COMMISSION STAFF WORKING DOCUMENT Accompanying the document Communication from the Commission to the European Parliament, the Council and the European Economic and Social Committee Report on the 2019 elections to the European Parliament
Date: 2020-06-19
Institutions: Directorate-General for Justice and Consumers, European Commission
Subjects: European Parliament, European election, European electoral system, data processing, disinformation, election result, organisation of elections, parliamentary election, right to stand for election, right to vote

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 19.6.2020  SWD(2020) 113 final  COMMISSION STAFF WORKING DOCUMENT Accompanying the document Communication from the Commission to the European Parliament, the Council and the European Economic and Social Committee Report on the 2019 elections to the European Parliament      {COM(2020) 252 final}  
 
 
Contents 
1. 

Introduction ................................................................................................................................. 2 

2. 

Participation in the elections ....................................................................................................... 3 

2.1. 

The strongest turnout in a generation .................................................................................... 3 

2.1.1. Communication and citizens’ mobilisation ahead of the elections ...................................... 6 

2.2. 

Participation of specific groups ............................................................................................... 9 

2.2.1. 

EU citizens residing in a Member State other than their own ........................................ 9 

2.2.2. 

By age group ................................................................................................................. 13 

2.2.3. 

Gender .......................................................................................................................... 14 

2.2.4. 

Other underrepresented groups ................................................................................... 18 

Funding of projects supporting the enjoyment of EU electoral rights and the democratic 

2.3. 
participation of EU citizens ............................................................................................................... 22 

3. 

The European dimension and the exercise of EU electoral rights ............................................ 23 

3.1. 

European dimension ............................................................................................................. 23 

3.2. 

Supporting the exercise of EU electoral rights ..................................................................... 26 

3.3. 

Prevention of multiple voting ............................................................................................... 28 

4.  Addressing disinformation and protecting the integrity and resilience of the electoral process

31 

4.1.  Unprecedented cooperation: election networks and other actions .................................... 35 

4.1.1. 

National networks ............................................................................................................. 35 

4.1.2. 

European Cooperation Network on Elections .................................................................. 40 

4.2. 

Enhancing transparency and exposing disinformation ......................................................... 42 

4.2.1.  Member States .................................................................................................................. 43 

4.2.2. 

Political parties .................................................................................................................. 46 

4.2.3. 

Private companies ............................................................................................................. 47 

Interactions between social media companies and Member States’ authorities and 

4.2.4. 
political parties .................................................................................................................................. 49 

4.3. 

Data protection ..................................................................................................................... 51 

4.3.1. 

General .............................................................................................................................. 51 

4.3.2. 

Action by data protection authorities ............................................................................... 51 

4.3.3. 

Input from political parties ............................................................................................... 53 

4.3.4. 

New legal mechanism for data protection breaches by European political parties ......... 54 

4.4. 

Cybersecurity ........................................................................................................................ 55 

5.  Annex: Replies to the questionnaires ....................................................................................... 60 

1 

 
 
 
 
1. Introduction 

This Commission Staff Working Document accompanies the Report on the 2019 elections to 
the  European  Parliament.  It  follows  the  same  structure  as  this  Report  in  detailing  its 
findings.  

The  European  elections  are  among  the  largest  democratic  exercises  in  the  world.  In  May 
2019,  EU  citizens  directly  elected  751  Members  of  the  European  Parliament  (MEPs)  from 
over 15,000 parliamentary candidates, with over 250 million votes cast across the EU.1 

Before  the  elections,  the  Commission  published  a  package  of  measures  (‘the  electoral 
package’) aimed at securing free and fair elections. This package notably promoted: 

  enhanced  cooperation  between  competent  authorities  with  the  establishment  of 
elections  networks  at  national  and  at  European  level  to  protect  the  electoral 
process; 
improved transparency in political campaigning; 
increased clarity on the application of data protection requirements in the electoral 
context and promoted greater awareness and readiness to meeting the challenges of 
the online environment2;  

 
 

  awareness raising, monitoring and enforcement 

This  package,  coupled  with  the  Commission’s  initiatives  on  disinformation  –  the  code  of 
practice  on  disinformation  committed  to  by  IT  platforms3,  the  action  plan  against 
disinformation4  –  including  the  Rapid  Alert  System  and  the  counter-narrative  and  myth-
busting  network  –  contributed  to  securing  the  integrity  of  the  electoral  process  and 
maintaining voters’ confidence. 

Ahead  of  the  elections,  the  Commission  also  took  a  number  of  initiatives  to  support  the 
European dimension of the elections, building on the findings of Commission’s report on the 
2014  elections5  and  delivering  on  the  Commission’s  2017  EU  citizenship  report,6  and 
supporting the efforts of the European institutions, political parties and Member States.  

1 On 31 January the UK left the EU, and the UK’s elected Members ceased to be MEPs. The European Parliament reduced 
from 751 to 705 elected representatives, with 46 of the 73 seats vacated by the UK to be held in reserve, potentially for 
allocation to new countries joining the EU. The remaining 27 seats were redistributed among 14 EU countries, to better 
reflect  the  principle  of  degressive  proportionality  as  follows:  France  (+5),  Spain  (+5),  Italy  (+3),  Netherlands  (+3),  Ireland 
(+2),  Sweden  (+1),  Austria  (+1),  Denmark  (+1),  Finland  (+1),  Slovakia  (+1),  Croatia  (+1),  Estonia  (+1),  Poland  (+1)  and 
Romania (+1). Since then figures for UK candidates and voters have been removed from the data reporting on results of 
the  elections,  but  do  remain  in  some  other  data  where  relevant,  e.g.  data  reporting  on  public  opinion  from  before  the 
election. This is clearly marked where it is done. 
2 
2018, 
on 
https://ec.europa.eu/commission/presscorner/detail/en/IP_18_5681.  
3 https://ec.europa.eu/newsroom/dae/document.cfm?doc_id=54454.  
4  Jointly  issued  in  2018  by  the  European  Commission  and  the  High  Representative  of  the  Union  for  Foreign  Affairs  and 
Security Policy, https://eeas.europa.eu/sites/eeas/files/action_plan_against_disinformation.pdf.  
5 https://ec.europa.eu/info/sites/info/files/com_2015_206_en.pdf 
6 http://ec.europa.eu/newsroom/document.cfm?doc_id=40723 

September 

Adopted 

Union 

2018. 

State 

the 

the 

12 

of 

2 

 
 
                                                           
This report reviews these elements, as well as turnout and the implementation of EU law. It 
is based on: 

 

information  provided  in  particular  by  Member  States,  European  and  national 
political parties, and IT platforms in response to Commission questionnaires;7 

  direct feedback from citizens; and  
  Eurobarometer  surveys  and  other  studies  including  the  post-election  survey 

published by the European Parliament. 

2. Participation in the elections 

2.1.   The strongest turnout in a generation  

Of the EU citizens eligible to vote 50.66%8took part in the 2019 elections. This is the highest 
turnout  in  25  years  and  the  first  time  since  1979  that  turnout  for  the  elections  has 
increased.  While  there  has  been  an  increase  in  turnout  for  all  groups,  the  increase  was 
highest among young people and first-time voters (see section 2.2).9

Figure 1: Overall turnout in the European Parliament elections since 1979 

TURNOUT IN THE EUROPEAN PARLIAMENT 
ELECTIONS 1979-2019  (%) 

61,99 

58,98 

58,41 

56,67 

49,51 

45,47 

42,97 

42,61 

52.4 

80

60

40

20

0

E U - 9    
1 9 7 9  

E U - 1 0    
1 9 8 4  

E U - 1 2    
1 9 8 9  

E U - 1 2    
1 9 9 4  

E U - 1 5    
1 9 9 9  

E U - 2 5    
2 0 0 4  

E U - 2 7    
2 0 0 9  

E U - 2 8    
2 0 1 4  

E U - 2 7    
2 0 1 9  

Source: European Commission (based on the 2019 European election results as published by the European Parliament)10. 

Turnout  increased  in 20  Member  States,  with double-digit  increases  since  2014  in  Poland, 
Romania, Spain, Austria, Hungary, Germany and Czechia, as well as significant increases in 
countries with the lowest turnout, such as Slovakia, Croatia and Slovenia. However, turnout 
fell in eight Member States,11 albeit by no more than 3 percentage points (pps). Despite the 
overall  increase  in  turnout,  there  are  substantial  differences  between  Member  States, 
ranging from 88% in Belgium (where voting is compulsory)12 to 23% in Slovakia.  

7  In  total,  27  Member  States,  3  European  political  parties,  17  national  political  parties  from  7  Member  States,  and  4  IT 
platforms replied to the questionnaire. See the Annex. 
8 If the UK is excluded from the results, this number rises to 52.4%. 
9  The  turnout  for  young  people  aged  under  25  is  42%  (+14  percentage  points).  For  the  ones  aged  25–39,  it  is  47%  (+12 

percentages points). This remains below the turnout of those aged 55 or over (54%, +3 pp).  

10 https://europarl.europa.eu/election-results-2019/en/turnout/. 
11 Bulgaria, Portugal, Belgium, Ireland, Italy, Luxembourg, Malta and Greece in order of percentage decrease. 
12 Voting is compulsory in Belgium, Bulgaria, Greece, Cyprus and Luxembourg. 

3 

 
 
 
 
                                                           
Figure 2: Turnout in the Member States in the European elections 2014 compared to 2019 

Turnout - European Parliament elections 2014 and 2019 

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2014

2019

EU average 2014

EU average 2019

Source: European Commission, based on the 2019 European election results as published by the European Parliament. 
Note: The European average reflects a European Union of 27. 
The reasons citizens reported for voting in these elections appear to be increasingly based 
on  European  issues  rather  than  national  issues.  According  to  the  European  Parliament’s 
post-election survey13, the most common reason for voting in the 2019 elections was that 
people  felt  it  was  their  ‘duty’  as  EU  citizens  (52%).14  This  has  gained  in  importance  since 
2014 (+12 pp). Compared with 2014, respondents are now also more likely to say they voted 
because  they  are  in  favour  of  the  EU  (25%,  +11  pp)  and  because  voting  can  make  things 
change (18%, +6 pp). Other reasons included that the respondent always votes (35%, -6pp) 
and to support the political party they feel close to (22%, no change). Around a fifth (22%) of 
respondents  indicated  that  the  UK  leaving  the  EU  also  had  at  least  some  impact  on  their 
decision to vote. 

As regards the reasons for non-voting, no major changes were observed compared to 2014. 
Respondents to the post-election survey most cited a lack of trust in or dissatisfaction with 
politics  in  general  (22%)  and  a  lack  of  interest  in  politics  (18%).  Furthermore,  14%  of 
respondents believe that voting has no consequences or does not change anything.15  

13  European  Parliament,  The  2019  post-electoral  survey,  p.42,  see:  https://www.europarl.europa.eu/at-your-
service/files/be-heard/eurobarometer/2019/post-election-survey-2019-complete-results/report/en-post-election-survey-
2019-report.pdf. 
14 The figure however reveals a discrepancy between younger and older voters. While they are similar in voting out of a 
sense of duty and out of concern for climate change, younger citizens were more concerned with promoting human rights 
and democratic values and the economy. In contrast, older voters were more concerned with helping shape the future of 
the EU. 
15 Citizens also differ moderately in their reason for not voting according to age and gender. Older people and men were 
more likely to say that they were dissatisfied with politics, younger people and women were more likely to say they were 
uninterested in politics. Older people were also more likely to feel that their vote does not matter.  

4 

 
 
 
 
                                                           
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure 3: What are the main reasons why you decided to vote in the recent European Parliament elections? (Max 3 answers) 
(% - EU)16 

What are the main reasons why you decided to vote in the recent 
European Parliament elections? (Max 3 answers) (%)  

0

10

20

30

40

50

60

This is your duty as a citizen

You always vote

You are in favour of the EU

To support the political party you feel close to

You can make things change in voting in the…

To express your disagreement

You feel European or a citizen of the EU

To support your national government

To express disapproval of your national…

To influence the choice of the President of…

The EU plays an important role in your…

To express disapproval of the EU

You are very interested in European affairs

The information you received during the…

Because voting is compulsory

Other (spontaneous)

Don't know

35 

41 

41 

52 

25 

22 
22 

14 

18 

12 
12 
11 

12 

13 

11 

9 
9 

10 

8 

8 

5 

6 

5 

7 

5 

6 

4 
4 

2 
2 

3 

0 

0 
0 

June 2019

June 2014

Source: European Commission (based on the European Parliament post-election survey, 2019). 

According  to  the  same  survey,  the  main  issues  that  encouraged  EU  citizens  to  vote  in  the 
2019 elections17 were:  

combatting climate change and protecting the environment (37%);  

-  economy and growth (44%);  
- 
-  promoting human rights and democracy (37%); 
- 
- 

the way the EU should be working in the future (36%); and  
immigration (34%). 

Economy and growth were the main issues for voters in 15 Member States,18 while climate 
change and the environment were the main issues in eight Member States.19  

16  EU28  numbers  included  in  this  survey,  which  was  conducted  before  the  UK  withdrew  from  the  EU,  among  citizens 
eligible to vote at the time of the elections. 
17 Observed on average at EU level. Respondents were asked to select several issues. 
18 Bulgaria, Estonia, Ireland, Greece, Spain, Croatia, Italy, Cyprus, Latvia, Lithuania, Hungary, Poland, Portugal, Romania and 
Slovenia. 
19 Denmark, Germany, France, Luxembourg, the Netherlands, Austria, Finland and Sweden. 

5 

 
 
                                                           
Figure 4: What are the issues that made you vote in the recent European Parliament elections? Firstly? And then? (% the 
most mentioned answer by country)

What are the issues that made you vote in the recent 
European Parliament elections? (% the most mentioned 
answer) 

61  60 

56  55 

70  68 

62 

50  50  50  47  44  42  41  41  38 

51  50 

25 

49  46 

50 

45  45 

38 

75 

67 

80

70

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Promoting human rights and democracy
The way the EU should be working in the future
Immigration
Combating climate change and protecting the environment
Economy and Growth

Source: European Commission (based on the European Parliament post-electoral survey, 2019). 

2.1.1. Communication and citizens’ mobilisation ahead of the elections 
Studies conducted ahead of the European Parliament elections showed that citizens would 
be more likely to vote if they had been informed better about the content and implications 
of EU policies for their everyday lives.20  

The  Commission  implemented  a  wide  range  of  communication  measures,  campaigns  and 
outreach  activities  between  2014  and  201921  with  specific  measures  aiming  at  raising 
citizens’  awareness  of  how  EU  issues  affect  their  daily  life  and  the  importance  of  EU 
elections. Transparently showing the real-life impact of the European Union and driving up 
turnout are crucial elements of European democracy. 

In the run-up to the elections, the Commission enhanced its cooperation with the European 
Parliament  aiming  to  encourage  citizens  to  take  part  in  the  elections  and  take  informed 
decisions about The EU’s future. This cooperation took place not only at headquarters level 
in  Brussels,  but  also  between  the  Commission’s  Representations  and  the  European 
Parliament’s  Liaison  Offices  in  the  Member  States,  which  focused  their  communication 

20 Being better informed about the EU’s impact on daily life is the factor most likely to increase motivation  to vote in the 
European Parliament elections – Special Eurobarometer 477 on Democracy and elections in the EU, November 2018.  
21 See the White Paper on the future of Europe and the Commission’s contribution to the Sibiu Leaders’ meeting on 9 May 
2019. 

6 

 
 
 
 
                                                           
 
activities  increasingly  on  the  elections.  All  Commission  departments  took  part  in  the 
communication activities.22  

To support electoral participation, and in close cooperation with the European Parliament, 
the Commission communicated from the following different perspectives:   

-  What the EU does: explaining to citizens what the EU stands for, what it does and 
how it affects their daily lives, to encourage participation in the elections23 This 
included preventing, detecting and rebutting disinformation about the EU; 

-  Why  and  how  to  vote:  explaining  the  importance  of  the  elections  and  how  to 
vote. With many different national registration deadlines and voting methods, it 
was  essential  to  inform  mobile  EU  citizens  about  the  specific  formalities  and 
options affecting the exercise of their electoral rights (see section 2.2.4.);24  

-  How to engage: informing staff about the materials, tools and initiatives at their 
disposal  to  help  engage  citizens.  In  the  context  of  the  Commission’s  corporate 
campaigns,  examples 
‘back-to-university’ 
initiatives,  the  social  media  staff  advocacy  tool  SMARP,  and  the  ‘staff  as 
ambassadors’ campaign. 

‘back-to-school’  and 

include  the 

The Commission published an election communication toolkit in 24 languages and organised 
more  than  1,400  elections-related  events.25  These  efforts  complemented  the  three 
corporate campaigns that were launched ahead of the elections (Invest EU, #EUandME and 
EU Protects).  

The Commission actively encouraged political debates to highlight the European dimension 
of local problems, as well as the local dimension of European policy issues. Between 2014 
and 2019, the Commission organised events to engage with EU citizens in public debates on 
European issues and the future of Europe. It launched a series of town-hall-style debates in 
the run-up to the elections. Up to 30 April 2019, 1,57226 such citizens’ dialogues took place 
in 583 locations, attracting over 194 000 participants and 1.6 million online viewers via web 
streaming.27 Across The EU, 14 transnational dialogues were also organised through cross-

22 This included activities undertaken by Erasmus students and members of the European Solidarity Corps, European civil 
society organisations, the research community, stakeholders in the areas of agriculture, regional policy and transport, and 
citizens who had previously contacted the Europe Direct Contact Centre (Europe’s single phone number for citizens  — 00 
800 6 7 8 9 10 11) with questions about the EU. 
23  This  was  mentioned  by  43%  of  respondents  in  the  2018  autumn  Eurobarometer  survey  as  the  single  most  important 
reason to vote. See Special Eurobarometer 477 on Democracy and elections, November 2018. 
24 The Commission focused on the top 10 expat groups. It cooperated with the Parliament on this, for example by feeding 
content 
in  addition  to  contributing  to  the 
interinstitutional ‘Your Europe’ portal under the Commission’s responsibility. 
25  Joint  working  groups  of  the  representations  of  the  Commission  and  Liaison  offices  of  the  European  Parliament  were 
established  in  27  Member  States,  which  in  some  cases  also  included  Member  States’  authorities  in  Belgium,  Germany, 
Estonia, Latvia, Luxembourg, the Netherlands, Austria and Sweden. 
26 1,730 in total from November 2014 until the elections in May 2019. 
27 
https://ec.europa.eu/commission/sites/beta-political/files/euco-sibiu-citizensdialogues_en.pdf.  

into  the  EP’s  central  elections  page  www.european-elections.eu, 

-  key  conclusions’,  European  Commission,  7  May  2019, 

‘Citizens’  dialogues  and  citizens’  consultations 

7 

 
 
                                                           
border  partnerships  of  local  Europe  Direct  Information  Centres28  in  Member  States  and 
through a youth network that was established.  

The  Commission  Representations  and  European  Parliament  Liaison  Offices  also  organised 
numerous  events  of  different  formats  to  engage  citizens  in  a  multifaceted  manner.  They 
also communicated about the European elections during the 2019 Europe Day celebrations. 

Specific  events  were  organised  in  close  cooperation  with  the  European  External  Action 
Service’s  East  StratCom  Task  Force  and  focused  on  briefing  journalists  about  Russian 
election meddling and pro-Kremlin disinformation in electoral contexts. 

