COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS On the European democracy action plan
Date: 2020-12-03
Institutions: European Commission, Secretariat-General
Subjects: EU action, democracy, digital literacy, disinformation, election, mass media, party financing, pluralism in the media, political communication, political propaganda

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 3.12.2020  COM(2020) 790 final  COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS On the European democracy action plan  
 
 
‘The European Union is not only about parties and politics, rules or regulations, markets or 
currencies. It is ultimately — and above all else — about people and their aspirations. It is 
about people standing together. For their liberty, for their values, simply for a better future.’ 

Commission President von der Leyen, 27 November 2019 

1 

INTRODUCTION 

Democracy,  the  rule  of  law  and  fundamental  rights  are  the  foundations  on  which  the 
European Union is based. Democracy is a core European value, and a precondition for EU 
membership. The EU’s citizens see democracy, human rights and the rule of law as its most 
important asset1. 

Democracy allows citizens to shape laws and public policies at European, national, regional 
and local levels. It requires safeguards, checks and balances, and institutions that fulfil their 
roles  and  uphold  the  rules  of  pluralistic  democratic  debate.  For  participation  to  be 
meaningful, citizens must also be able to form their own judgements – they should be able to 
make electoral choices in a public space where a plurality of views can be expressed freely 
and  where  free  media,  academia  and  civil  society  can  play  their  role  in  stimulating  open 
debate, free from malign interference, either domestic or foreign. Democracy can only thrive 
in  a  climate  where  freedom  of  information  and  freedom  of  expression  are  both  upheld,  in 
line  with  the  Charter  of  Fundamental  Rights,  allowing  everyone  to  express  their  views, 
regardless how critical they are towards the governments and those in power. 

Democracy  cannot  be  taken  for  granted  –  it  needs  to  be  actively  nurtured  and  defended. 
Recent  times  have  shown  a  resurgence  of  popular  political  engagement  and  increased 
turnout in elections, but as in many places around the world, democracy in the EU and its 
Member  States  is  facing  challenges:  rising  extremism  and  polarisation,  as  well  as  a 
perceived  distance  between  people  and  their  elected  representatives2.  Our  democratic 
systems and institutions have come increasingly under attack in recent years3. The integrity 
of  elections  has  come  under  threat,  the  environment  in  which  journalists  and  civil  society 
operate  has  deteriorated,  and  concerted  efforts  to  spread  false  and  misleading  information 
and manipulate voters, including by foreign actors have been observed. The very freedoms 
we strive to uphold, like the freedom of expression, have been used in some cases to deceive 
and  manipulate.  The  COVID-19  pandemic  has  brought  these  challenges  into  relief:  the 
exceptional  emergency  measures  taken  to  address  this  unprecedented  public  health  crisis 
have affected the political process and in some places sparked concerns about the impact on 
democracy4.  

1   Special Eurobarometer 479 on the Future of Europe (October-November 2018). With 34% of respondents, 
this  comes  ahead  of  its  economic,  industrial  and  trading  power  (31%)  and  the  standard  of  living  of  EU 
citizens (25%).  

2   See for example The Global State of Democracy 2019 Report (2019) International Institute for Democracy 

and Electoral Assistance.  

3   President 

Political  Guidelines, 
political/files/political-guidelines-next-commission_en.pdf  . 

der  Leyen’s 

von 

https://ec.europa.eu/commission/sites/beta-

4   Venice Commission (2020), Interim report on the measures taken in the EU Member States as a result of 
the COVID-19 crisis and their impact on democracy, the rule of law and fundamental rights (adopted on 8 
October 2020). 

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This European Democracy Action Plan seeks to strengthen the resilience of EU democracies 
in  the face of challenges, addressing the areas in  which our systems  and  citizens are most 
vulnerable.  This  work  has  to  be  carried  out  at  EU  and  national  level  in  full  respect  of  the 
fundamental rights and freedoms enshrined in the Treaties and the Charter of Fundamental 
Rights, as well as in national and international human rights rules.  

. 

