarelli is one of 12 winners of Substack Local, a year-long, $1 million program to support the launch of new local news publications on the platform. Nearly half of recipients reside outside of the United States and were hand-selected by a jury that included some of Substack’s most popular contributors, including Zeynep Tufekci and Anne Helen Petersen.

“When I got the winner announcement email, the first thing they asked was, Are you able to do this full time for a whole year? Because we are going to need your full dedication for this project,” Passarelli told Rest of World. She didn’t disclose how much Substack was paying her but said the company awarded her the amount she specified in her application without negotiation.

As part of the program, Substack offers Passarelli access to a mentor, a journalist based in the U.S. who helps her conceptualize her project. They discuss audience development goals and hash out the particulars of upcoming newsletter ideas. But because the mentor doesn’t speak Brazilian Portugese, they’re unable to read Passarelli’s finished product. While Substack publishes a number of newsletters in languages other than English, it currently cannot support languages that read right to left, and its navigation and customer service portals are available only in English. 

International Substack writers have run into a number of country-specific challenges using the platform. Last March, Nigerian journalist Joey Akan took his previous experience reporting on the West African music industry to launch the popular Substack newsletter Afrobeats Intelligence. He has been joined by other prominent Nigerian writers who have flocked to the platform — most recently David Hundeyin, an investigative journalist who was also named a winner of the Substack Local campaign.

But because Substack uses Stripe to process payments, writers in Nigeria can’t easily collect money from their newsletter subscribers. The digital payment service isn’t operational in many non-Western markets, Nigeria included. Akan says he eventually haggled his way into obtaining an American bank account but wants Substack to better accommodate non-American customers and writers. “They can find a way to create payment solutions that work better in a host country or region and use local payment partners to help with that,” Akan said.

After reaching out to a Substack representative this spring, Akan eventually signed up for Substack Bridge, a two-month mentorship program. He also received a grant from the company through another initiative to support writers impacted by the pandemic and is starting to work with a Substack-hired art director, who helps design logos and newsletter headers. “Substack has been very good to me,” Akan said.

At least one Substack reporter has already been subject to state pressure as a result of their reporting.

The use of Substack-hired editorial staff conflicts with some of the company’s public comments saying that it takes a “hands-off approach” to moderating its platform. While Substack maintains a short list of content guidelines, it claims not to have any direct involvement in editorial decision-making, including editing stories. Substack declined to answer questions about how it balances that position while paying to support writers editorially. It also didn’t specify whether, or how, it’s offering international writers one of the most important resources typically provided by traditional publications: legal support. 

Last year, Substack launched a legal defense program that offers up to $1 million in attorneys’ fees to writers who “publish work that may attract unreasonable legal pressure.” The program’s application form states that only U.S.-based writers are eligible, and the company has retained a boutique California-licensed firm to help run it. 

It’s unclear how often Substack may extend similar protection to journalists abroad. In response to a request for comment, a company representative connected Rest of World to Mumbai-based journalist and Washington Post columnist Rana Ayyub, who announced she was joining the platform last month. In July, the One Free Press Coalition highlighted Ayyub as part of a list of journalists who are “under attack for pursuing the truth.”

Since day one, [Substack has] been vocal about how they will take care of all the legal issues. They will hire a lawyer, and they will take care of the legalities. They said they will provide all necessary support and will not censor me,” Ayyub told Rest of World over a WhatsApp call. “I can only tell you based on what they have communicated to me.” 

Ayyub said she began speaking with Substack early this year, and, given the sensitivity of her work, her first question was about how much legal support the company could provide. In 2016, Ayyub self-published Gujarat Files: Anatomy of a Cover Up, a book which took aim at Indian Prime Minister Narendra Modi and included undercover audio recordings of politicians in India’s ruling Bharatiya Janata Party (BJP). 

Ever since, she says she’s struggled to find mainstream Indian outlets that will publish her investigative reporting. “Some of the biggest stories about what’s happening in India are not being published because Indian journalists are living in fear,Ayyub said, detailing death threats and government pressure she has faced.

Ayyub says Substack offers her a competitive payment contract, an editor, a designer, a subscription to Getty Images, health care, and access to a lawyer. “But more than any other reasons I joined Substack was because there was a complete absence of gatekeepers and censorship,” Ayyub said, echoing a statement she posted online.

Ayyub represents a standout addition to Substack’s roster of writers in India, and her presence on the platform may help bolster the company’s image as a supporter of ambitious journalism and press freedom. Recruiting investigative journalists, though, could also make Substack a target for governments that are hostile to their work. In June, authorities in Uttar Pradesh state launched a criminal investigation into Ayyub and several other journalists for sharing a video reported to depict Islamophobic violence. 

In China, Substack has already been blocked, according to GreatFire.org, a group that monitors internet censorship in the country. A number of China-focused writers have still found success on the platform, including Bill Bishop, who writes Sinocism, the first newsletter to ever launch on Substack. Chinese Characteristics, a long-form tech industry newsletter written by former venture capitalist Lillian Li, has also become widely popular. Li, who is based in China, says that Substack has offered her 12 hours of free copy editing a month and selected her to join the Substack Bridge mentorship program.

“I have a very international readership, and the typical reader is someone working in tech or investment,” Li told Rest of World in an email. A respected tech analyst, she says that Substack has yet to do much to internationalize its product. “Ideally, it should allow currency adjustments and price adjustments for customers from different regions. The navigation systems are all in English,” she explained.

At least one Substack reporter has already been subject to state pressure as a result of their reporting. In February, Han, the Singaporean journalist, said she was interrogated by local police after she covered a protest demanding better treatment for transgender students in Singapore schools, which was published on her Substack newsletter, We, The Citizens.

Han says she never notified Substack about the incident and didn’t expect them to intervene at the time. When asked to comment, a Substack spokesperson said over email that Han was welcome to reach out to discuss the incident now.

In March, Han decided to migrate her newsletter to a competing service called Ghost, after a number of writers accused Substack of giving a platform to transphobic authors. But when the interrogation happened, Han said she might have placed more responsibility on Substack if it had been directly involved in editing her piece, or was using her work to promote itself as a company.

“They gave me a small pandemic grant, but otherwise I was doing all this for myself,” Han said, thinking out loud. “But if they had used my newsletter as a new Substack initiative and were supporting writers in order to stand up for free speech around the world, then shit hits the fan, I mean, would it feel different?”