Almost  300  pieces  of  election-related  content  were  published  through  the  Commission’s 
social media accounts, which attracted significant interest from EU citizens. The Commission 
also  worked  closely  with  the  European  Parliament  in  developing  the  central  EU  elections 
webpage.29  The  Commission  furthermore  actively  promoted  the  European  Parliament’s 
‘Choose your future’ film.30 

On  their  part,  Member  States’  authorities  and  civil  society  organisations31  and  other 
bodies32  engaged 
in  numerous  awareness-raising  activities,  and  supported  citizens’ 
participation  including  through  information  on  the  functioning  of  the  EU  and  on  how  the 
elections work (voting process, parties and programmes).  

These  initiatives  included  citizens’  assemblies  and  ‘citizen  cabinets’.33  In  these  bodies 
citizens were actively involved in: 

 

 making policy recommendations; 

  producing election manuals; 

  sending letters to all first-time voters; 

  staffing helpdesks; 

  participating in paid outdoor and online advertisements;  

  putting up posters identifying polling stations; 

  providing  online  tutorials,  mobile  applications  and  financial  support  for  private 

media to cover the elections; and 

28  The  network  of  around  500  walk-in  centres  is  one  of  the  main  tools  of  the  European  Commission  to  engage  with  the 
public on EU-related topics at local and regional level. These centres are found in all EU Member States. Their mission is to 
inform  EU  citizens  at  local  and  regional  level  about  the  EU,  referring  them  to  specialised  information  sources  and  other 
services and networks. 
29 https://www.european-elections.eu./.  
30 The film was offered to the members of the Europa Cinemas network. 
31 See point 3.5 below. 
32 This included private sector. 
33 For instance, the Belgian authorities stated that Brussels-Wallonia established a ‘citizen cabinet’ which aimed to involve 
citizens in the making of policy recommendations with a focus on ‘fake news’. Citizens’ assemblies are deliberative bodies 
used in a number of Member States to enable citizens to contribute to policymaking. A notable example is Ireland, where 
they are commonly used to develop options for referenda. 

8 

 
 
                                                           
  acting as electoral ambassadors.34  

This was done using television, radio, websites and social media. 

Building on the experience gained from the cooperation between the European Parliament 
and the Commission ahead of the European elections and driven by the acknowledgement 
that  communication  is  a  shared  responsibility,35  the  directors-general  in  charge  of 
communication in both institutions signed a ’Joint Statement on Communicating together at 
the  service  of  citizens  and  European  democracy’  on  5  December  2019  in  order  to  further 
deepen their strategic communication partnership. 

2.2. Participation of specific groups 

Diversity  and  inclusion  of  all  groups  are  essential  elements  of  healthy  democracies.  This 
section  examines  the  electoral  participation  of  mobile  EU  citizens,  young  voters,  women, 
ethnic minorities, and citizens with disabilities36.  

2.2.1. EU citizens residing in a Member State other than their own 

A  growing  group  within  the  EU  are  ‘mobile  EU  citizens’:  people  who  moved  to  another 
Member  State  to  work,  live  or  study.  In  line  with  EU  law,  they  have the  right  to  vote  and 
stand as parliamentary candidates in European elections in their Member State of residence 
under the same conditions as nationals of that Member State.37 It is estimated that of the 
over 17 million mobile EU citizens in the EU, almost 14 million were eligible to vote.38 This is 
a  population  larger  than  several  Member  States,  and  accounts  for  over  3%  of  the  total 
voting population across the EU.  

Mobile  EU  citizens  can  also  vote  in  their  Member  State  of  origin.39  Eurobarometer  data40 
suggests that most EU citizens indicate they would prefer to exercise their voting rights for 
European elections in their country of residence (56%) rather than voting in their country of 
origin (26%). However, data obtained from Member States shows that  four times as many 
mobile  EU  citizens  registered  to  vote  in  the  European  elections  in  their  Member  State  of 
origin, than in their Member State of residence (see Table 1). 

34 Public figures promoted participation in the elections. 
35 ‘Europe in May 2019: Preparing for a more united, stronger and more democratic Union in an increasingly uncertain 
world’  – The European Commission's contribution to the informal EU27 leaders' meeting in Sibiu (Romania) on 9 May 
2019: 5 recommendations on communication, in particular ‘Recognise that communicating about the European Union is a 
joint responsibility for EU Member States, governments at all levels and EU institutions alike’. 
36 The data in this section excludes the data originally collected on UK citizens, to help ensure that future policymaking is 
based on data from current Member States (EU27). 
37 This right, enshrined in Article 22(2) TFEU and Article 39(1) of the EU Charter of Fundamental Rights, is given effect in 
Council Directive 93/109/EC of 6 December 1993 laying down detailed arrangements for the exercise of the right to vote 
and stand as a candidate in elections to the European Parliament for citizens of the Union residing in a Member State of 
which they are not nationals, OJ L 329, 30.12.1993, p. 34–38. Mobile EU citizens may vote on the lists of their countries of 
origin in line with applicable national law (e.g. postal voting, vote in consular posts etc.). 
38 3.68 millions of EU citizens resided in UK whereas 850 000 UK citizens resided in a Member State of the European Union. 
39  All  but  four  Member  States  (Czechia,  Ireland,  Malta  and  Slovakia)  allow  for  some  possibility  of  voting  from  another 
Member State, either at an embassy/consulate, by post or on the internet. Denmark, Germany, Ireland, Cyprus and Malta 
limit the right to vote in the European elections in their state of origin when their citizens have been resident outside their 
territory for a certain period. Conditions vary. 
40 Special Eurobarometer 477 – Democracy and Elections, November 2018.  

9 

 
 
                                                           
A  relatively  low  number  of  mobile  EU  citizens  made  use  of  their  electoral  rights  in  the 
elections. Data received from the Member States shows that the registration of mobile EU 
citizens  in  their  countries  of  residence  remains  low  across  the  EU,  although  the  numbers 
vary greatly between Member States (as does the availability of relevant data), from 0.1% in 
Croatia and 0.2% in Latvia, to 17% in Spain and 24% in Malta.  

Table 1: national and non-national (‘mobile’) EU citizen voters on the electoral roll 

Resident 
nationals on 
electoral roll 
in own 
country 

Non-resident 
nationals on 
electoral roll 
in own 
country 

Resident non-
national EU 
citizen  

Resident non-
national EU 
citizen on 
electoral roll 
in resident 
country 

Proportion of 
national 
residents to 
non-national 
residents on 
roll 

Proportion of 
non-resident 
to resident 
nationals on 
roll 

Member 
State 

Belgium 

Bulgaria 

Czechia 

Denmark 

7 989 802 

6 288 656 

8 314 451 

4 222 135 

Germany 

61 361 569 

Estonia 

Ireland 

Greece 

882 232 

3 304 052 

9 922 294 

54 832 

8 148 

- 

636 

15 294 

58 408 

1 112 

14 865 

755 569 

- 

213 310 

4 219 314 

4 243 327 

15 640 

- 

- 

Spain 

34 803 796 

582 036 

2 137 901 

France 

Croatia 

45 800 000 

1 250 000 

- 

3 678 130 

33 569 

15 992 

Italy 

49 207 309 

1 673 837 

Cyprus 

Latvia 

Lithuania 

Luxembourg 

624 487 

1 408 563 

2 449 759 

261 513 

6 135 

2 168 

62 525 

862 

Hungary 

7 889 638 

115 325 

Malta 

353 267 

Netherlands 

13 044 534 

Austria 

Poland 

6 332 782 

30 005 000 

Portugal 

9 318 580 

Romania 

18 267 618 

Slovenia 

Slovakia 

Finland 

Sweden 

1 609 705 

4 429 801 

4 256 326 

7 359 384 

- 

39 311 

44 723 

106 000 

688 898 

384 943 

94 158 

- 

240 711 

75 624 

- 

158 601 

13 958 

5 330 

200 240 

113 285 

74 956 

- 

- 

- 

158 915 

- 

21 711 

- 

88 019 

275 434 

73 251 

- 

2 286 

- 

202 106 

1 618 

84 313 

15 367 

365 603 

264 915 

13 

93 848 

10 559 

28 

331 

0 

3 390 

18 376 

56 637 

38 672 

2 500 

10 751 

114 

1 000 

824 

7 444 

49 072 

0.9% 

- 

- 

- 

0.3% 

0.2% 

2.6% 

0.2% 

1.1% 

0.6% 

0.0% 

0.2% 

1.7% 

- 

0.0% 

0.0% 

0.0% 

5.2% 

0.4% 

0.6% 

0.0% 

0.1% 

0.0% 

0.1% 

- 

0.2% 

0.7% 

0.7% 

0.1% 

- 

0.0% 

0.0% 

6.6% 

0.0% 

0.1% 

1.7% 

2.7% 

0.9% 

3.4% 

1.0% 

0.2% 

2.6% 

0.3% 

1.5% 

- 

0.3% 

0.7% 

0.4% 

7.4% 

2.1% 

5.8% 

- 

5.7% 

1.0% 

Total 

343 385 383 

5 554 120 

12 711 502 

1 303 018 

Source: Replies from Member States to the Commission’s questionnaire, 2019, see the Annex. 

Most Member States do not collect data on the effective turnout of mobile EU citizens that 
registered  to  vote.  Those  that  do,  report  that  up  to  a  half  of  the  registered  mobile  EU 
citizens vote: Czechia (50%), Finland (50%) and Cyprus (30%). 

In 21 Member States, 168 mobile EU citizens exercised their right to stand as a candidate in 
the elections. This represents a consistent trend compared to 170 candidates in 2014. Out 

10 

 
 
 
 
of the total number of these candidates (representing 1% of the total number of candidates 
that stood), 3 MEPs were elected in France and 2 in the United Kingdom.  

Table 2: national and non-national (‘mobile’) EU citizens candidates 

MEMBER STATE 

OWN NATIONALS 
AS CANDIDATES 

NON-NATIONAL EU 
CITIZEN CANDIDATES  

NON-NATIONAL EU 
CITIZENS ELECTED 

Belgium 
Bulgaria 
Czechia 
Denmark 
Germany 
Estonia 
Ireland 
Greece 
Spain 
France 
Croatia 
Italy 
Cyprus 
Latvia 
Lithuania 
Luxembourg 
Hungary 
Malta 
Netherlands 
Austria 
Poland 
Portugal 
Romania 
Slovenia 
Slovak Republic 
Finland 
Sweden 
United Kingdom 
Total 
Source: Replies from Member States to the Commission’s questionnaire, 2019, see the Annex. 

260 
316 
840 
135 
1 358 
66 
58 
1 195 
- 
2 652 
396 
- 
72 
244 
300 
58 
291 
40 
306 
236 
866 
482 
476 
- 
336 
265 
553 
574 
12 375 

37 
2 
1 
- 
22 
0 
1 
- 
20 
34 
0 
2 
- 
2 
1 
2 
0 
1 
2 
14 
- 
1 
1 
1 
1 
4 
3 
16 
168 

0 
0 
0 
0 
0 
0 
0 
- 
- 
3 
0 
- 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
0 
- 
0 
0 
0 
2 
5 

11 

 
 
Figure 5: non-national (‘mobile’) EU citizen candidates standing in the Member States 

NUMBER OF NON-NATIONAL CANDIDATES 
PER MEMBER STATE  

7
3

4
3

2
2

0
2

M
U

I

G
L
E
B

E
C
N
A
R
F

N

I

A
P
S

Y
N
A
M
R
E
G

4
1

A

I

R
T
S
U
A

4

D
N
A
L
N

I
F

3

N
E
D
E
W
S

2

1

,

D
N
A
L
E
R

I

,

A
T
L
A
M

,

A

,

I

A

I

H
C
E
Z
C

N
A
U
H
T
I
L

,

A

A

I

I

N
E
V
O
L
S

,

A

I

K
A
V
O
L
S

N
A
M
O
R

,
L
A
G
U
T
R
O
P

,

A

I

V
T
A
L

,
Y
L
A
T
I

,

A

I

R
A
G
L
U
B

E
H
T

,

G
R
U
O
B
M
E
X
U
L

S
D
N
A
L
R
E
H
T
E
N

Source: Replies from Member States to the Commission’s questionnaire, 2019, see the Annex. 

Mobile  EU  citizens  still  face  challenges  in  exercising  their  electoral  rights,41  for  example 
regarding  registration  on  the  roll.  Registration  procedures  differ  from  country  to  country 
and  can  be  difficult  to  implement  for  non-nationals  aiming  at  voting  in  their  country  of 
residence.42 These procedures may create concerns for mobile EU citizens where there is a 
lack  of  clarity  about  which  election  they  are  registering  for,43  and  with  regard  to  their 
obligations in Member States where voting is compulsory.44  

A study45 on remote voting solutions46 conducted on behalf of the Commission, found that 
issues can also arise from insufficient remote voting options,47 as well as the administration 

41 See point 4.1. 
42 Article 9 of Council Directive 93/109/EC requires Member States to ‘take the necessary measures to enable a Community 
voter who has expressed the wish for such to be entered on the electoral roll sufficiently in advance of polling day.’ Article 
12  requires  Member  States  to  inform  mobile  citizens  in  good  time  and  in  an  appropriate  manner  of  the  conditions  and 
detailed arrangements for the exercise of the right to vote in that State.  
43  In  some  Member  States,  such  as  Ireland,  enrolment  in  the  Register  of  Electors  will  cover  all  relevant  elections.  Other 
Member States, such as Germany, maintain different electoral rolls for different types of election. 
44 Some Member States, including Belgium, Greece and Luxembourg provide for compulsory voting for their own nationals, 
and  have  differing  approaches  towards  registered  non-national  citizens.  For  instance,  Belgium  extends  the  obligation  to 
vote to non-nationals on the electoral roll, but permits such citizens to indicate that they no longer wish to exercise this 
right. Any such obligations must in any event be interpreted compatibly with the prohibition for citizens from voting more 
than once in the European elections. 
45  See  Commission  study  on  remote  voting:  https://ec.europa.eu/info/policies/justice-and-fundamental-rights/eu-
citizenship/electoral-rights/studies_en. 
46 Postal voting, proxy voting, voting in consulates and embassies. 

12 

 
 
 
                                                           
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
of  such  options,  such  as  with  letters  being  sent  too  late,  or  insufficient  provisions  being 
made to  enable  citizens  to  vote remotely.48  It  furthermore found  that  when  implemented 
effectively,49  remote  voting  solutions  can  support  mobile  citizens  in  the  exercise  of  their 
voting rights.50  

Before  the  elections,  the  Commission  promoted  the  sharing  of  best  practices  among 
Member States to encourage mobile EU citizens to vote, and provided specific support and 
information on voting and standing as a parliamentary candidate, including:  

- 

information  on  voting  formalities  and  deadlines  through  the  Your  Europe  advice 
portal;51  

-  practical  information  on  formalities  to  be  completed  and  voting  methods  through 
the central EU elections webpage and factsheets, produced in cooperation with the 
European Parliament;  
support to projects under its Rights, Equality and Citizenship programme (see section 
2.3); and 

- 

-  a targeted social media campaign encouraging mobile EU citizens to vote. 

2.2.2. By age group 

Turnout  among  young  people  and  first-time  voters  increased  significantly  for  the  2019 
elections:  these  increases  drove  turnout  figures  up,  exceeding  any  increase  for  other  age 
groups.52 According to recent data,53 44% of 18-2454 year olds indicated they had voted in 
the 2019 elections (an increase of 50%) compared to a youth turnout of only 28% in 2014. 
The turnout also increased for the 25-39 age group, rising from 35% to 49%.55  

This is also reflected in the elected representatives: 21% of the new European Parliament or 
158 of the MEPs are under the age of 40.  

The oldest current Member is 82 years old and the youngest is 21, the youngest ever sitting 
MEP.  

47 Postal voting is provided for in 15 Member States, proxy in 4 Member States, e-voting in 1. Voting in diplomatic missions 
is possible for 21 Member States 
https://www.europarl.europa.eu/RegData/etudes/ATAG/2018/623556/EPRS_ATA(2018)623556_EN.pdf 
48 e.g. slow or cumbersome postal voting procedures, insufficient voting booths and staffing at consulates 
49  With  good  communications  to  inform  citizens  of  their  voting  options  based  on  straightforward  procedures  and  with 
realistic deadlines and sufficiently well-resourced facilities. 
50 The same applies to other groups with particular needs, such as citizens with disabilities. 
51 https://europa.eu/youreurope/citizens/residence/elections-abroad/european-elections/index_en.htm.  
52  Despite  the  increased  turnout  among  younger  people,  the  overall  voter  population  continues  to  show  a  strong 
representation among older people, including 43% aged 55 or over (unchanged from 2014). 
53 European Parliament post-election survey (see footnote 9), p. 22. 
54 Except in Austria, where this group includes ages 16-24, and Greece, where it includes 17-24, as voters become eligible 
younger in those countries. 
55 European Parliament post-election survey (see footnote 9), p. 22.  

13 

 
 
 
 
                                                                                                                                                                                     
Table 3 – Turnout by demographic group 

Voted 2014  Voted 2019  Diff. ‘19-’14 
(percentage 
points) 

EU27 

Gender 

Man 

Woman 

Age 

16/18-24 

25-39 

40-54 

55+ 

Education (end of) 

15- 

16-19 

20+ 

Still studying 

43% 

52% 

45% 

41% 

28% 

35% 

45% 

51% 

43% 

38% 

51% 

37% 

54% 

51% 

44% 

49% 

53% 

56% 

47% 

50% 

61% 

53% 

+8  

+7 

+8 

+16 

+14 

+8 

+5 

+4 

+12 

+10 

+16 

Voted 2014  Voted 2019  Diff. ‘19-’14 
(percentage 
points) 

Source: European Commission (based on European Parliament post-election survey, 2019).56 

2.2.3. Gender 

The  EU  is  committed  to  gender-balanced  representation  and  participation  in  European 
political  life.  The  full  participation  of  women  in  politics  and  in  all  aspects  of  the  political 
process  is  essential  for  building  and  sustaining  strong  and  vibrant  democracies.  Women’s 
including  greater 
political  participation  results 
responsiveness to people’s needs and more trust.  

in  tangible  gains 

for  democracy, 

Women  face  challenges  in  exercising  their  political  rights,  due  to  various  forms  of  sexism, 
harassment  and  violence,  including  online.  Research  shows  that  violent  online  content 
targeted against women is an emerging form of violence, with women politicians and other 
women active in public life particularly affected.57 

56 This table has been adapted from the post-election survey, to show numbers for EU27. 
57 According to a 2018 study by the Inter-Parliamentary Union and the Parliamentary Assembly of the Council of Europe, 
85.2% of women parliamentarians reported having experienced psychological violence during their terms in office. 46.9% 

14 

 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
 
The  participation  and  representation  of  women  increased  in  the  2019  elections.  Turnout 
increased  among  women  compared  to  the  previous  election,  reducing  the  gender  gap  in 
voter  turnout  from  4  pps  in  2014  to  3  pps.58  The  number  of  female  MEPs  also  increased 
from 37% to 39.4%. There remain, however, major differences between Member States and 
a  number  of  challenges persist.  Only  Finland  and  Sweden  elected  more  women  than  men 
with 8 out of 14 and 11 out of 21 seats being taken by women respectively. Five Member 
States  elected  as  many  women  as  men  (Denmark,  Latvia,  Luxembourg,  Malta,  Slovenia). 
France, Ireland, the Netherlands and Portugal each only have one more male MEP than they 
have  female  MEPs.  Five  Member  States  elected  at  least  40%  of  each  gender  (Denmark, 
Ireland,  Spain,  Italy  and  Portugal).  Estonia,  Bulgaria,  Greece,  Lithuania,  Romania  and 
Slovakia elected fewer than 30% female MEPs. All MEPs from Cyprus are men.  

Figure 6: Female candidates vs. female Members of the European Parliament 

0%

10%

100%

70%

80%

20%

30%

40%

60%

57% 

31% 

50% 

22% 

50% 

45% 

48% 

47% 

41% 

39% 

39% 

39% 
41% 

52% 
50% 
50% 
50% 
50% 
50% 
49% 
48% 
48% 
46% 
44% 
42% 
42% 

FEMALE CANDIDATES VS. FEMALE MEMBERS OF 
50%
90%
THE EUROPEAN PARLIAMENT 
[CATEGORY NAME] 
[CATEGORY NAME] 
[CATEGORY NAME] 
[CATEGORY NAME] 
[CATEGORY NAME] 
[CATEGORY NAME] 
[CATEGORY NAME] 
[CATEGORY NAME] 
[CATEGORY NAME] 
[CATEGORY NAME] 
[CATEGORY NAME] 
[CATEGORY NAME] 
[CATEGORY NAME] 
[CATEGORY NAME] 
[CATEGORY NAME] 
[CATEGORY NAME] 
[CATEGORY NAME] 
[CATEGORY NAME] 
[CATEGORY NAME] 
[CATEGORY NAME] 
[CATEGORY NAME] 
[CATEGORY NAME] 
[CATEGORY NAME] 
[CATEGORY NAME] 
[CATEGORY NAME] 
[CATEGORY NAME] 
[CATEGORY NAME] 
[CATEGORY NAME] 
Column2

39% 
39% 
38% 
38% 
36% 
35% 
33% 

28% 
Female Candidates

30% 
32% 
34% 

29% 
29% 
27% 

Female MEPs

Male MEPs

43% 
43% 

24% 

18% 

24% 

32% 

35% 

21% 

24% 

50% 

43% 

47% 

50% 

42% 

21% 

0% 

Male Candidates

of the respondents reported having received death threats or threats of rape and beatings directed against themselves or 
against their children and other family members, mainly delivered through social media and e-mail.  
58 In some countries the turnout of women increased markedly for instance in Finland from 38% to 43.4%. 

15 

 
 
 
                                                                                                                                                                                     
Source: European Commission, based on European Parliament’s data.59 

Although  some  Member  States  have  legislation  in  place  to  ensure  gender  balance  for 
MEPs,60 this legislation can vary from 33% to 50% for gender balance and does not always 
cover  candidatures.  In  Hungary,  Malta,  Czechia,  Slovakia  and  Cyprus,  more  than  70%  of 
candidates were men.  

59  See  https://europarl.europa.eu/election-results-2019/en/mep-gender-balance/2019-2024/.  At  the  time  of  the  data 
collection, the Netherlands and Spain had not confirmed all of their Member of European Parliament yet. 
60 Legislated quotas applied in 11 countries (Belgium, Greece, Spain, France, Croatia, Italy, Luxembourg, Poland, Portugal, 
Romania and Slovenia) at the European Parliament elections in 2019 (EP Briefing March 2019 ‘Women in politics in the EU 
– State of play’). 

16 

 
 
 
 
 
 
 
 
                                                           
Figure 7: Probability of being elected to the 2019 European Parliament for male and female candidates  

Source: European Commission (based on European Parliament’s data).61 

61 
https://www.europarl.europa.eu/news/en/press-room/20190516BKG51011/european-elections-2019-country-sheets. 

https://europarl.europa.eu/election-results-2019/en/mep-gender-balance/2019-2024/ 

See 

and 

17 

 
 
 
                                                           
Figure 7 shows the Member States in which it is more likely that women candidates would 
be elected compared to male candidates.62 Female candidates are more likely to be elected 
in Malta (1 out of 3 female candidates) and Ireland (1 out of 5). For most other countries, 
the  probability  of  being  elected  is  fairly  balanced  between  male  and  female  candidates. 
However, a large discrepancy remains for Cyprus, where none of the 20 female candidates 
were  elected,  while  6  of  the  52  male  candidates  took  their  seats  in  the  European 
Parliament.  

In  the  run  up  to  the  elections,  the  Commission  asked  its  Advisory  Committee  on  Equal 
Opportunities for Women and Men63 to provide examples of measures to promote women’s 
participation in the elections. Some are outlined below.  

Examples of measures reported by Member States to promote women’s participation 

Several  Member  States  referred  to  national  laws  that  introduced  a  quota  system  for  the  lists  of 
candidates, linking the allocation of public funding for political parties to the promotion of political 
participation  of  women  (Ireland)  or  introducing  a  general  obligation  for  political  parties  to  have 
gender-balanced  candidate  lists  (Romania).  Others  reported  that  legislation  to  promote  gender 
balance in political life is being prepared (Malta) or being considered (Cyprus). 

Civil  society  has  also  been  active  in  promoting  female  turnout  and  participation  in  elections.  For 
instance,  prior  to  the  EU  elections  in  Finland,  Eurooppanaiset,  a  Finnish  non-governmental 
organisation,  led  a  year-long  campaign  that  included  seminars  and  various  events  to  encourage 
women to vote  and increase  women’s participation in the EU institutions. The  National Council of 
Women of Finland (together  with its member organisations) led a social media campaign with the 
tag lines: ‘vote for a female candidate’ and ‘it’s time for a Female EU Commissioner.’ A list of female 
candidates was compiled and a conference with the European Parliament Liaison Office took place 
to increase women's participation in the EU titled: ‘Is the European Union also for women?’ 

2.2.4. Other underrepresented groups 

The President of the Commission stated in her political guidelines, ‘in business, politics and 
society  as  a  whole,  we  can  only  reach  our  full  potential  if  we  use  all  of  our  talent  and 
diversity.’64  It  is  essential  that  all  groups  participate  in  the  political  process.  Yet  certain 
groups  continue  to  face  difficulties  when  taking  part 
in  elections  and  remain 
underrepresented.  

Aside  from  women,  this  includes  mobile  EU  citizens,  ethnic  minorities,  people  with  a 
disability, younger people, people from disadvantaged backgrounds, and people from areas 
which  have  seen  depopulation,  unemployment  and  demographic  change.  These  groups 

information  on  this  committee,  see 

62 For instance in Malta, 33% of all female candidates were elected and only 9% of male candidates. This reflects, in part, 
the number of candidates. Malta saw 9 female and 32 male candidates participate. 
63  For  more 
in  the  Register  of  Commission  Expert  Groups: 
https://ec.europa.eu/transparency/regexpert/index.cfm?do=groupDetail.groupDetail&groupID=1238&NewSearch=1&New
Search=1.  
64  President  Ursula  von  der  Leyen,  A  Union  that  strives  for  more: My  agenda,  Political  Guidelines  for  the  next  European 
Commission 2019-2024. 

its  pages 

18 

 
 
                                                           
share  a  lower  representation  in  the  voting  activity  and  in  the  Parliament  than  their 
representation in the population.  

The  Commission  issued  a  Recommendation  in  February  201865  calling  on  Member  State 
authorities to meet in spring 2018 to exchange best practices to enable underrepresented 
groups  to  exercise  their  electoral  rights.  These  issues  were  also  discussed  at  the  2018 
Fundamental  Rights  Colloquium  dedicated  to  Democracy  in  Europe66.  Exchanges  of  best 
practice  take  place  in  the  expert  group  on  electoral  matters67  and  the  European 
Cooperation Network on Elections (see Section 4.1.2.).  

Data on regional voting behaviour across The EU is not available. However, certain regions, 
and  particularly  rural  areas,  are  affected  by  demographic  and  socioeconomic  challenges68 
which could affect their electoral participation69. The trend in rural areas facing important 
challenges is,  in  a number  of  cases,  aligned  with  the  vote  in  urban  and  industrial zones  in 
decline. 

Regarding the territorial dimension, there appear to be differences in a number of countries 
in the levels of trust in the EU reported by rural, small and large towns70. 

In  the  absence  of  official  data  on  ethnic  and  racial  minority71  participation,  civil  society 
organisations  have  published  their  own  analyses.  The  analysis  of  the  European  Network 
Against  Racism  shows  an  increase  in  ethnic  minority  representation  compared  to  the 

65  Commission  Recommendation  (EU)  2018/234  of  14  February  2018  on  enhancing  the  European  nature  and  efficient 
conduct of the 2019 elections to the European Parliament, OJ L 45, 17.2.2018, p. 40–43. Following the Recommendation, 
Member States’ authorities, with Commission support, met on 25 April 2018 to exchange practices on how to best foster 
the democratic participation of EU citizens (including mobile EU citizens and other underrepresented groups). This included 
the  exchange  of  best  practices  on  i)  awareness  raising  and  communications  activities;  ii)  candidacy  funding  for  specific 
underrepresented groups; iii) support networks, community championing etc.; iv) adjustments to help people to vote and 
stand as a candidate; v) measures to assist officials in managing local and European elections; vi) measures to support the 
European  dimension  of  the  elections  and  to  support  campaigning  that  is  focused  on  European  issues  (e.g.  display  of  EU 
party logos in manifestos and transparency about European party affiliation); and vii) measures to support remote voting 
solutions and other practical simplifications. 
66https://ec.europa.eu/info/events/annual-colloquium-fundamental-rights/2018-annual-colloquium-fundamental-rights-
2018-nov-26_en. 
67 https://ec.europa.eu/transparency/regexpert/index.cfm?do=groupDetail.groupDetail&groupID=617. 
68 
https://ec.europa.eu/eurostat/web/products-statistical-books/-/KS-HA-19-001  
69 
discontent 
70 Scipioni, M., Tintori, G., Alessandrini, A., Migali, S. and Natale, F., Immigration and trust in the EU, EUR 30042 EN, 
Publications Office of the European Union, Luxembourg, 2019, ISBN 978-92-76-14661-2 (online), doi:10.2760/76114 
(online), JRC118855 
https://publications.jrc.ec.europa.eu/repository/bitstream/JRC118855/immigration_and_trust_in_the_eu_1.pdf 
71  There  is  no  generally  accepted  definition  of  the  term  ‘minority’  in  the  EU.  This  lack  of  definition  has  also  been 
acknowledged  in  relation  to  various  international  conventions  and  treaties.  Francesco  Capotorti,  in  his  role  as  Special 
Rapporteur to the United Nations, proposed a definition that is now commonly used: ‘A group numerically inferior to the 
rest  of  the  population  of  a  State,  in  a  non-dominant  position,  whose  members  -  being  nationals  of  the  State  -  possess 
ethnic, religious or linguistic characteristics differing from those of the rest of the population and show, if only implicitly, a 
sense of solidarity, directed towards preserving their culture, traditions, religion or language.’ (Capotorti, 1979, par. 586). 

https://ec.europa.eu/regional_policy/en/information/publications/working-papers/2018/the-geography-of-eu-

Demographic 

and  way 

European 

societies 

impacts 

various 

change 

life. 

has 

on 

of 

19 

 
 
                                                           
previous  mandate  of  the  European  Parliament.72  However,  this  amounts  to  5%  of  MEPs, 
whereas the European Network Against Racism estimates that ethnic minorities make up at 
least 10% of the EU population. Moreover, the number of elected parliamentary candidates 
has decreased for some groups. In the case of the Roma minority, the number has dropped 
from five to three.59 

For  ethnic  minorities,  entering  candidate  lists,  registering  for  elections  or  fulfilling  other 
electoral  procedures  can  be  more  demanding  than  for  the  rest  of  the  population.  For 
instance, voters belonging to certain communities, such as the Roma, are more likely to face 
difficulties  in  accessing  voter  registration  procedures.  This  is  in  part  due  to  a  lack  of 
documentation, a lack of clarity about the procedural requirements needed to vote (such as 
how to provide valid proof of address), and support in completing these steps.73 

No data are available regarding participation of people with disabilities74. A report published 
by the  European  Economic  and  Social  Affairs  Committee75    before  the  elections  estimates 
that 800,000 EU citizens from 16 Member States are in practice deprived of the exercise of 
their  right  to  participate  in  the  elections  because  of  their  disability  or  mental  health 
problems61. Research undertaken by the Fundamental Rights Agency indicates that persons 
with intellectual disabilities are generally underrepresented among elected persons76. 

Citizens with disabilities face difficulties when participating in elections77. The report of the 
European  Economic  and  Social  Affairs  Committee  found  that  in  all  Member  States  certain 
laws or organisational arrangements limit the ability of people with disabilities to participate 
in  elections.  For  instance,  in  18  Member  States,  visually  impaired  voters  cannot  vote 
independently as they can only entrust somebody accompanying them to cast their vote on 
their  behalf.  In  many  countries,  polling  stations  are  designated  by  a  citizen’s  place  of 
residence.  In  12  Member  States,  it  is  not  possible  to  choose  another  station  that  would 
better accommodate voters with a specific disability. In eight Member States, citizens who 
cannot get to a polling station are not able to vote, because they do not have the option of 
an  alternative  form  of  voting  (postal  voting,  voting  by  mobile  ballot  box  or  electronic 
voting). However, many people with disabilities, even when given the option of alternative 

in 

2019, 

72  The  European  Network  Against  Racism,  ‘ENAR’s  Election  Analysis:  Ethnic  Minorities  in  the  New  European  Parliament 
2019-2025’, 
https://www.enar-eu.org/IMG/pdf/2019_06_racial_diversity_eu_ 
parliament_elected_meps_final.pdf. 
73  Study  conducted  for  the  Commission  by  the  network  of  academics  on  EU  citizenship  on  the  participation  of 
underrepresented  citizens 
the  EU,  2018  https://ec.europa.eu/info/policies/justice-and-fundamental-rights/eu-
citizenship/electoral-rights/studies_en. 
74  15.1%  of  women  and  12.9%  of  men  aged  15-64  report  a  difficulty  with  a  basic  activity.  See  Eurostat 
https://ec.europa.eu/eurostat/statistics-explained/images/8/8c/Infographic_Disability_statistics_final.png. 
75  Real 
https://www.eesc.europa.eu/sites/default/files/files/qe-02-19-153-en-n.pdf.  
76  Fundamental  Rights  Agency,  ‘Developments  in  the  right  to  vote  of people  deprived  of  legal  capacity  in EU  Member 
States’, 2019. 
77 All EU Member States, as well as the EU, have ratified the UN Convention on the Rights of Persons with Disabilities (UN 
CRPD), guaranteeing to persons with disabilities political rights and the opportunity to enjoy them on an equal basis with 
others. 

in  European  Parliament  elections  –  March  2019, 

rights  of  persons  with  disabilities 

to  vote 

20 

 
 
                                                           
 
 
ways  of  voting,  prefer  to  vote  at  a  polling  station,  considering  it  as  the  best  form  of 
participation. 

National systems vary on candidacy and voting rights for people with intellectual disabilities. 
A  total  of  12  Member  States  extend  voting  rights  to  people  under  guardianship78.  Four 
Member States79 have recently adopted legislation and have reviewed the thresholds they 
apply in order to enable people deprived of legal capacity to participate in the democratic 
process80.  

In order to support the electoral rights of citizens with disabilities, several Member States 
have implemented specific actions81. 

Examples of best practice include: 

- 
- 

- 
- 

- 
- 

in  plain 

information  material  drafted 

language  and  braille  (videos, 

mobile ballot boxes for people with disabilities (Bulgaria); 
targeted 
brochures) to support specific groups in different languages (Belgium); 
trial project on autonomous electronic voting for the visually impaired (Belgium); 
accessible  polling  stations  and  ballot  boxes  in  hospitals,  nursing  homes  or  similar 
institutions (Ireland)82; 
braille paper ballots (Slovakia); 
dedicated  support  for  parliamentary  candidates  with  disabilities  including  funded 
internships with political parties (UK – Scottish government project).  

On  26  and  27  November  2018,  First  Vice-President  Frans  Timmermans,  together  with 
Commissioner  Věra  Jourová  hosted  the  European  Commission's  Annual  Colloquium  on 
Fundamental Rights, which this year was dedicated to democracy in the EU. This high-level 
event brought together over 400 politicians, national and EU policymakers, representatives 
of International Organisations, civil society leaders, academics, legal practitioners, activists, 
representatives  from  across  the  tech  industry  and  the  wider  business  community,  trade 
unions,  media  representatives  and  journalists.  Participants  worked  together  to  identify 
avenues to foster free, open and healthy democratic governance in an era of low turnout in 

78  Estonia,  Greece,  France,  Croatia,  Italy,  Latvia,  Hungary,  the  Netherlands,  Austria,  Finland,  Sweden  and  the  United 
Kingdom. 
79 Belgium, Denmark, Germany and Spain. 
80  Fundamental  Rights  Agency  Report,  ‘Who  will  (not)  get  to  vote  in  the  2019  European  Parliament  elections? 
Developments in the right to vote of people deprived of legal capacity in EU Member States’, February 2019. 
81  The  Dutch  government  is  conducting  research  into  the  obstacles  politicians  with  disabilities  face  and  what  measures 
need to be taken in order for them to participate and carry out their duties. Politicians and candidates with disabilities, as 
well  as  DPOs,  will  be  interviewed.  For  the  2015  General  Election  in  the  United  Kingdom,  prospective  candidates  with 
disabilities  standing  for  election  could  access  grants  of  between  £250  and  £40,000  for  disability  related  costs  including 
specialist  transport,  screen  reader  software,  sign  language  interpretation  and  Braille  transcription  (United  Kingdom, 
Government  Digital  Service  (2015),  Access  to  Elected  Office  Fund).  In  Romania,  the  lowering  of  the  threshold  for 
establishing political parties was indicated as a measure generally supporting the access of underrepresented groups to the 
political process. 
82 https://www.housing.gov.ie/sites/default/files/publications/files/01_-_info-voters_with_disability-english.pdf 

21 

 
 
                                                           
elections, populism, disinformation and challenges facing civil society. It included substantial 
discussion of practices to support participation, which are summarised in its conclusions.83 

2.3. Funding of projects supporting the enjoyment of EU electoral rights and 

the democratic participation of EU citizens 

The  Commission  used  available  funding  to  support  national  authorities  and  civil  society 
groups in implementing projects aimed at encouraging European citizens to get involved in 
the democratic process.  

Under  its  Rights,  Equality  and  Citizenship  programme,  the  Commission  supported  the 
participation  of  underrepresented  EU  citizens,  including  people  with  disabilities.  Between 
2014 and 2020, programme financed initiatives for € 20 million, with more than 20 projects 
having received funding.  

In the run-up to the elections, these projects have included: 

- 

tools to raise EU citizens’ awareness of their political rights and of the procedures 
to participate in European Parliament elections;84 

-  good  practice  guides  for  Member  States’  authorities  to  support  EU  citizens  in 

exercising their voting rights;85 

-  multilingual  tools  providing  information  about  the  programmes  promoted  by 

political parties during the electoral campaign;86 
targeted initiatives to encourage the participation of underrepresented groups.87 

- 

The Europe for Citizens programme supported activities that cover civic participation in the 
broad sense with the aim of encouraging citizens to participate in the shaping of the political 
agenda  of  the  EU.  Under  the  multi-annual  priority  ‘Debating  the  future  of  Europe  and 
challenging Eurosceptics’ project applicants were invited in 2019 to identify ways of further 
enhancing  the  European  dimension  and  the  democratic  legitimacy  of  the  EU  decision-
making process. In light of the low turnout rates in European elections of the past years and 
the  rise  of  populism  in  many  Member  States,  town-twinning  projects  and  civil  society 
projects  supported by  Europe  for  Citizens  addressed  the  question  of  how  to  reach  voters, 
including first time/young voters, or voters living in remote areas.88  

for 

See 

83 https://ec.europa.eu/info/files/conclusions-colloquium-2018_en. 
84 See for example http://www.spaceu2019.eu/.  
85 See for example http://smp.eelga.gov.uk/migrant-workers/act-project.aspx.  
86 See for example https://euandi2019.eui.eu/ and https://yourvotematters.eu/en/.  
87 
https://www.lawcentres.org.uk/lcn-s-work/living-rights-project.  
88  Projects  included  ALDA  (Belgium)  https://www.alda-europe.eu/newSite/Towards-EU-Elections-2019.php,  Expert  Pool  - 
(Bulgaria) 
(Belgium) 
https://www.ccre.org/en/activites/view/8, EAVI – European Association for Viewers Interests (Belgium) https://eavi.eu/  
https://europeanhouse.hu/,  Europski  Dom  Slavonski  Brod  (Croatia)  http://europski-dom-sb.hr/projekti/,  European 
Movement  International  (Belgium)  https://europeanmovement.eu/news/the-european-movement-international-in-2019/ 

http://www.diversitygroup.lt/fwp_portfolio/migrant-political-participation/ 

European  Municipalities 

https://vote4europe.org/, 

example 

Regions 

Council 

and 

and 

of 

22 

 
 
 
 
                                                           
 
3. The European dimension and the exercise of EU electoral rights 

3.1. European dimension 

The European elections are unique in the way they are organised: 28 Member States, each 
with  national  campaigns,  national  lists  and  distinctive  rules  and  traditions  contribute  to  a 
collective  result  in  the  European  Parliament  whose  members  represent  all  EU  citizens. 
Taking into account that the elections are organised nationally and remain for the most part 
regulated by national laws (even if some common rules apply), one of the challenges is to 
make sure that they are truly European and more than the sum of national ones. 

The  European  Electoral  Act  sets  out  the  provisions  necessary  for  the  election  of  the 
Members  of  the  European  Parliament  by  direct  universal  suffrage  in  accordance  with 
principles common to all Member States. When the European Electoral Act was adopted in 
1976,89  it already  contained  specific  measures to promote the  European dimension of the 
elections,  providing,  for  instance,  that  results  should  be  announced  jointly,90  not  only  to 
preserve  the  freedom  of  elections  principle,  but  also  to  help  creating  a  shared  European 
democratic experience. Over the years, different initiatives have been promoted for further 
fostering  of  the  European  dimension  of  the  elections.91  In  2015,  the  European  Parliament 
proposed  a  reform  of  the  European  electoral  procedure  under  the  1976  Act,92  which 
included the following provisions:  

-  A  joint  constituency  to  be  created,  with  lists  headed  by  each  political  family’s 
candidate  for  the  post  of  President  of  the  Commission.  The  candidate  should  be 
nominated at least 12 weeks before the election period; 

-  Gender  balanced  lists  of  candidates  for  the  European  Parliament  elections  to  be 

established at least 12 weeks before the election period; 

-  Deadline  of  8  weeks  before  the  first  election  day  for  the  establishment  and 

finalisation of the electoral roll; 

-  Democratic  procedures  and  transparency  in  selecting  parliamentary  candidates  for 
the elections to be observed by all political parties participating in the elections; 

European  University  College  Association  (Belgium)  https://www.euca.eu/messagetoeuropeans,  Europeum  Institute  for 
European Policy (Czech Republic ), Young European Federalists (Belgium) https://www.jef.eu/activities/projects/european-
also 
youth-together-road-to-the-future-project-towards-the-european-elections-2019/. 
https://eacea.ec.europa.eu/europe-for-citizens_en  and 
the  ground’ 
https://op.europa.eu/en/publication-detail/-/publication/87410a7b-cec0-11e9-992f-01aa75ed71a1/language-en/format-
PDF/source-111528910. 
89 Act concerning the election of the members of the European Parliament by direct universal suffrage, OJ L 278, 8.10.1976, 
p. 5. 
90 So that the announcement of results in one Member State cannot influence ongoing voting in another.  
91  See  Commission  Recommendation  (EU)  No  2013/142  of  12  March  2013  on  enhancing  the  democratic  and  efficient 
conduct of the elections to the European Parliament of 12 March 2013, OJ L 79, 21.3.2013, p. 29–32. 
92  European  Parliament  Resolution  of  11  November  2015  on  the  reform  of  the  electoral  law  of  the  European  Union 
(2015/2035(INL)), OJ C 366, 27.10.2017, p. 7–18. 

‘European  elections  2019 

feedback 

from 

See 

23 

 
 
 
                                                                                                                                                                                     
-  Ballot papers to give equal visibility to the names and logos of national parties and to 

those of the European political parties; 

-  Member  States  to  encourage  and  facilitate  the  provision  of  those  political 

affiliations, for example, by 

o 

o 

including  them  in  electoral  campaign  materials  and    television  and  radio 
broadcasts; 
linking electoral campaign materials, where possible, to the manifesto of the 
European political party, if any, to which the national party is affiliated; and  
o  making  the  European  political  party  affiliation  on  national  campaign 

communications and ballot papers visible; 

-  Mandatory  minimum  threshold  for  seats  in  the  European  Parliament  for  larger 
Member  States  ranging  between  3  and  5%  for  allocations  of  seats  in  single 
constituency and constituencies comprising of more than 26 seats; 

-  Member States allowed to introduce electronic and internet voting for elections to 
the  European  Parliament  and,  if  they  do  so,  measures  sufficient  to  ensure  the 
reliability of the result, the secrecy of the vote and data protection to be adopted; 

-  Member States allowed to grant postal voting to their citizens; 
-  Voting rights for citizens residing outside their Member States of origin; 
-  Member States to designate contact authorities responsible for exchanging data on 

voters. 

Consensus could only be found on certain elements of these proposals, including providing 
for:  

-  different remote voting methods as long as there is a reliability of the result, and the 

- 

- 

secrecy of the vote and the data protection are ensured;  
the option for Member States to allow their citizens residing in third country to take 
part in the elections; 
the  option  for  Member  States  to  allow  the  display  of  the  name  or  logo  of  the 
European political party to which the national political party or individual candidate 
is affiliated on the ballot paper; 

-  penalisation of double voting by national legislation;  
-  a deadline for submitting the lists three weeks before election day; 
-  designation  of  a  contact  authority  responsible  for  exchanging  data  on  mobile  EU 
citizens  being  voters  and/or  candidates  with  other  Member  States  and  starting  of 
the exchange of data at least 6 weeks before the elections; 

-  a threshold between 2 and 5 % that would apply to constituencies of more than 35 

seats.93 

93 Council Decision (EU, Euratom) 2018/994 of 13 July 2018 amending the Act concerning the election of the members of 
the  European  Parliament  by  direct  universal  suffrage,  annexed  to  Council  Decision  76/787/ECSC,  EEC,  Euratom  of  20 
September 1976, OJ L 178, 16.7.2018, p. 1–3. 

24 

 
 
 
                                                           
The amendments did not enter into force in time for the 2019 elections.94  

On  the  basis  of  the  existing  common  rules,  Member  States  vote  on  the  day  on  which 
national  elections  are  traditionally  held.  This  means  that  the  elections  occurred  over  a 
period of four days, from 23 to 26 May 2019, with results to be published only after the last 
polls  closed  on  26  May  2019  at  23:00.  Within  the  framework  of  the  Commission’s  expert 
group  on  electoral  matters,  Member  States  exchanged  on  a  number  of  aspects  of 
administrating  the  elections,  including  on  relevant  deadlines,  including  details  of  the 
opening and closing of the polls.  

In 2017, the Commission proposed to reform the rules on the funding of European political 
parties  and  foundations.95  This  included  proposals  to  strengthen  the  enforcement  of  the 
obligations  on  political  parties  which  receive  funding  under  the  regulation,  including  as 
regards their obligation to respect the common EU values under Article 2 of the Treaty of 
European  Union,  as  well  as  the  consequences  for  the  misapplication  of  European  funds. 
Another important element of the reform was to improve transparency by making the links 
between European and national parties clearer, so that EU citizens can be better informed 
on  whom  they  are  voting  for96.  European  parties  were  required  to  make  sure  that  the 
national parties with which they were affiliated displayed their European logo and political 
programme on their own websites.97 Whether European political parties which applied for 
funding did indeed meet the requirements set out in the amended Regulation has not yet 
been reported.98 The Commission will review the application of this Regulation by 2021.   

In  2018,  the  Commission  adopted  a  Recommendation  on  enhancing  the  European  nature 
and  efficient  conduct  of  the  2019  elections  to  the  European  Parliament99  addressed  to 
Member States and political parties. It called on them to build on the lead candidate system 
and to  make the  link between national  parties  and European  parties  more  visible,  inviting 
national  political  parties  to  display  prominently  with  which  European  political  party  they 
were affiliated in all campaign materials, communications and political broadcasts. Political 
parties  were  encouraged  to  communicate  clearly  which  political  group  in  the  European 
Parliament  they  intended  to  join  or  create  in  the  next  legislature.  Member  States  were 

94  The  relevant  procedure  (Article  223  TFEU)  requires  that  the  Council,  acting  unanimously  in  accordance  with  a  special 
legislative  procedure  and  after  obtaining  the  consent  of  the  European  Parliament,  which  shall  act  by  a  majority  of  its 
component Members, lays down the necessary provisions. These provisions will enter into force following their approval 
by  the  Member  States  in  accordance  with  their  respective  constitutional  requirements.  Not  all  Member  States  had 
approved the agreed amendments early enough before the elections. 
95 European Commission, Proposal for a regulation amending Regulation (EU, Euratom) No. 1141/2014 of 22 October 2014 
on the statute and funding of European political parties and European political foundations, COM(2017)481. 
96 A recital called on political parties also to provide transparency on the gender balance of their candidate lists. 
97 The Commission’s proposal also included the publication, on its member parties' websites, of information on the gender 
representation among the candidates at the last European elections. 
98  Regulation  (EU,  Euratom)  No  1141/2014  of  the  European  Parliament  and  of  the  Council  of  22  October  2014  on  the 
statute and funding of European political parties and European political foundations, OJ L 317, 4.11.2014, p. 1–27. 
99 Commission Recommendation (EU) No 2018/234 of 14 February 2018 on enhancing the European nature and efficient 
conduct of the 2019 elections to the European Parliament, OJ L 45, 17.2.2018, p. 40–43. 

25 

 
 
                                                           
encouraged  to  allow  the  indication  of  the  affiliations  to  European  political  parties  on  the 
ballot papers.  

The  following  elements  can  be  highlighted  based  on  the  contributions  received  from  the 
Member States and European and national parties. When it comes to displaying the logo or 
name  of  the  European  political  party  on  ballot  papers  alongside  its  affiliated  national 
political party, 17 Member States100 stated that their national laws do not permit this,101 10 
reported that they do,102 and 5 Member States reported that political parties had made use 
of this option.103  

In terms of the national political parties themselves, there seems to be a lack of knowledge 
on  whether  the  name  or  logo  of  the  relevant  affiliated  European  political  party  could  be 
displayed on the ballot paper. Out of the 18 political parties that replied, two indicated they 
were  not  aware  of  any  provisions  allowing  them  to  display  the  names  or  logos  of  these 
European  political  parties,104  while  what  5  stated  was  inconsistent  with  the  response  of 
their Member State authorities.105 This suggests that further awareness-raising activities are 
necessary. 

Furthermore, the campaign topics appeared to have become more European in nature than 
previously.  Based  on  over  11,000  electoral  materials, 
including  posters,  television 
commercials,  social  media  posts  and  printed  announcements  by  418  political  parties  or 
candidates, as well as 193 official Facebook accounts,106 the European Elections Monitoring 
Center  identified  the  most  common  issues  raised  in  election  campaigns,  namely  ‘Europe’ 
(15% of all topics), followed by ‘values,’ ‘economics,’ ‘social’ and the ‘environment’. In many 
countries, the keyword ‘Europe’ covered the discussions about the country’s position and its 
future role in the EU.  

3.2. Supporting the exercise of EU electoral rights  

The Commission took many different actions before the elections to ensure that EU law was 
being  implemented  and  to  eliminate  possible  obstacles  to  EU  citizens’  exercise  of  their 
electoral  rights.  EU  electoral  rights  include  the  rights  provided  to  all  citizens  under  the 
Treaties to participate in the democratic life of the Union, and to elect the Members of the 
European  Parliament  by  direct  universal  suffrage  in  a  free  and  secret  ballot.  They  also 

100  Bulgaria,  Czechia,  Denmark,  Germany,  Estonia,  Spain,  Croatia,  Latvia,  Lithuania,  Hungary,  Malta,  Poland,  Portugal, 
Romania, Slovakia and Sweden. 
101 One Member State did not respond. 
102 Belgium, Ireland, Greece, France, Cyprus, Luxembourg, the Netherlands, Austria, Slovenia and the United Kingdom. 
103 1 party in Greece, 4 in France, 2 out of 10 in Luxembourg, 2 out 18 in the Netherlands and four in Ireland.  
104 Christen-Democratisch Appèl (the Netherlands) and Eilliniko Orama (Greece). 
105 The Socialistische Partij Anders claimed that it was not allowed in Belgium, when in fact it is. The same was the case for 
Volt in both Luxembourg and the Netherlands as well as for the Chrëschtlech Sozial Vollekspartei in Luxembourg.  On the 
other  hand,  the  social  democratic  party  of  Lithuania,  Lietuvos  socialdemokratų  partija,  thought  that  displaying  the 
European logo or name on the ballot papers was allowed in Lithuania, while actually it is not permitted there.  
106 Johansson, Bengt and Novelli, Edoardo, ‘2019 European elections campaign – Images, topics, media in the 28 Member 
States’, 
https://op.europa.eu/en/publication-detail/-/publication/e6767a95-a386-11e9-9d01-
01aa75ed71a1/language-en.  

2019, 

July 

9 

26 

 
 
                                                           
include  the  rights  provided  to  EU  citizens  which  exercise  their  right  to  move  freely  to 
another Member State, to vote and stand in the European elections in their Member State 
of  residence.  These  rights  are  enshrined  in  the  Treaties  and  the  European  Charter  of 
Fundamental  Rights  and  Freedoms,  and  are  elaborated  in  the  European  electoral  Act, 
Directive 93/109/EC107 and the relevant case law of the Court of Justice. 

The Commission was in dialogue with four Member States on the right of mobile EU citizens 
to join a political party.108 Discussions were also held with several Member States to ensure 
information is exchanged within the five days envisaged so that candidates who have been 
disqualified  in  their  home  Member  State  can  be  prevented  from  being  elected  in  another 
Member  State.109  Following  these  discussions,  several  Member  States110  amended  their 
laws.  

Dialogue with one Member State addressed successfully the issue of protecting the secrecy 
of voting and discussions with another Member State resolved an issue on enabling people 
without fixed place of residence to exercise their electoral rights.  

Before  the  elections  and  immediately  following  them,  many  EU  citizens  contacted  the 
Commission  to  express  their  concerns  regarding  the  elections,  or  to  request  the 
enforcement of EU electoral rights. The most common issues were: 

-  Citizens  unable  to  vote remotely  (by  post,  by proxy or  online) or  in person  outside 
their  country  of  origin  (in  consulates,  embassies  or  specially  established  polling 
stations),  or  where  such  an  option  was  provided,  experiencing  administrative 
complexities,  delays  or  other  issues  which  prevented  them  from  completing  the 
procedure; 

-  Citizens  encountering  delays  or  complications  in  national  registration  procedures. 
This  applied  to  EU  citizens  attempting  to  complete  formalities  established  by  their 
country  of  nationality  when  voting  from  outside  that  country,  and  by  non-national 
EU  citizens  attempting  to  complete  formalities  established  by  their  country  of 
residence. 

The two largest groups of complaints concerned the possibility for:  

-  EU citizens to exercise their voting rights in the UK effectively111; and  

107 Council Directive 93/109/EC of 6 December 1993 laying down detailed arrangements for the exercise of the right to 
vote and stand as a candidate in elections to the European Parliament for citizens of the Union residing in a Member State 
of which they are not nationals OJ L 329, 30.12.1993, p. 34–38 
108 Czechia, Latvia, Lithuania and Poland. 
109 Either by being prevented from standing altogether, or, where this is not possible, from being elected or from exercising 
their  mandate.  See  Council  Directive  2013/1/EU  of  20  December  2012  amending  Directive  93/109/EC.  The  case  of  Oriol 
Junqueras, ECJ Case C-502/19- decided by the Court of Justice in December 2019, is relevant to the scope of EU law. 
110 Belgium, Greece, the Netherlands, Slovenia and Finland. 
111 The UK Electoral Commission published its report on 8 October 2019 https://www.electoralcommission.org.uk/who-we-
are-and-what-we-do/elections-and-referendums/past-elections-and-referendums/european-parliamentary-
elections/report-may-2019-european-parliamentary-elections-and-local-elections regarding the voting registration process 
for EU citizens resident in the UK for the 2019 European Parliamentary elections held in the UK. Of the 149 calls and 618 
formal complaints that the Electoral Commission received, over half were not aware of the ‘UC1’ declaration requirement, 

27 

 
 
                                                           
 
-  Romanian citizens voting from abroad at embassies and consulates.112  

Citizens themselves are generally confident that their countries were doing what is needed 
to prevent illegal and fraudulent activities during elections113.  

The EU and its Member States conduct and promote election observation globally and are 
committed  to  facilitating  access  for  international  and  citizen  election  observers114.  Some 
Member  States  have  implemented  this  commitment  in  national  law,  but  there  is  no 
common  approach.  In  the  context  of  the  European  network  on  elections,  experts  on 
election  observation  presented  to  Member  States  to  facilitate  discussion  of  the  differing 
national approaches and to provide additional information to support policymaking in this 
area, including from the Office for Democratic Institutions and Human Rights of the OECD 
and the voluntary group, Election-Watch.EU.115  

3.3. Prevention of multiple voting 

The  European  elections  are  organised  nationally.  This  means  that  voters  vote  on  national 
lists  and  candidates  stand  on  national  lists.  EU  law  provides  some  common  rules  for  the 
Member States to enable mobile EU citizens to exercise their right to vote, which includes a 
process  to  prevent  voting  in  more  than  one  Member  State  for  the  elections,  which  is 
prohibited.116  The  process  is  based  on  Member  States  exchanging  information  about  the 
relevant  voters  and  candidates.  Well  in  advance  of  polling  day,  the  Member  State  of 
residence  has  to  supply  the  Member  State  of  nationality  with  information  on  the  latter 
State’s nationals entered on its electoral rolls or standing as candidates. The Member State 
of  nationality  must  then  take  appropriate  action  to  ensure  that  its  nationals  do  not  vote 
more than once or stand as candidates in more than one Member State.117 

The  Commission  supported  Member  States’  efforts  to  exchange  data  through  contact 
points, adding a secure platform to perform the exchange to the IT tool it provided in 2014 

a smaller number did not submit it in time and around one sixth completed it in time but were still unable to vote. The 
Electoral Commission also noted that approximately four in five EU citizens (1.7 million) who had previously registered to 
vote did not submit an additional declaration in time to be registered to vote at the European Parliament elections in the 
UK. This data reflected complaints by mobile EU citizens in media reports at the time - see https://www.bbc.com/news/uk-
politics-48384000. 
112  At  the  2019  European  Parliamentary  elections,  Romanians  abroad  faced  long  queues  at  embassies  and  consulates, 
resulting that some citizens didn’t get the chance to vote in the end - see http://business-review.eu/news/thousands-of-
romanians-abroad-unable-to-vote-due-to-long-queues-201321.  
113 Special Eurobarometer 477 — Democracy and elections, November 2018. 
114 Through their respective commitments to supporting electoral observation, inter alia by endorsing the Declaration of 
Principles for International Election Observation 
http://ec.europa.eu/external_relations/human_rights/eu_election_ass_observ/docs/code_conduct_en.pdf  
115 An observation mission by ODIHR was not invited by the Member States for the 2019 elections, and has not been done 
so since 2009. Election-Watch.EU conducted an own initiative survey of the European elections the findings of which can 
be  accessed  online  https://www.wahlbeobachtung.org/en/european-parliament-elections-2019-election-watch-eu-eam-
final-report-with-16-recommendations/.  
116 See Council Directive 93/109/EC of 6 December 1993 laying down detailed arrangements for the exercise of the right to 
vote and stand as a candidate in elections to the European Parliament for citizens of the Union residing in a Member State 
of which they are not nationals, OJ L 329, 30.12.1993, p. 34-38.  
117 Article 13 of Council Directive 93/109/EC. Also, Member States are also required to exchange information to ensure that 
citizens who have had their rights to vote or stand as a candidate withdrawn, do not do so in another Member State. 

28 

 
 
                                                                                                                                                                                     
to  encrypt  the  data.  The  development  and  implementation  of  a  process  to  achieve  the 
exchange efficiently118 was coordinated in the framework of the expert group on electoral 
matters119. The Commission also supported Member States to compile an overview of the 
relevant  procedural  deadlines  in  the  run-up  to  the  elections.  It  comprised  information  on 
the  date  of  opening  and  closing  of  the  electoral  register,  campaigning  periods  where 
relevant,  and  on  date  of  the  closure  of  the  polls  in  the  different  Member  States.  This 
revealed  significant  and  challenging  divergences.120  The  Commission  also  supported  the 
development  of  a  multilingual  form  to  facilitate  the  prompt  exchange  of  information  on 
candidates, which was used by 10 Member States. 

Between  February  and  May  2019,  Member  States  exchanged  data  on  around  1.3  million 
voters  and  114  parliamentary  candidates.  This  exchange  resulted  in  the  identification  of 
over 213 000 multiple registration of citizens.  

Feedback from Member States indicates that while the process has improved both in terms 
of  its  security  and  efficiency,  they  still  face  difficulties  to  exchange  information  allowing 
accurate  and  timely  identification  of  the  EU  citizens  concerned121.  This  stems  particularly 
from  the  diversity  of  the  national  electoral  processes,  including  incompatible  national 
deadlines to prepare and close the electoral census (the  roll) and the effect of registration 
and deregistration on a citizen’s ability to vote in other national elections. This diversity in 
the  types  of  data  exchanged  and  the  timetables  to  which  the  data  was  being  collected 
affected its quality and its usability.  

Table 5: Data exchange to help prevent dual voting of mobile EU citizens 

Member 
State 

Used 
multilingual form 

Records sent 

Records received 

Duplicate records 
identified 

Identification 
rate 

Belgium 

Bulgaria 

Czechia 

Denmark 

Germany 

Estonia 

Yes 

No 

No 

No 

No 

Yes 

73 298 

100 

2 286 

16 445 

202 128 

1 615 

66 767 

34 165 

6 540 

- 

148 539 

3 430 

- 

- 

2 046 

- 

23 255 

- 

- 

- 

31.3% 

- 

15.7% 

- 

118  This  is  conducted  using  a  combination  of  a  bespoke  encryption/decryption  tool  (the  crypto-tool)  which  allows  the 
personal  data  to  be  encrypted  and  compressed,  and  a  dedicated  space  within  the  Commission’s  CIRCABC  platform 
https://circabc.europa.eu/faces/jsp/extension/wai/navigation/container.jsp, to which only relevant Member State officials 
have  access.  The  crypto-tool  performs  validation  of  the  data  being  encrypted  against  a  pre-specified  standard  which  is 
provided as an annex to the Directive. 
119 https://ec.europa.eu/transparency/regexpert/index.cfm?do=groupDetail.groupDetail&groupID=617. 
120 For instance, the periods during which citizens could register as voters and candidates were not common from Member 
States  to  Member  States,  and  in  some  instances  were  wholly  separate  (meaning  that  citizens  in  some  states  would  be 
expected to start registering to vote after the possibility to register in other states had closed). 
121  Data  on  the  identification  rate  are  incomplete.  On  the  basis  of  the  Member  States  for  which  complete  data  was 
exchanged, the overall identification rate was around 31%, though some Member States managed to identify over 90% of 
the  records  received.  However,  the  rate  was  very  low  in  some  cases,  mostly  reflecting  the  mismatch  between  the 
information collected about voters seeking to register to vote in one country, and the information required to identify a 
citizen in another country. 

29 

 
 
 
                                                           
Ireland 

Greece 

Spain 

France 

Croatia 

Italy 

Cyprus 

Latvia 

Lithuania 

Luxembourg 

Hungary 

Malta 

Netherlands 

Austria 

Poland 

Portugal 

Romania 

Slovenia 

Slovak 
Republic 

Finland 

Sweden 

Total 

No 

Yes 

Yes 

Yes 

Yes 

Yes 

No 

Yes 

- 

No 

Yes 

No 

Yes 

No 

No 

Yes 

Yes 

No 

No 

No 

No 

1 741 

15 367 

365 603 

264 949 

13 

93 848 

10 559 

30 

207 

49 850 

3 014 

18 376 

56 639 

38 672 

- 

10 752 

115 

554 

825 

7 513 

48 991 

14 649 

23 833 

51 501 

98 348 

10 276 

172 372 

1 346 

6 448 

2 689 

3 911 

10 650 

370 

61 737 

5 266 

- 

125 630 

166 234 

52 

8 597 

15 658 

14 772 

1 283 490 

1 053 780 

- 

17 061 

25 089 

32 380 

- 

- 

587 

1 181 

2 515 

- 

2 438 

- 

- 

665 

- 

81 158 

454 

- 

3 183 

14 439 

7 024 

213 475 

- 

71.6% 

48.7% 

32.9% 

- 

- 

43.6% 

18.3% 

93.5% 

- 

22.9% 

- 

- 

12.6% 

- 

64.6% 

0.3% 

- 

37.0% 

92.2% 

47.5% 

20.3% 

Totals for comparison (where data 
are available in all cases) 

686 051 

213 475 

31.1% 

Source: Replies from Member States to the Commission’s questionnaire, see the Annex. 

30 

 
 
 
 
 
 
 
 
 
 
 
 
 
4.  Addressing disinformation and protecting the integrity and 

resilience of the electoral process 

Campaigning  in  the  2019  European  elections  was  the  most  digital  to  date.  The  internet  is 
now  used  at  least  once  a  week  by  most  Europeans122  and  is  an  essential  source  of 
information  for  EU  citizens  in  the  electoral  context.  Almost  half  of  EU  citizens  now  rely 
primarily  on  online  news  sources  for  information  about  national  and  European  politics123. 
Social  media  is  also  an  important  tool  for  politicians  to  reach  voters  and  for  campaigns 
groups to organise supporters. 

The  digital  revolution  has  brought  many  benefits  in  terms  of  EU  citizens’  democratic 
participation. It has reduced the barriers and costs for EU citizens to join in the democratic 
debate and participate in the democratic process.  

However,  the  speed,  ease  and  reach  of  online  communication,  as  well  as  the  possibilities 
that online social platforms have created to target people through political advertisements 
and communications also pose new challenges. Most EU citizens, while agreeing that online 
social networks are a modern way to keep up to date with politics also believe that online 
political information cannot be trusted124.  

Elections  in  The  EU  and  around  the  world  have  become  a  target  for  interference  from  a 
variety  of  bad  actors  who  seek  to  exploit  the  opportunities  that  the  digital  environment 
provides125. 

Electoral  interference  can  take  many  forms.  Bad  actors  try  to  shape  public  opinion  and 
electoral  choices  using  disinformation  and  other  misleading  narratives  shared  on  social 
platforms, the amplification of content through fake accounts, fake engagement or abusive 

122 Ahead of radio and print media, and second to television. 
123  This  number  has  increased  by  15  pps  since  2010.  Standard  Eurobarometer  90  –  Media  use  in  the  European  Union, 
December 2018. 44% and 41% of Europeans said that the internet is one of the main information sources for national and 
European political matters, respectively.  
124 59%, 57% and 54% respectively. Standard Eurobarometer 90 —Media use in the European Union, December 2018. 
125  The  scope  and  nature  of  interference  in  elections  is  a  matter  of  ongoing  research  and  monitoring  by  a  number  of 
organisations,  including  the  European  Commission.  The  Computer  Emergency  Response  Team  for  the  EU  Institutions, 
bodies  and  agencies  (CERT-EU)  monitors  the  online  environment  as  part  of  its  task  to  support  the  security  of  the  ICT 
infrastructure of all EU institutions, bodies and agencies. It does this by helping to prevent, detect, mitigate and respond to 
cyber-attacks and by acting as the cyber-security information exchange and incident-response coordination hub. CERT-EU 
provides reports and analysis of incidents to the Member State authorities through the European Cooperation Network on 
Elections. The European External Action Service maintains a number of bodies tasked in this respect, including the Rapid 
Alert System and the https://euvsdisinfo.eu/ website. The EU-NATO European Centre of Excellence for Countering Hybrid 
Threats  supports  research  into  external  interference  in  elections  (for  instance,  see  the  research  into  the  use  of  cyber-
interference  to  manipulate  elections,  https://www.hybridcoe.fi/wp-content/uploads/2018/10/Strategic-Analysis-2018-8-
Past.pdf. Member State organisations are also involved in supporting research in this field. Relevant research organisations 
include  Cardiff  University’s  Crime  and  Security  Research  Institute  https://www.cardiff.ac.uk/crime-security-research-
institute  and  the  Computational  Propaganda  Project  https://comprop.oii.ox.ac.uk/.  The  Commission  monitors  the 
implementation of the self-regulatory code of practice (see point 4.2.3). The EU-NATO European Centre of Excellence for 
Countering Hybrid Threats supports research into external interference in elections (see for instance research into the use 
of cyber-interference to manipulate elections,  https://www.hybridcoe.fi/wp-content/uploads/2018/10/Strategic-Analysis-
2018-8-Past.pdf.  Member  State  organisations  are  also  involved  in  supporting  research  in  this  field.  Relevant  research 
organisations  include Cardiff University’s Crime and  Security Research Institute  https://www.cardiff.ac.uk/crime-security-
research-institute and the Computational Propaganda Project https://comprop.oii.ox.ac.uk/. 

31 

 
 
                                                           
bots,  online  intimidation  and  cyberattacks  to  steal  information  about  candidates  and  to 
deface political websites. Disinformation and misleading narratives can be disseminated and 
amplified  through  social  media  using  the  micro-targeting  functionality  that  social  media 
providers  have  created  to  enable  advertisers  to  reach  specific  potential  customers.  Such 
micro-targeting works on the basis of collated personal data and sophisticated psychological 
profiling  techniques,  which  are  not  always  transparent  to  the  citizen  and  might  not  have 
been consented to by the people affected. Interference can also be financial, through direct 
and  indirect  opaque  financial  support  of  political  actors,  campaigns  or  other  involved 
bodies.  Extremist  content  can  be  used  to  generate  funds,  sometimes  for  personal  gain, 
sometimes to fund further interference. Some interference tries to undermine confidence in 
the  system  with  cyberattacks  targeting  electoral  processes  and  misleading  information 
seeking  to  suppress  the  vote  or  erode  public  trust.  Electoral  interference  can  stem  from 
external  intervention  but  also  from  actors  operating  within  the  EU.  As  a  low  cost,  high 
impact  phenomenon,  interference  in  elections  can  be  a  tool  for  hybrid  influencing, 
organised criminality or promoting private interests. 

Certain actors seek to undermine the EU’s credibility as a guarantor of the core EU values, 
including democracy and equality of all citizens (e.g. gender equality and the protection of 
specific  groups).  Polarising  narratives,  disinformation  and  other  manipulation  attempt  to 
encourage citizens to disconnect from politics and weaken the credibility of EU institutions, 
fuelling discontent and distrust.126 

Together  with  the  action  plan  against  disinformation,  the  Commission’s  electoral  package 
provides a toolkit to tackle these challenges, bringing together all the parties responsible in 
the Member States and in the EU institutions. 

The  electoral  package  supports  enhanced  cooperation  between  national  and  European 
authorities, promotion of online transparency of political ads and communications targeting 
EU  citizens,  the  fight  against  disinformation  campaigns  and  other  manipulation, 
strengthening  resilience  against  cybersecurity  incidents  and  awareness-raising  activities.  It 
also  promotes  the  oversight  of  the  application  of  relevant  safeguards  including  electoral 
ones and supports data protection compliance in the electoral context. It contains a specific 
recommendation  addressed  to  Member  States  and  political  parties,  data  protection 
guidance,  and  a  legislative  proposal  providing  sanctions  for  the  deliberate  misuse  of 
personal  data  by  European  political  parties  and  foundations  to  attempt  to  influence  the 
outcome of the elections.127  

a 

of 

For 

survey 

impact 

126 
instance 
such 
https://ec.europa.eu/regional_policy/sources/docgener/work/2018_02_geog_discontent.pdf.  For  a  behavioural  approach 
to 
see 
decision-making, 
http://publications.jrc.ec.europa.eu/repository/bitstream/JRC117161/understanding-our-political-nature.pdf. 
127  Regulation  (EU,  Euratom)  2019/493  of  25  March  2019  amending  Regulation  (EU,  Euratom)  1141/2014  as  regards  a 
verification procedure related to infringements of rules on the protection of personal data in the context of elections to the 
European  Parliament,  OJ  L  85I  ,  27.3.2019,  p.  7–10  (and  it  entered  into  force  on  27  March  2019).  A  corresponding 
recommendation was addressed to Member States as regards national political parties. 

information 

narratives, 

political 

see 

for 

on 

of 

32 

 
 
                                                           
The electoral package was welcomed by the Council in its Conclusions of 19 February 2019 
on securing free and fair elections.128 The European Parliament also welcomed the package 
in  its  Resolution  of  25  October  2018  on  the  use  of  Facebook  users’  data  by  Cambridge 
Analytica  and  the  impact  on  data  protection,129  and  acknowledged  the  positive  impact  of 
the measures implemented by the Commission and the Member States in response to the 
fight against disinformation and interference in elections.130 

The  action  plan  against  disinformation  included  setting  up  a  Rapid  Alert  System  in 
collaboration with Member States, to create a direct connection between relevant experts 
both  in  Member  States  and  EU  institutions  in  order  to  exchange  information  on 
disinformation,  as  well  as  to  coordinate  –  where  possible  –  appropriate  responses.  The 
action  plan  also  put  in  place  close  monitoring  program  for  the  code  of  practice  on 
disinformation (see below section 4.2.3).131  

The  EU  institutions  and  the  Member  States  worked  intensively  to  deliver  the  measures 
contained in the electoral package and the action plan against disinformation in the run-up 
to  the  European  Parliament  elections.  Competent  Member  State  authorities,  civil  society 
organisations, journalists, fact-checkers, platforms, and other stakeholders joined together 
in  efforts  to  protect  the  resilience  of  the  electoral  process.  Such  efforts  contributed  to 
deterring  attacks  and  electoral  manipulation,  as  well  as  to  exposing  disinformation  and 
other manipulative interference in the democratic debate.  

While Russia's ongoing disinformation campaigns recurrently focused on politically sensitive 
topics and EU audiences ahead of the elections, no coordinated covert interference in the 
2019 elections has been identified on the basis of available analyses.132 The identification of 
covert  interference  campaigns  is  however  complicated  by  the  lack  of  transparency  and 
research  access  to  public  interest  data  held  by  online  platforms,  as  well  as  the  lack  of 
relevant common terms.  

128 https://data.consilium.europa.eu/doc/document/ST-6573-2019-REV-1/en/pdf. It was further welcomed and supported 
by  the  European  Council  in  its  conclusions  of  March  2019  https://data.consilium.europa.eu/doc/document/ST-1-2019-
INIT/en/pdf  and  June  2019  https://www.consilium.europa.eu/media/39922/20-21-euco-final-conclusions-en.pdf.  Further 
Council  Conclusions  supporting  the  implementation  of  the  electoral  package  and  the  continuation  of  the  work  of  the 
electoral  network  were  adopted  in  December  2019  https://data.consilium.europa.eu/doc/document/ST-14972-2019-
INIT/en/pdf. 
129 http://www.europarl.europa.eu/doceo/document/TA-8-2018-0433_EN.pdf?redirect.  
130 http://www.europarl.europa.eu/doceo/document/TA-9-2019-0031_EN.html.  
131 The Code is a self-regulatory measure,  supported by the Commission, whereby the major online platforms and trade 
associations  from  the  advertising  sector  commit  to  carry  out  policies  and  actions  aimed  at  ensuring  public  disclosure  of 
political  advertising  and  at  improving  the  transparency,  trustworthiness  and  accountability  of  online  services.  The  Code 
was signed in October 2018 by Facebook, Google, Twitter and Mozilla, as well as advertising trade associations. Microsoft 
joined  the  Code  in  May  2019,  and  additional  trade  associations  from  the  advertising  sector  also  subscribed  to  the  Code 
since. 
132 Data enabling precise analysis of the scope of disinformation campaigns around the elections  on social media and on 
the extent to which foreign actors might have been involved is not available. 

33 

 
 
                                                           
Manipulative  efforts  were  nevertheless  identified  at  a  smaller  scale  making  use  of  the 
techniques  described  above,  for 
instance  to  suppress  turnout  through  attacks  on 
government websites133, or to disseminate disinformation or other manipulative content. 

In the context of the comprehensive efforts undertaken prior to the elections, it should be 
underlined EU citizens appeared to be more satisfied with free and fair elections in the EU 
after the elections than before them. Comparing the results between a pre-election survey 
on democracy and elections from September 2018,134 and the European Parliament’s post-
election  survey,  citizens’  satisfaction  with  free  and  fair  elections  has  increased  since 
September 2018 in 21 Member States. The biggest increases can be seen in Greece (80%, 
+18 pps), Lithuania (78%, +14 pps), Romania (65%, +14 pps), Spain (77%, +12 pps), Portugal 
(92%, +11 pps), Malta (79%, +11 pps), Poland (84%, +10 pps) and Italy (71%, +10 pps). Most 
respondents in all Member States are satisfied that there are free and fair elections in the 
EU. Nine in ten say they are satisfied in Portugal (92%), the Netherlands (89%) and Germany 
(88%),  while  satisfaction  is  lowest  in  Bulgaria  (46%  vs  41%  ‘not  satisfied’)  and  Croatia 
(55%).135  

Figure 8: How satisfied or not are you with the following aspects of democracy in the European Union? Free and fair 
elections (% Total - 'satisfied') 

Percentage of citizens who are satisfied with free and fair 
elections per country 

92  89  88  86  85  84  83  82  82  82  80  79  79  78  77  74  72  71  71  67  66  66  65  64  63 

55 

46 

100
90
80
70
60
50
40
30
20
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June 2019

September 2018

Source: European Commission (based on the European Parliament post-election survey, 2019). 

133  Distributed  denial-of-service  (DDOS)  attacks  against  the  websites  of  public  authorities  offering  advice  about  the 
elections  were  observed  in  a  number  of  states,  including  Finland  and  Czechia,  where  detection  and  recovery  were  very 
prompt. Such attacks continue: efforts to suppress the vote in the recent national elections through disinformation were 
reported in Poland, and the websites of political parties were attacked in the run up to the national elections in the UK. 
134 Special Eurobarometer 477—Democracy and elections, November 2018. 
135 According to the European Parliament post-election survey (see footnote 12), the lowest levels of satisfaction are seen 
in relation to the fight against disinformation in the media ‘(48%) and the fight against corruption (43%). 

34 

 
 
 
                                                           
 
4.1.  

Unprecedented cooperation: election networks and other actions  
A  key  rationale  for  the  electoral  package  was  that  protecting  the  integrity  of  elections 
stakeholder  acting  alone.136  The  Commission’s 
cannot  be  achieved  by  any 
Recommendation137  therefore  called  on  Member  States  to  set  up  national  election 
networks,  involving  competent  national  authorities.  Contact  points  from  these  national 
networks were appointed to take part in the European Cooperation Network on Elections, 
gathering  representatives  of  all  Member  States.  This  network  serves  to  alert  on  threats, 
share  best  practices,  discuss  common  solutions  to  challenges  including  with  specific 
stakeholders and encourage common projects and exercises.  

Enhanced  cooperation  among  competent  authorities  and  relevant  stakeholders  is  indeed 
required  to  protect  the  resilience  and  integrity  of  electoral  systems,  and  is  central  to 
confidence  and  trust  of  citizens.  The  Council  specifically  recognised  the  value  of  this 
approach in its Conclusions of 10 December on countering hybrid threats.138 

National networks  

4.1.1. 
National  networks  on  elections  bring  together  national  authorities  with  responsible  for 
monitoring  and  enforcing  rules  related  to  online  activities  relevant  to  the  electoral 
context.139 Their composition, working methods and powers vary, reflecting the diversity in 
national  traditions,  administrative  and  jurisdictional  specificities  as  well  as  the  priorities 
identified by the Member States concerned.  

All  Member  States  established  national  election  networks,  some  by  creating  new 
coordination structures, others by strengthening and broadening existing ones. While most 
national election networks  were  established  as  informal  structures, 10 Member  States  set 
them up through formal decisions.  

136 The Commission also encouraged Member States to apply the principles of this Recommendation to other elections and 
referenda they organise at national level. 
137 C(2018) 5949 final. 
138 https://data.consilium.europa.eu/doc/document/ST-14972-2019-INIT/en/pdf. 
139  The  Commission’s  Recommendation  referred  for  instance  to  electoral  authorities,  data  protection  authorities, 
authorities in charge of cybersecurity and media regulators. 

35 

 
 
                                                           
Figure 9:  

Source: European Commission based on  replies from Member States to the Commission’s questionnaire, see the  Annex. 
Cartography by Eurostat.  

The  electoral  package  recommends 
involving  electoral  authorities,  data  protection 
authorities,  authorities  in  charge  of  cybersecurity  and  media  regulators  in  the  national 
networks.  Some  Member  States  included  national  security  and  intelligence  authorities, 
Prime  Minister’s  offices  and  ministries,  such  as  Foreign  Affairs,  Justice,  Internal  Affairs, 
Digital Affairs and Public Administration in their national election networks. Half of national 
data protection authorities140 reported being involved in the work of the national election 
networks. In terms of engagement with the media regulators, national electoral authorities 

140 Out of the 14 national data protection authorities which responded to the questionnaire of the Commission. 

36 

 
 
 
                                                           
in six Member States141 have not established any specific cooperation with them due to lack 
of  need  or  lack  of  existing  procedures.  In  four  Member  States,142  such  cooperation  was 
conducted  within  the  national  election  network,  whereas 
in  most  other  cases 
communication was based on specific exchanges of information when necessary.  

The coordinating bodies varied. For example, Ministries of Interior coordinate the networks 
in  seven  Member  States.143  The  task  is  conducted  by  the  Ministries  of  Justice  in  two 
Member States144, and by the Ministries of Foreign Affairs in two other Member States.145 
Member  States  indicated  that  networks  which  were  championed  by  senior  leadership 
worked well. 

The  Commission  also  urged  Member  States  to  ensure  that  appropriate  links  with  relevant 
structures were formed. In 13 Member States, the national contact point for the EU Rapid 
Alert System146 is also included in the national election network, and in 16 Member States 
national  networks  are  themselves  using  the  Rapid  Alert  System  to  share  alerts  on 
disinformation  affecting  elections.  In  Belgium  and  Latvia  for  instance,  the  same  contact 
point coordinated the work of the national network and served as the national contact point 
for the Rapid Alert System prior to the 2019 elections.  

14 Member States reported that the national networks have been or will be involved in 
monitoring the conduct of other elections at the national, local or regional level. 

141 Czechia, Germany, Austria, Latvia, Portugal and Sweden. 
142 Bulgaria, Croatia, Luxembourg and Romania. 
143 Czechia, Germany, Spain, Cyprus, the Netherlands, Austria and Portugal. 
144 Denmark and Finland. 
145 Bulgaria and Slovakia. 
146 The Rapid Alert System was set up pursuant to the action plan against disinformation adopted in December 2018. This 
platform facilitates the sharing of insights related to disinformation campaigns and coordinating responses among the EU 
institutions and Member States. 

37 

 
 
                                                           
Figure 10: Application of national electoral networks to elections beyond the European elections 

Source: European Commission based on  replies from Member States to the Commission’s questionnaire, see the  Annex. 
Cartography by Eurostat. 

A total of 11 Member States conducted a mapping exercise or analysis of their laws relevant 
to the electoral context through their national electoral networks. Some 20 Member States 
reported  having  carried  out  exercises  to  identify  threats  and  gaps  in  monitoring  and 
enforcing  the  rules,  and/or  to  assess  risks  to  electoral  processes  before the  elections  (see 
Figure  11).  Beyond  testing  cyber-risk  scenarios,  these  activities  included  assessing  risks 
related  to  disinformation  and  hybrid  threats,  and  simulations  of  elections  to  test  and 
develop contingency plans. 

38 

 
 
 
Figure 11: national electoral networks that conducted exercises ahead of the elections 

Source: European Commission based on  replies from Member States to the Commission’s questionnaire, see the  Annex. 
Cartography by Eurostat. 

In  addition to  holding  regular  meetings  (22  Member  States)  and  communicating  by email, 
five  Member  States  reported  having  established  secure  channels  for  classified or  sensitive 
information, and three have a dedicated IT platform. 

Member States’ authorities reported that no additional resources were provided to national 
election  networks  to  facilitate  their  work.  The  importance  of  adequate  resources  was 
nevertheless underlined. To support the national election networks and the coordination of 
these networks at EU level, the Commission published a call for proposals in 2019 under the 
Rights,  Equality  and  Citizenship  Programme  2014-2020.147  While  no  public  authorities  or 

147 http://ec.europa.eu/research/participants/data/ref/other_eu_prog/rec/wp/rec-awp-2019_en.pdf, p. 22. 

39 

 
 
 
                                                           
bodies with competence in electoral matters were in a position to apply for these grants in 
2019, most Member States expressed interest to apply for these grants in the future.148 

Member  States  have  provided  feedback  on  their  experience  with  the  national  elections 
networks.  They  indicated  that  a  clear  political  commitment  to  promoting  a  cross-
government  approach  was  valuable.  Establishing  links  with  independent  bodies  had  some 
challenges, but it was felt that an informal approach in this respect could help.  

A  number  of  Member  States  have  indicated  that  they  intend  to  makes  these  structures 
permanent.  Several  have  indicated  that  the  work  of  the  national  networks  should  be 
evaluated  and  where  scope  for  improvement  is  identified,  adjustments  would  be  made 
accordingly149.  

European Cooperation Network on Elections 

4.1.2. 
The Commission supported Member States by establishing and organising meetings of the 
European  Cooperation  Network  on  Elections.  This  European  network  consists  of  national 
contact  points  appointed  by  Member  States  to  represent  their  national  networks  on 
elections and serve as a liaison between the national and European level of coordination.150  

All  Member  States  have  appointed  contact  points  for  the  European  network.  The  contact 
points  vary  across  Member  States  in  terms  of  the  functions  of  nominated  individuals  or 
bodies, and can include (representatives of) electoral authorities, ministries of the Interior, 
Justice, Public administration, or the State Chancellery.  

The  then  Commissioner  for  Justice,  Consumers  and  Gender  Equality  Vera  Jourová 
inaugurated  the  European  Cooperation  Network  on  Elections  on  21  January  2019.  Four 
additional  meetings  were  held  on  27  February,  4  April,  7  June  and  27  November.  A  table 
top exercise on cyber resilience was organised on 5 April 2019 (see section 4.4). 

The  European  Cooperation  Network  on  Elections  supports  Member  States’  authorities  in 
sharing knowledge, expertise and best practice, including on threats, gaps and enforcement. 
Discussions focused on meaningful and practical exchange of practices on a range of topics 
relevant to ensuring free and fair elections, implementing the electoral package and building 
more resilient electoral systems, including on data protection, cyber security, transparency 
and awareness-raising. Some of the examples are summarised in the table below. 

be 

for 

open 

applications 

until  March 

148  And  will 
see 
tenders/opportunities/portal/screen/opportunities/topic-details/rec-rcit-citi-ag-2020. 
149 Fourth Meeting of the European Cooperation Network on Elections, 7 June 2019. 
150  Its  terms  of  reference  and  minutes  are  published  online,  see  https://ec.europa.eu/info/policies/justice-and-
fundamental-rights/eu-citizenship/electoral-rights_en#electionsnetwork. 
In the same way, the European Parliament achieves transparency with a website of mainly financial information pursuant 
to Article 32 of Regulation (EU, Euratom) 1141/2014 of 22 October 2014 on the statute and funding of European political 
parties and European political foundations, as amended by Regulation (EU, Euratom) 2018/673. 

https://ec.europa.eu/info/funding-

2020, 

40 

 
 
 
                                                           
Latvia  presented  an  application,  which  allows  EU  citizens  to  monitor  political  party  financing  and 
report cases of potential abuse  to the  Anti-corruption Bureau. This participatory application had a 
deterrent, as well as enforcement effect. 

An  awareness-raising  campaign  conducted  by  the  Netherlands,  which  targets  disinformation  in 
general, focuses on critical reading tips and therefore can be applied beyond the elections. 

Austria described a national master plan for digitalisation and a safer internet initiative. 

Luxembourg devised a national action plan covering all areas highlighted in the election package. 

Spain  produced  a  bilingual  website  and  guidance  for  elections,  and  a  24-hour  helpline  on 
disinformation.  

France  enacted  a  new  law  on  political  campaigning  in  December 2018  .  France  is  also  considering 
legislation to shape EU citizens’ education. Further legislation is being considered to establish further 
responsibilities for social media platforms.  

To  support the  sharing of  best practices,  a  mapping  of  the  rules  relevant  to the  electoral 
context was carried out within the network.151 The mapping reviewed rules applicable to: (i) 
contributions  (bans  on  foreign  funding,  limits,  disclosure  rules),  (ii)  spending  (earmarking 
and  limits),  (iii)  campaigning  (duration,  silence  period,  polling  and  other  restrictions),  and 
(iv) media (broadcasting, transparency of political advertising and social media rules).  

Some of the main findings include: 

-  most  Member  States  have  some  rules  on  the  transparency  of  donations  and/or 

prohibit anonymous donations; 

-  most Member States ban foreign funding of political parties and campaigns, though 

some only limit its amount or impose disclosure requirements;  

-  about half of the Member States require transparency for paid political adverts and 

communications;  
few Member States have specific rules applying to social media; 

- 
-  over a third of the Member States have rules that control the broadcast media in an 

electoral context; 
few Member States have such rules applicable online;  

- 
-  a third of Member States have clearly defined campaign periods. In other Member 

States, there are no specific requirements applicable; and 

-  most Member States have silence periods. 

The  network  meetings  also  provided  a platform for  exchanges  with  relevant  stakeholders 
such  as  the  European  Parliament,  the  Authority  for  European  Political  Parties  and 
Foundations,  the  European  Regulators  Group  for  Audiovisual  Media  Services  (ERGA), 
EUROPOL,  the  Organization  for  Security  and  Co-operation  in  Europe  (OSCE),  the  OSCE 

151  Sources  used:  Member  State  authorities’  websites,  academic  literature,  online  databases,  Member  State  feedback  to 
DG JUST questionnaires. 

41 

 
 
 
                                                           
Office for Democratic Institutions and Human Rights (ODIHR), the European Data Protection 
Board  (EDPB)  and the  European Data  Protection  Supervisor  (EDPS),  as well  as  with  other, 
non-institutional stakeholders including elections observers and fact-checker organisations. 

The  European  Cooperation  Network  on  Elections  will  continue  its  work  to  support  the 
integrity  of  elections.  Following  the  elections,  Member  States  asked  to  exchange  more 
information among themselves by using the existing channels, and to further improve the 
European  network  by  conducting  risk  assessments  or  organising  dedicated  workshops. 
Specific suggestions regarding future work included  

i. 

ii. 
iii. 
iv. 

sharing  experiences  in  conducting  electoral  reforms,  particularly  in  view  of  the 
changing and increasingly digital environment;  
establishing and broadening cooperation with social media platforms;  
awareness raising, also in relation to third parties such as the media and 
transparency of political advertising and party financing.  

Some suggestions also related to expanding the scope of the network to include topics such 
as advance/remote voting and voting for persons with disabilities. Member States have also 
underlined  the  added  value  of  the  mapping  exercise,  which  should  be  maintained  and 
further developed. 

4.2. Enhancing transparency and exposing disinformation 

Open democratic societies depend on public debate to allow citizens to be well informed 
and to express their will through free and fair political processes.  

Public debate was a key focus in efforts to interfere in elections. Political actors (candidates, 
journalists, activists and members of civil society) have been subjected to increased online 
interference,  including  harassment,  hate  speech,  distributed  denial-of-service  (DDoS) 
attacks  and  attempts  to  access  personal  information152.  Disinformation  targeting  the 
democratic  process,  as  well  as  divisive  and  manipulative  narratives,  have  been  observed 
and amplified through targeted communications on social media in the period running up 
to the elections.153  

A  characteristic  of  many  of  these  efforts  to  interfere  with  elections  is  the  lack  of 
transparency, which leads to a lack of accountability and scrutiny. Comments and content 

152  Information  received  from  Member  States  indicated  that  limited  DDoS  attacks  were  encountered  on  a  number  of 
occasions and responded to successfully and promptly. The NATO Communications and Information (NCI) Agency and the 
Computer  Emergency  Response  Team  for  the  European  Union’s  institutions,  bodies  and  Agencies  (CERT-EU)  held  a 
workshop on ‘Cyber Threat Vector Analysis’ ahead of the European Parliament elections in May 2019 which considered a 
range  of  threats  to  the  elections  process  https://ec.europa.eu/info/news/nato-and-cert-eu-discuss-cyber-threats-ahead-
see 
eu-elections-2019-may-06_en. 
https://www.idea.int/sites/default/files/publications/cybersecurity-in-elections-models-of-interagency-collaboration.pdf. 
153 While greatly increased and externally coordinated disinformation campaigns and cyberattacks were not observed, the 
systematic  long-term  pro-Kremlin  disinformation  campaigns,  spread  through  known  state-controlled  disinformation 
sources  and  amplified  via  social  media  and  domestically,  included  attacks  on  European  democratic  processes  and 
institutions,  and  continued  through  the  elections  period.  See  for  instance:  https://euvsdisinfo.eu/eu-elections-update-
reaping-what-was-sown/. 

cyberthreats 

overview 

elections 

For 

an 

of 

in 

42 

 
 
                                                           
may be posted by fake or misleading accounts, or the source of these comments may not 
be  identified.  Editorial  content  may  be  presented  as  journalism,  and  facts  or  authorship 
misrepresented.  Paid  for  content  may  not  be  readily distinguished  from  ‘organic’  content 
(content  recommended  by  social  media  connections  without  payment),  and  sources  of 
funding or expenses in paid political communication may not be disclosed. Further, users of 
social  media  may  be  unable  to  tell  when  messages  are  targeted  at  them,  on  what  basis 
(which  characteristics  and/or  behaviour  informed  the  targeting  algorithm)  and  where  the 
personal data used to target the message were collected.  

Transparency is central to EU values and to democracy. To address specific risks stemming 
from  lack  of  transparency,  disinformation  and  other  electoral  manipulations,  several 
strands of action were pursued. 

Beyond the actions taken by the Commission to address issues of disinformation including 
by specific information activities (such as daily rebuttals by the Spokesperson Service of the 
Commission and by the European Commission Representations in the Member States, long-
term  myth-busting  strategies  and  multi-dimensional  public  awareness  raising  actions), 
measures were implemented by other bodies and stakeholders. 

Member States 

4.2.1. 
The  Commission  in  its  electoral  package,  invited  Member  States  to  encourage  the 
transparency  of  paid  online  political  advertisements  and  communications  by  promoting 
active disclosure of who is behind the paid political advertisements and communications. It 
also  encouraged  more  transparency  in  campaign  spending  for  online  activities  as  well  as 
information on the targeting criteria being used. Applying sanctions, where available, when 
transparency is not ensured, was also recommended.154 The purpose is to address opaque 
practices in political advertising so that EU citizens know who is sending the political advert 
and  who  is  behind  it.  The  objective  is  also  to  create  a  barrier  for  covertly  influencing 
elections via opaque paid advertisements and communications.  

In  most  Member  States,  laws  exist  to  ensure  transparency  of  paid  online  political 
advertisements and communications (see Figure 12). While in some Member States the law 
explicitly refers to online media and includes a legal obligation on parties, campaigners and 
candidates to report what they have spent on advertising, in others the law does not cover 
such activities.  

Where  transparency  requirements  exist,  the  monitoring  of  rules  is  based  on  different 
models. The bodies in charge of monitoring vary across the Member States. Examples are: 
the  Election  Commission,155  the  Authority  for  political  parties,156  the  Audio-visual 

154 Commission Recommendation of 12.9.2018 on election cooperation networks, online transparency, protection against 
cybersecurity  incidents  and  fighting  disinformation  campaigns  in  the  context  of  elections  to  the  European  Parliament,  C 
(2018) 5949 final, p. 8. 
155 Bulgaria and Cyprus 
156 Czechia and Estonia. 

43 

 
 
                                                           
Regulator,157  the  Corruption  Prevention  and  Combating  Bureau,158  and  the  national  audit 
office.159 

Figure  12:  Member  States  with  national  requirements  regarding  the  transparency  in  paid  online  political  advertisements 
and communications 

Source: European Commission based on  replies from Member States to the Commission’s questionnaire, see the  Annex. 
Cartography by Eurostat. 

As mentioned above, Latvia developed a mobile application to enable EU citizens to report 
illegal  advertising  or  misuse  of  administrative  resources  to  the  electoral  authorities.  This 
application  was  made  available  to  other  Member  States  to  develop  for  use  in  their  own 
jurisdictions.  

Many  Member  States  also  promoted  the  transparency  of  online  political  adverts  to 
stakeholders in line with the Commission’s Recommendation.  

157 France.  
158 Latvia. 
159 Hungary. 

44 

 
 
 
                                                           
In  most  cases,  this  was  done  in  cooperation  with  other  authorities  from  the  national 
election  network  by  holding  seminars  for  political  parties,  media  and  advertising  service 
providers.  In  some  Member  States,  the  national  authorities  passed  on  the  Commission’s 
package of measures for free and fair elections to all registered political parties.  

Some  Member  States  issued  their  own  guidelines  on  transparency  and  some  used  social 
media accounts to share information on transparency.  

To  further  improve  transparency  in  political  advertising,  Member  States  suggested  that 
there  should  be  further  exploration  on  how  to  enforce  advertising  bans  on  social  media 
during  silence  periods.  Some  Member  States  stressed  the  need  to  further  improve 
advertising transparency measures provided by social media and to make them permanent 
and equally available in all Member States.  

A  number  of  Member  States have  developed detailed  policy plans  in this  respect,  notably 
Ireland160 and the Netherlands.161 In its contribution, one Member State called for European 
political parties and social media companies to observe national law when placing political 
advertising in the EU. Others suggested that social media platforms should conduct a pre-
approval  procedure 
in  collaboration  with  electoral 
commissions  and  national  media  regulators,  and  that  public  authorities  and  public 
broadcasters  should  be  pre-cleared  to  enable  prompt  and  unobstructed  dissemination  of 
content relevant for informing voters. One Member State pointed out that recurring issues 
with  a  lack  of  transparency  should  be  addressed  in  public  service  media  and  possibly  on 
social  networks,  in  order  to  put  such  problematic  behaviour  under  public  pressure  and  in 
this way encourage behaviour which is more transparent. 

for  political  communications 

Some  Member  States  amended  their  national  laws  ahead  of  the  elections  to  ensure 
increased  financial  transparency.  For  instance,  in  Croatia  new  measures  included  the 
publication  of  financial  statements  of  electoral  participants  on  the  webpages  of  the  State 
Electoral Commission.162  

In  general terms,  the  method  and  extent  of  the  financial disclosures  required  vary among 
Member  States.  In  some,  disclosure  requirements  are  rather  general  and  do  not  facilitate 
identification  of  the  source  of  funding  or  where  this  funding  was  used.  The  absence  of 
transparency  on  the  online  platforms  in  this  respect  further  complicates  monitoring,  and 
Member States pointed out the need to improve such disclosures. 

Transparency  of  the  targeting  criteria  used  does  not  appear  to  have  been  included  in 
national legislation so far. The Irish policy proposal for online political advertising stipulates 
that i) the person or party behind the advert must be clearly identified; ii) it must be made 

160https://merrionstreet.ie/en/News-
Room/News/Proposal_to_Regulate_Transparency_of_Online_Political_Advertising.html. 
161https://www.rijksoverheid.nl/onderwerpen/desinformatie-nepnieuws/nieuws/2019/10/18/kabinet-zet-in-op-
transparantie-in-strategie-tegen-desinformatie.  
162 Act on the Financing of Political Activities, Election Campaigns and Referenda, 2019. 

45 

 
 
                                                           
clear  whether  targeting  was  applied;  and  iii)  a  description  of  the  target  audience/criteria 
applied must be provided.163 

Political parties 

4.2.2. 
Beyond  Member  States,  the  Commission’s  Recommendation  is  directly  addressed  to 
political  parties,  foundations  and  campaign  organisations,  which  were  invited  to  take 
specific  steps  to  promote  transparency  in  political  advertisements  and  communications. 
This  includes  (i)  ensuring  that  EU  citizens  can  easily  recognise  online  paid  political 
advertisements  and  communications  and  the  party,  foundation  or  organisation  behind 
them, and (ii) making available on their websites information about the amounts  spent on 
online  political  advertisements  and  communications  as  well  as  on  any  targeting  criteria 
used in their dissemination.164  

In  March  2019,  then  Commissioner  Vera  Jourová  wrote  to  national  political  parties165 
calling on them to put Commission’s Recommendation into practice.  

In  their  replies  to  the  Commission’s  questionnaire,  political  parties  indicated  that  they 
abided by the relevant national and EU law, and have to follow the  terms of service set by 
the social media platforms for running political advertising on their services, including those  
introduced by Facebook in April 2019.  

Regarding  the  display  of  political  advertising  records  and  transparent  communication 
thereof  on  the  webpages  of  political  actors,  there  is  still  room  for  progress.  With  a  few 
exceptions,  political  parties  did  not  generally  undertake  additional  transparency  activities 
such as listing their adverts, or disclosing their spending for online political adverts on their 
websites. Most political parties indicated that they relied on the transparency databases of 
the  social  media  companies  to  report  on  this  or  that  their  spending  on  online  adverts  is 
included 
in  their  general  post-campaign  financial  reporting.  Some  political  parties 
emphasised  that  transparency  could  be  improved  by  simplifying  and  clarifying  the  laws 
governing electoral campaigns and providing information about the rules for access to the 
media  for  political  parties.  Open  access  online  disclosure  portals  maintained  by  electoral 
authorities were put forward as a way to improve this. 

Some political parties reported that the procedures established by social media companies 
for online political advertising were too complicated, slow and not sufficiently transparent. 
They  also  pointed  to  specific  problems  in  placing  their  adverts  such  as  late  approval  for 
their adverts, editorial censorship or not being able to place adverts targeting voters who 
are voting from abroad. One political party complained that a social media company closed 
all  its  accounts  during  the  campaign  period.  Furthermore,  two  European  political  parties 

Policy 

Outline 

Proposal 

163 
https://assets.gov.ie/39188/8c7b6bc1d0d046be915963abfe427e90.pdf. 
164 Complementing the commitments made by the major online platforms under the Code of Practice to provide for the 
transparency and public disclosure of political advertising on their services, see next section. 
165 https://ec.europa.eu/info/sites/info/files/letter_political_parties_final_en.pdf.  

Transparency 

Regulate 

Political 

On-line 

to 

of 

Advertising 

46 

 
 
                                                           
identified  Facebook’s  policy  changes  in  March  2019,  which  introduced  a  requirement  for 
advertisers  to  be  separately  authorised  in  each  country  in  which  political  advertising  was 
being run, as presenting an obstacle to communications at a European level.  

Some Political parties proposed measures to increase trust in communications by creating 
‘official channels’ for political parties and candidates on social media.  

Private companies  

4.2.3. 
The  Commission  worked  with  industry  to  protect  the  2019  elections  from  disinformation 
campaigns and online manipulation. A self-regulatory code of practice on disinformation166 
was drafted by stakeholders and was first implemented in October 2018. On this basis, the 
online platforms Facebook, Google, Twitter, and Microsoft have committed to: 

i. 
ii. 
iii. 
iv. 

provide for the transparency and public disclosure of political advertising;167 
prevent the manipulative use of their services by bad actors; 
 further empower citizens and researchers; and  
take other actions to improve the accountability and trustworthiness of the online 
social media market ecosystem.  

Trade  associations  from  the  advertising  sector  have  committed  to  cooperating  with  the 
platforms  to  improve  scrutiny  of  ad  placements  and  disrupt  advertising  and  monetization 
incentives for disinformation. 

As  called  for  in  the  action  plan  against  disinformation,  prior  to  the  elections,  the 
Commission,  with  the  assistance  of  Member  States’  authorities  (the  European  Regulators 
Group for Audio-visual Media Services (ERGA), carried out targeted intermediate monitoring 
of  the  implementation  of  the  Code  by  Facebook,  Google  and  Twitter,  based  on  monthly 
reports  from  the  platforms  and  focussing  on  actions  most  urgent  and  pertinent  to  the 
integrity of elections.168  

The Commission, with ERGA’s assistance, is currently assessing the overall effectiveness of 
this  Code  during  its  first  year  of  operations.169    In  October  2019,  the  platforms  and  other 
Code  signatories  already  submitted  annual  self-assessment  reports  covering  actions 
undertaken  to  implement  their  commitments  Code  during  the  Code’s  first  year  of 

166 EU code of practice on disinformation, available at: https://ec.europa.eu/digital-single-market/en/news/code-practice-
disinformation.  
167 Under the code of practice, the signatory platforms have committed to developing approaches to the transparency and 
public disclosure of ‘issue-based advertising.’ This is a wider concept than ‘political advertising’ (defined under the Code as 
advertising  advocating  for  or  against  a  candidate  or  referenda  in  national  and  European  elections)  and  encompasses 
advertising concerning, for instance, economic and social issues. To date, only Facebook has adopted a policy at EU level 
with respect to issue-based advertising. The Commission’s Recommendation refers in points 7-10 to ‘paid communications’ 
which encompasses ‘issue-based advertising’.  
168 The monthly reports, submitted by Facebook, Google and Twitter for January through May 2019, have been published 
on 
the  Commission’s  website,  available  at:  https://ec.europa.eu/digital-single-market/en/news/code-practice-
disinformation. Microsoft, which subscribed to the code of practice on 22 May 2019, was not subject to the Commission’s 
program of targeted monthly monitoring.  
169  In  addition  to  ERGA,  the  Commission  is  also  being  supported  in  its  assessment  of  the  Code  by  an  independent 
consultant.  

47 

 
 
                                                           
operations.170  

The Code has provided an opportunity for greater transparency into the platforms’ policies 
on disinformation as well as a framework for structured dialogue to monitor, improve and 
effectively implement those policies. In particular, in the run-up to the 2019 elections: 

- 

In the run-up to the 2019 elections, Facebook, Google and Twitter stepped up efforts 
to  provide  for the transparency of  political  ads,  in  particular  by labelling  them  and 
making them publicly available via searchable ad repositories;  

-  platforms  made  efforts  to  ensure  the  integrity  of  their  services  by  detecting  and 
closing  down  manipulative  activities,  such  as  coordinated  operations  aimed  at 
amplifying content as well as the abusive use of bots and fake accounts; and 

- 

the three platforms improved the scrutiny of ad placements to limit malicious click-
baiting practices and reduce advertising revenues for purveyors of disinformation.  

Moreover,  a  number  of  measures  designed  to  promote  content  from  authentic  and 
authoritative  sources  and  limit  the  distribution  of  disinformation  on  platforms’  services’ 
have  been  taken  and  have  contributed  to  deter  media  manipulation  and  malicious 
interferences.  

Further  actions  by  individual  signatories  and  the  community  as  a  whole  remain  however 
necessary.  There  are  differences  in  the  scope  of  actions  undertaken  by  each  platform  to 
ensure  they  fulfil  their  commitments,  as  well  as  differences  across  Member  States  in  the 
deployment  of  the  individual  policies.171  Furthermore,  progress  is  less  advanced  with 
respect to platforms’ commitments to empower consumers and commitments to empower 
the  research  community.  In  particular,  the  provision  of  data  and  search  tools  to  the 
research community is still episodic and arbitrary and does not respond to the full range of 
research needs.172 Moreover, cooperation with fact-checkers across the EU is also sporadic 
and a genuine coverage of all Member States and EU languages is still not in sight, showing 
the need for a mechanism which allows truly independent organisations to cooperate with 
the platforms (including via relevant and data protection compliant access to datasets for 
research purposes). Within the European Cooperation Network on Elections, three Member 
States pointed specifically to issues in registering fact-checkers with Facebook. 

Apart  from  Microsoft,  no  additional  platform  stakeholders,  brands  or  other  corporate 
actors from the advertising ecosystem operating in the EU subscribed to the Code since its 
inception. 

170  The  signatories’  annual  self-assessment  reports,  along  with  a  summary  overview  from  the  Commission,  have  been 
published  on  the  Commission’s  website,  available  at:  https://ec.europa.eu/digital-single-market/en/news/annual-self-
assessment-reports-signatories-code-practice-disinformation-2019.  
171  Available  at:  https://ec.europa.eu/digital-single-market/en/news/annual-self-assessment-reports-signatories-code-
practice-disinformation-2019.  
172 Social Science One, a partnership between a Social Science Research Council and private industry, for example, found in 
a meeting in December 2019 that the Facebook Ad Library was incomplete, inconsistent and difficult to use for research 
purposes in Czechia, Germany, Italy and the UK (EAC Workshop December 2019).  

48 

 
 
                                                           
4.2.4. 

Interactions between social media companies and Member States’ 

authorities and political parties 

A total of 18 Member States report having superficially engaged with social media platforms 
in the run-up to the elections, in particular Facebook, and without access to their data. In 
the  framework  of  the  European  elections  network  Member  States  exchanged  information 
on their experience engaging with the social media platforms, as well as in their responses 
to  the  Commission’s  questionnaires.  Member  States  provided  some  examples  of  where 
engagement worked well, which included: 

  Several Member States reported having established direct communication channels 

with social media networks for rapid response on urgent security issues; 

  A  few  Member  States  indicated  direct  contacts  with  platforms  where  specific 
training  was  provided  to  officials  to  assist  them  in  understanding  the  platform 
environment. 

Many Member States nonetheless indicated concerns regarding: 

 

Inequality and inconsistency in the approach adopted towards the Member States, 
with experiences differing between Member States and between platforms. Support 
provided  directly  to  actors  in  the  political  context  was  flagged  as  potentially 
problematic. Member States exchanged on the terms under which such engagement 
was provided to them, if at all. 

  Poor  or  lacking  operational  engagement  with  the  platforms  –  examples  were 
provided  of  a  lack  of  responsiveness  when  Member  State  authorities  drew  to 
platforms  attention  content  which  did  not  appear  to  conform  to  the  platform’s 
terms  of  service,  and  general  difficulties  accessing  platform  decision-makers. 
Member  States  considered  that  the  value  of  specific  operational  points  of  contact 
should  be  explored,  including  to  enable  their  authorities  better  to  perform  their 
oversight functions in the context of elections. Appropriate access to  data was also 
stressed in this regard; 

  A lack of own-language engagement and understanding of national jurisdictions. In 
this regard Member States provided examples where definitions included in platform 
terms of service did not align with national rules,  or where platform measures, e.g. 
on transparency, were introduced late, after official campaigning periods had begun; 

On  their  part,  online  social  media  platforms  report173  that  in  terms  of  engagement  with 
national authorities, no formal frameworks have been established.  

173  Google,  Facebook,  Snapchat  and  Twitter  responded  to  a  dedicated  questionnaire  on  the  implementation  of  the 
electoral package. 

49 

 
 
 
                                                           
Figure 13: Member States engaging with social media platforms 

Source: European Commission based on  replies from Member States to the Commission’s questionnaire, see the  Annex. 
Cartography by Eurostat. 

Facebook referred to the Integrity & Security Initiative launched together with the German 
Federal  Office  for  Information  Security  in  early  2019,  which  aimed  to  create  a  better  and 
more comprehensive understanding of interference into elections and develop guidance on 
how  to  combat  election  interference.  Since  the  launch,  Google  and  the  Dutch  Ministry  of 
the Interior have also joined the Initiative. 

In the run up to the elections, Facebook also reported that it launched an Election Security 
Escalation Channel for trusted security and intelligence partners to directly report potential 
cybersecurity  and  information  operations  threats.  Facebook  indicated  that  this  reporting 
channel includes partners from 11 EU Member States. 

Facebook also indicated that both of these initiatives would continue to be maintained post-
election.  In  general,  all  platforms  indicate  that  they  will  continue  with  the  established 
engagement with national authorities following the elections. 

Platforms  indicate  that  they  engaged  with  other  organisations,  including  national  and 
European  political  parties.  Google  reports  having  organised  in  person  and  online  security 
training  courses  on  how  to  use  their  advanced  protection  programme,  and  trained  2,508 
campaign  and  election  officials,  journalists  and  people  from  election-related  NGOs  in  20 

50 

 
 
 
Member  States.  These  training  courses  focused  on  political  advertising,  and  support  was 
offered  to  political  parties  regarding  the  verification  process  for  their  adverts.  Twitter 
produced a dedicated online guide to Advertising for the Elections.174 

Social  media  platforms  highlight  the  usefulness  of  cooperating  with  the  Member  States' 
authorities on workshops and training courses for political parties, and call for more clarity 
on  how  to  apply  national  rules,  for  instance  in  relation  to  online  political  campaign 
advertising  for  the  elections.  A  specific  suggestion  refers  to  establishing  points  of  contact 
within Member States that would assist smaller platforms in understanding the possibilities 
for outreach and engagement in the context of elections, enabling them to better respond 
to the challenges regarding the misuse of their services to harm or mislead users.175 

4.3. Data protection 

General 

4.3.1. 
The 2019 elections were the first European elections to which the General Data Protection 
Regulation  (GDPR)176  applied.  The  Commission  published  specific  guidance177  on  the 
applying  EU  data  protection  law  in  the  electoral  context  as  part  of  the  electoral  package. 
The  guidance,  provided  clarity  to  those  actors  involved  in  election  processes  -  national 
electoral  authorities,  political  parties,  data  brokers  and  data  analytics  companies,  social 
media platforms and online advertising networks - on the principles and obligations of GDPR 
regarding  the  lawfulness  of  processing  of  personal  data  (including  sensitive  data  such  as 
political  opinions),  transparency  requirements,  automated  decision-making  and  micro-
targeting. It called on the national data protection authorities, as enforcers of the GDPR, to 
make  full  use  of their  strengthened  powers  to  monitor  the  situation  and  address  possible 
data protection breaches. 

National  data  protection  authorities  adopted  a  number  of  measures  to  take  into  account 
data protection requirements during the electoral process. Some electoral commissions also 
took specific measures in this context.  

Action by data protection authorities 

4.3.2. 
Before  the  elections,  the  European  Data  Protection  Board,  composed  of  Member  States’ 
data protection authorities, adopted a statement on the use of personal data in the course 

174 https://business.twitter.com/en/a/twitter-ads-guide-eu-elections.html. 
175 These findings echo the recommendations made by the NATO Stratcom Centre of Excellence in its study on the role of 
social  media  in  combatting  inauthentic  behaviour,  which  stressed  the  importance  of  increased  and  meaningful 
transparency, 
effort 
https://www.stratcomcoe.org/how-social-media-companies-are-failing-combat-inauthentic-behaviour-online . 

self-regulation 

independent 

as  well 

reporting, 

oversight 

greater 

and 

as 

176 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural 
persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 
95/46/EC (General Data Protection Regulation), OJ L 119, 4.5.2016, p. 1–88. 
177 Commission guidance on the application of Union data protection law in the electoral Context— contribution from the 
European Commission to the Leaders' meeting in Salzburg on 19-20 September 2018, (COM(2018) 638 final). 

51 

 
 
 
                                                           
 
of political campaigns.178 The European Data Protection Supervisor also adopted an opinion 
on the Commission’s electoral package.179 A number of national data protection authorities 
issued statements and guidelines on data processing in the context of political campaigns.180  

Political  parties  in  many  Member  States  were  directly  informed  by  their  respective  data 
protection  authorities  about  the  measures  to  be  taken  when  processing  personal  data 
during the elections. For instance, the Latvian Data Protection Authority sent a letter to all 
the political parties on processing personal data in the context of elections. The Dutch Data 
Protection  Authority  conducted  an  exploratory  investigation  in  February/March  2019 
involving  all  political  parties  in  the  House  of  Representatives,  asking  questions  about  how 
those  parties  process  personal  data  during  election  campaigns  and  any  service  providers 
who  help  parties  with  their  campaigns  such  as  with  micro-targeting.  In  Finland,  political 
parties were sent the Commission's guidance on the application of EU data protection law in 
the  context  of  the  elections,  as  well  as  the  Commission's  Recommendation  on  election 
cooperation  networks,  online 
transparency,  cybersecurity  disruption  and  anti-
disinformation  campaigns  in  the  European  elections.  Four  data  protection  authorities 
organised  seminars  or  consultations  for  political  parties181  and  the  head  of  one  data 
protection authority held personal meetings with representatives of all the political parties, 
as well as independent groupings and candidates. 

Some data protection authorities also published material aimed at voters on the processing 
of  personal  data  during the  elections  of  the  European  Parliament.  For  example,  when  the 
United  Kingdom  was  still  a  Member  State,  its  Information  Commissioner’s  Office  ran  an 
awareness  campaign  tagged  'be  data  aware',  that  provided  information  to  EU  citizens  on 
how  to  protect  their  data  and  how  to  raise  concerns  if  they  believed  the  rules  had  been 
breached. 

A regards data protection incidents, the French and Spanish authorities reported the highest 
numbers,182 with several Member States reporting a lower number of incidents183 and the 
majority  reporting  no  incidents.  In  France,  697  complaints  were  received  during  the 
European elections via a dedicated form made available online during the election campaign 
to report suspicious practices. These mainly concerned unsolicited political communication 
operations by telephone (SMS and the use of automated calling machines) and by sending 

178  Statement  2/2019  of  13  March  2019  https://edpb.europa.eu/sites/edpb/files/files/file1/edpb-2019-03-13-statement-
on-elections_en.pdf. 
179 https://edps.europa.eu/sites/edp/files/publication/18-12-18_opinion_on_election_package_en.pdf.  
180  In  response  to  the  Commission  questionnaire,  data  protection  authorities  from  Bulgaria,  Ireland,  France,  Croatia, 
Cyprus, Latvia, Luxembourg, Malta, Romania, Slovenia, Slovakia and Finland reported dissemination guidelines to political 
parties and candidates or the electorate more generally through information packages, press statements, online guidance, 
video  blogs  and  social  media  outreach.  Latvian  and  Lithuanian  authorities  also  provided  trainings.  Spanish  authorities 
provided a Frequently Asked Questions section on their website and published a legal report ahead of the elections. 
181 Based on the answers to the Commission questionnaire, data protection authorities from Estonia, Latvia, Greece and 
Cyprus. 
182 The follow-up to be given, where appropriate, to all of these reports and complaints is under investigation. 
183 Bulgaria, Denmark, Ireland, Cyprus, Luxembourg, Hungary, Malta, Romania and Slovakia. 

52 

 
 
                                                           
emails  (especially  targeting  French  citizens  living  outside  France).  Also  11  claims  against 
political parties were received.  

In Spain, 102 complaints about political parties and administrations involved in the electoral 
process  were  received.  The  most  striking  claims  referred  to  the  potentially  wrongful 
publication  of  electoral  roll  data  (including  names)  on  public  websites  or  social  media 
networks. Three security breaches were detected that affected personal data in relation to 
the  publication  of  the  names  of  people  working  at  polling  stations  in  a  town  hall,  the 
publication  of  the  census  of  a  locality  and  the  attack  on  the  website  of  a  national  party. 
Poland also reported infringements relating to, among other things, online disclosure of an 
attendance list of members of a local voting commission. 

Concerning specifically social media platforms, the Irish data protection authority engaged 
with  them  in  support  of  monitoring  and  enforcement  efforts,  while  the  Latvian  Data 
Protection Authority envisages engaging with social media platforms for future elections. 

In one case, where the Italian Data Protection Authority considered that Facebook acquired 
and processed personal data disclosing political opinions without providing the appropriate 
information, contact was made with the Irish Data Protection Authority through the Internal 
Market Information System, with the request to investigate under the GDPR.184 

At  the  time  of  reporting,  most  of  these  cases  were  under  investigation.  Greece  however 
noted that the investigation of one complaint is completed and the national data protection 
authority issued  a fine of  €  2  000  to  a  candidate  for  the  European Parliament for  sending 
unsolicited emails to promote his candidacy.  

Input from political parties  

4.3.3. 
Most political parties indicate having complied with the GDPR, as well as specific guidelines 
of  the  national data protection  authorities,  where  these  were  issued.  Political  parties  also 
specifically  mentioned  engaging  legal  counsel  to  ensure  the  compliance  with  all  laws  and 
regulations,  as  well  as  employing  a  digital  campaign  manager  responsible  for  this  issue. 
Information  sessions  on  obligations  under  the  GDPR  were  held  with  candidates  and 
activists, and as with cybersecurity, parties also mention participating in sessions organised 
by the European Parliament on the issue of data protection. 

While  political  parties  generally  appreciated  being  able  to  contact  their  national  data 
protection authority for specific questions, they indicate that more information and active 
support would be desirable. One European political party specifically pointed out that there 
is insufficient clarity on key legal concepts such as ‘targeting’ and ‘consent’, under the GDPR. 
Political  parties  underlined  the  need  to  receive  guidance  well  in  advance  of  the  next 
elections and with clearer guidance on certain aspects of the GDPR.  

184  Article  60  of  the  GDPR  (cooperation  between  the  lead  supervisory  authority  and  the  other  supervisory  authorities 
concerned). 

53 

 
 
                                                           
4.3.4. 

New legal mechanism for data protection breaches by European 

political parties 

As part of the electoral package, the Commission proposed introducing financial sanctions 
for European political parties and foundations that breached data protection rules in order 
to deliberately influence or attempt to influence the outcome of the European elections. 

Regulation 2019/493 as regards a verification procedure related to infringements of rules on 
the protection of personal data in the context of elections to the European Parliament was 
adopted  before  the  2019  elections  and  now  provides 
in  these 
circumstances.185  

for  sanctions 

Most Member States have established a contact point between the national data protection 
authorities  and  the  Authority  for  European  political  parties  and  European  political 
foundations.186  Based  on  responses  received,  in  six  Member  States  the  contact  point  is 
designated  within  the  data  protection  authority,187  in  two  within  the  Ministry  of  the 
Interior,188 and one each within the electoral commission, the Ministry of State, Ministry of 
Justice and the Ministry of Foreign Affairs.189 

185 It inserted Article 10a Verification procedure related to infringements of rules on the protection of personal data into 
Regulation (EU, Euratom) 1141/2014 of 22 October 2014. It provides that where the Authority is informed of a decision of 
a national supervisory authority regarding a personal data infringement linked to political activities by a European political 
party or a European political foundation in the context of elections to the European Parliament, it must refer the matter to 
the  committee  of  independent  eminent  persons  (Article  11).  The  committee  shall  give  its  opinion  as  to  whether  the 
European political party or European political foundation concerned has deliberately influenced or attempted to influence 
the outcome of elections to the European Parliament by taking advantage of that infringement. The Authority shall then 
decide on sanctions. 
186 Established under Regulation 1141/2014. 
187 Ireland, France, Croatia, Italy, Poland and Slovakia. 
188 Germany and Greece. 
189 Luxembourg, Romania, Slovenia and Finland respectively. 

54 

 
 
                                                           
Figure 14: Member States that reported establishing points of contact with national data protection authorities190 

Source: European Commission based on replies from Member States to the Commission’s questionnaire, see the Annex. 
Cartography by Eurostat. 

4.4. Cybersecurity 

Cybersecurity  is  central  in  securing  free  and  fair  elections,  and  cyberattacks  against  the 
electoral infrastructure, the authorities responsible in the electoral process, the IT systems 
of political parties and candidates, and of media, civil society and other actors in the political 
process  are  widespread.  These  attacks  range  from  sophisticated  efforts  to  undermine 
particular actors in the process by stealing personal data to simple acts of online vandalism 
and  distributed  denial-of-service  (DDoS)  attacks.  No  network  system  can  ever  be  made 

190 National data protection authorities in France, Italy and Poland reported that they established some contact with other 
authorities. 

55 

 
 
 
                                                           
completely  secure.  In  this  context,  the  Commission  engaged  early  with  experts  as  it 
recognises  (i)  the  importance  of  cybersecurity  in  an  electoral  context  to  maintaining  EU 
citizens’ confidence and trust in the process, and (ii) the value of sufficient preparation from 
both government and other actors.  

The Commission’s Recommendation invited Member States to:  

 

take  appropriate  and  proportionate  measures  to  manage  the  risks  posed  to  the 
security of network and information systems used to organise the elections; 

  apply  the  Compendium191  developed  by  the  Cooperation  Group  established  under 
the Directive on the security of Network and information systems (NIS Cooperation 
Group) (EU) 2016/1148192 over the course of the election process; and 

  perform  a  comprehensive  assessment  of  risks  to  identify  potential  cyber  incidents 

that could affect the integrity of the electoral process. 

The Recommendation also invited European and national political parties, foundations and 
campaign  organisations  to  implement  specific  and  appropriate  measures  to  prevent  cyber 
incidents and protect themselves against cyberattacks. 

In order to support the implementation of the Recommendation and enhance cooperation 
between different national authorities, the Commission organised a high-level workshop on 
cyber-enabled threats to elections in October 2018193, where also cybersecurity authorities 
had  a  first  discussion  with  election  authorities  to  discuss  the  upcoming  challenges.  The 
outcome of that workshop also fed in to the Colloquium on Fundamental Rights held at the 
end of November 2018, focused on ‘Democracy in the European Union’.194 

In addition, a first ever table-top exercise with competent authorities was organised on 5 
April  2019.  The  Commission,  the  European  Parliament,  the  Member  States,  and  the 
European Union Agency for Cybersecurity (ENISA) worked together on an exercise to test 
the effectiveness of the EU's and Member States response procedures and crisis plans. The 
exercise  sought  to  identify  ways  to  prevent,  detect  and  mitigate  cybersecurity  incidents 
that  may  affect  the  elections.  It  focused  on  a  range  of  possible  scenarios  in  the  week 
leading up to the elections.  

The exercise tested the level of resilience of election systems across the EU, as well as the 
risks  linked  to  the  cybersecurity.  It  also  raised  awareness  of  the  importance  of  increased 
cooperation between national authorities and cooperation networks at EU level.195  

191https://ec.europa.eu/information_society/newsroom/image/document/2018-
30/election_security_compendium_00BE09F9-D2BE-5D69-9E39C5A9C81C290F_53645.pdf . 
192 First EU-wide cybersecurity rules (the Directive on security of network and information systems, (NIS Directive) establish 
the Computer Security Incident Response Team Network to promote swift and effective operational cooperation between 
the Member States. 
193 https://ec.europa.eu/epsc/events/election-interference-digital-age-building-resilience-cyber-enabled-threats_en  
194 See above, https://ec.europa.eu/info/events/annual-colloquium-fundamental-rights/2018-annual-colloquium-
fundamental-rights-2018-nov-26_en.  
195 Beyond the European Cooperation Network on Elections, the NIS Cooperation Group, CSIRTs Network. 

56 

 
 
                                                           
TENISA  sent  a  report  to  the  Member  States  outlining  the  main  conclusions  including  the 
policies and capabilities that are considered central to supporting cyber security resilience 
in  European  elections.  Approximately  two  thirds  of  Member  States  also  reported  having 
organised specific cybersecurity exercises at national level. 

Member  States  reported  having 
implemented  a  range  of  specific  technical  and 
organisational  measures  to  prevent,  detect,  manage  and  respond  to  cyberattacks  and  to 
understand  and  manage  network  security risks  and  information  systems used to organise 
the elections. These included:  

  heightening the level of alert; 
  deploying specific risk analysis and risk mitigation strategies;  
  conducting detailed risk analysis and developing an action plan to manage risks;  
  conducting penetration testing and vulnerability scanning on key components of the 

 

information systems used in the electoral process;  
increasing  cooperation  between  Computer  Security  Incident  Response  Team 
(CSIRTs),  as  well  as  cooperating  with  the  companies  contracted  to  extract  a 
complete inventory of the systems.  

Member States also reported on efforts to take the use of network systems out of certain 
parts of the process, including by replacing certain electronic systems with paper. 

Bulgaria  mentioned  that  an  organisation  was  set  up  to  interact  with  Europol’s  European 
Cybercrime  Centre  and,  where  necessary,  with  other  governmental  and  private  partners 
abroad. 

In  many  Member  States,  dedicated  mechanisms  to  exchange  information  quickly  and 
efficiently were set up so that any threats or incidents could be investigated and handled. 
Some  examples  include  putting  in  place  a  security  operations  centre,  activating  a  crisis 
management  mechanism,  and  activating  operational  and  strategic  cells  on  the day  of  the 
elections, including a technical cockpit, an evaluation cell and a coordination cell.  

Several Member States pointed to measures specific to the elections, primarily for ensuring 
confidentiality  of  the  election  results  until  their  publication  after  23:00  CET  on  26  May 
2019,  and  in  securing  their  transmission  nationally  and  to  the  European  Parliament  on 
election night. 

In nearly two thirds of Member States, work carried out to ensure the cyber resilience of 
network  and  information  systems  used  to  organise  the  elections  was  informed  by  the 
Compendium on the security of election technology (see Figure 16).  

In  Luxembourg  for  instance,  the  cybersecurity  subgroup  within  the  national  election 
network  set  up  a  national  action  plan  that  considers  each  recommendation  listed  in  the 
Compendium and identifies the actions needed to implement them.  

57 

 
 
 
Figure 15: Member States that took steps to apply the Compendium on the security of election technology 

Source: European Commission based on replies from Member States to the Commission’s questionnaire, see the Annex. 
Cartography by Eurostat. 

In the transmission of results, France noted the lack of a dedicated and secured channel of 
communication between the European Parliament and the national authorities. 

One  third  of  Member  States  also  applied  some  of  the  measures  addressed  in  the  Joint 
Communication  on  increasing  resilience  and  boosting  capabilities  to  address  hybrid 
threats.196 

No  Member  State  reported  having  applied  criminal  law  under  Directive  2013/40/EU.197 
Similarly, no non-EU investments were encountered in Member States or by platforms that 
could affect public order by giving access to sensitive information, including personal data, 
or  the  ability  to  control  such  information,  or  by  potentially  interfering  with  an  electoral 

196 JOIN(2018) 16 final. 
197 Directive 2013/40/EU of the European Parliament and of the Council of 12 August 2013 on attacks against information 
systems and replacing Council Framework Decision 2005/222/JHA, OJ L 218, 14.8.2013, p. 8–14. 

58 

 
 
 
                                                           
infrastructure.198  At  least  one  Member  State  intends  to  set  up  a  national  screening 
mechanism to monitor foreign direct investments that might raise security concerns. 

Several Member States reported having encountered cyber incidents that were successfully 
resolved.  Several  Member  States  reported  having  established  direct  communication 
channels  with  social  media  networks  for  rapid  response.  Google  and  Twitter  did  not 
observe or detect any significant cyber incidents that were election related in the course of 
the election period.  

Facebook  pointed  to  the  removal  of  accounts,  pages  and  groups  for  violations  of  their 
‘coordinated  inauthentic  behaviour  policy’.  In  the  run-up  to  the  European  elections, 
Facebook  reported  having  disrupted  networks  engaged 
‘inauthentic  misleading 
behaviour’ from inter alia Moldova, Iran, Russia, Kosovo and Macedonia.  

in 

Several political parties reported not taking action to address cybersecurity risks.199 Others 
reported carrying out activities or taking measures. These included: 

i. 
ii. 
iii. 
iv. 

distributing information sheets to party membership on cybersecurity risks; 
participating in seminars organised by the European Parliament on cybersecurity; 
improving monitoring of the security of digital platforms and tools; and  
employing dedicated software and analytics specialists during the campaign period.  

In  most  cases,  political  parties  relied  on  firewall  systems  and  anti-virus  software  for 
cybersecurity. The political parties also took advice from their IT departments or companies 
hosting  their  websites  or  servers.  Two  political  parties,  one  national  and  one  European, 
reported that they participated in a campaign security workshop held by Microsoft, while 
one  European  party  referred  to  dedicated  seminars  also  being  provided  by  Google, 
Facebook and YouTube. 

Several  political  parties  mentioned  that  they  received  support  from  national  authorities, 
which  included  information  sessions  organised by the national  intelligence  agency, or  the 
national  cybersecurity  authority  examining  the  resilience  of  the  app  used  by  the  party 
members. One political party reported a number of DDoS attacks on its website platform, 
after  which  they  involved  the  national  cybersecurity  authority  and  the  police.200  In  most 
cases however, political parties have not detected any cyber incidents.  

198 Regulation (EU) 2019/452 of the European Parliament and of the Council of 19 March 2019 establishing a framework for 
the screening of foreign direct investments into the Union, OJ L 79I , 21.3.2019, p. 1–14. 
199 Four out of 20 that replied. 
200 Such attacks have continued to affect political parties. In the context of national elections in December 2019, the UK 
Labour  party  was  hit  with  two  DDoS  attacks.  Both  were  aimed  at  taking  down  Labour’s  digital  infrastructure,  mainly 
targeting some important canvassing and campaigning tools (source https://cert.europa.eu/cert/). 

59 

 
 
 
 
 
                                                           
5.  Annex: Replies to the questionnaires 
Member States (27): 

Austria 

Cyprus 

Finland 

Hungary 

Luxembourg  Portugal 

Spain 

Belgium 

Czechia 

France 

Ireland 

Italy 

Malta 

Romania 

Bulgaria 

Denmark 

Germany 

Latvia 

Netherlands  Slovakia 

Sweden  

Croatia 

Estonia 

Greece 

Lithuania 

Poland 

Slovenia 

European and national political groups and parties (22): 

European People’s Party 

Renew Europe 

European Democratic Party 

Belgium: (2) Nieuw-Vlaamse Alliantie, sp.a  

Germany: (1) Freie Demokratische Partei, 

Greece: (2) Komma Neon, Elliniko Orama 

Lithuania: (1) Lietuvos Socialdemokratu Partija 

Luxembourg: (6) Parti démocrate européen, Chrëschtlech Sozial Vollekspartei, Dei Lenk, Dei Greng, 
Pirate, Volt  

Malta: (2) Imperium Romanum, Partit Laburista 

Netherlands: (3) CDA, Volt, 50 PLUS 

Portugal: (2) PAN, Basta 

Data protection authorities (14)  

Croatia 

Cyprus 

Estonia 

France 

Greece 

Italy 

Luxembourg  Malta 

Hungary 

Ireland 

Latvia 

Poland 

Slovakia 

Slovenia 

Platforms 

Google, Snapchat, Twitter, Facebook 

Direct contributions were also received from the Members of the Advisory Committee on Equal 
Opportunities for Women and Men from the following 16 Member States: 

Austria, Belgium, Bulgaria, Cyprus, Denmark, Finland, Germany, Greece, Ireland, Latvia, Malta, the 
Netherlands, Poland, Romania, Slovenia and Spain. 

60