At  the  same  time,  the  EU  is  not  only  concerned  with  protecting  democracy  within  its 
borders,  but  as  pressure  is  mounting  on  democracy,  the  rule  of  law  and  human  rights 
globally, the EU is working actively to protect, inspire and support democracies around the 
world5 The  challenges  relating  to  the  exercise  of  democracy  are  global  and  the  world’s 
democracies have a common interest in working together to address them. At EU level, this 
requires a coherent approach between internal and external actions. The way we nurture and 
bolster  our  democratic  foundations  in  the  Union  and  Member  States  has  impact  on  the 
strength  of  our  external  action. 
With  this  action  plan,  the  Commission  is  proposing  a 
response  centred  around  individual  rights  and  freedoms,  transparency  and  accountability 
challenges  to 
which  could  also  serve 
democracy and a basis to build partnership with like-minded democracies.  

as  an  example  of  how  to  approach  these  global 

The digital transformation of our democracies 

The digital revolution has transformed democratic politics. Political campaigns are now run 
not only on the doorstep, billboards, radio waves and TV screens, but also online. This gives 
political actors new opportunities to reach out to voters. It also brings new opportunities for 
civic  engagement,  making  it  easier  for  some  groups  —  in  particular  young  people  —  to 
access information and participate in public life and democratic debate. 

However, the rapid growth of online campaigning and online platforms has also opened up 
new vulnerabilities and made it more difficult to maintain the integrity of elections, ensure a 
free  and  plural  media,  and  protect  the  democratic  process  from  disinformation  and  other 
manipulation. Digitalisation enabled new ways to finance political actors from uncontrolled 
sources,  cyber-attacks  can  target  critical  electoral  infrastructure,  journalists  face  online 
harassment  and  hate  speech,  and  false  information  and  polarising  messages  spread  rapidly 
through on social media, also by coordinated disinformation campaigns. The impact of some 
of  these  steps  is  amplified  by  the  use  of  opaque  algorithms  controlled  by  widely  used 
communication platforms.  

Our European democratic cultures, in all their diversity, are being challenged by the digital 
transformation.  Existing  safeguards  to  ensure  transparency  and  parity  of  resources  and 
airtime  during  election  campaigns  are  not  designed  for  the  digital  environment.  Online 
campaign  tools  have  added  potency  by  combining  personal  data  and  artificial  intelligence 
with psychological profiling and complex micro-targeting techniques6. Some of these tools, 
such as the processing of personal  data, are regulated by EU law.  But  others are  currently 
framed  mainly  by  corporate  terms  of  service,  and  can  also  escape  national  or  regional 
regulation  by  being  deployed  from  outside  the  electoral  jurisdiction.  Concern  about  the 

5   Joint Communication to the European Parliament and the Council  EU Action Plan on Human Rights and 
Democracy  2020-2024  (JOIN/2020/5  final,  25  March  2020),  which  reaffirms  the  EU’s  commitment  to 
promote and protect democracy worldwide. 

6   European  Commission,  Joint  Research  Centre  (2020),  Technology  and  democracy:  understanding  the 

influence of online technologies on political behaviour and decision-making.  

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transparency and accountability of online platforms adds to the challenge of enforcing rules. 
Online  platforms  can  both  have  news  media-related  activities  and  act  as  gatekeepers  for 
online news, while not being subject to the same national rules and professional standards.  

Strengthening democratic resilience 

This action plan addresses the EU institutions, national governments and parliaments  who 
have primary responsibility for ensuring the sound functioning of democracy  , as well as 
other national authorities, political parties, media and civil society, and online platforms. In 
full  respect  of  national  competences,  it  sets  out  a  reinforced  EU  policy  framework  and 
specific measures to: 

-  Promote free and fair elections and strong democratic participation; 

- 

- 

support free and independent media; and  

counter disinformation.  

A  healthy  democracy  relies  on  citizen  engagement  and  an  active  civil  society,  not  only  at 
election  time,  but  all  the  time.  Engaged,  informed  and  empowered  citizens  are  the  best 
guarantee  for  the  resilience  of  our  democracies.  Across  the  action  plan,  there  is  a  strong 
emphasis on empowering citizens and civil society to counter the threats7. 

2  PROTECTING  ELECTION  INTEGRITY  AND  PROMOTING  DEMOCRATIC 

PARTICIPATION 

High  voter  turnouts  in  recent  elections  across  the  EU  demonstrate  that  citizens  remain 
confident  in  the  power  of  the  ballot  box  as  tool  to  voice  their  opinion  and  hold  their 
representatives  to  account.  At  the  same  time,  social  media  are  one  of  the  channels  for 
attempts to manipulate public opinion, discourage participation in  elections and cast  doubt 
on  the  integrity  of  election  processes.  Attempts  at  foreign  interference  have  also  been 
documented8. 

Maintaining  democracy  requires  more  determined  action  to  protect  electoral  processes, 
preserve open democratic debate and update safeguards in the light of new digital realities. 
Democracy is about the richness of participatory practices, civic engagement and respect for 
democratic standards and the rule of law, applied throughout the electoral cycle.  

7   The Action Plan has been informed by a public consultation that demonstrated wide recognition of the risks 
of  interference  in  EU  democracy  and  the  need  for  targeted  action  both  online  and  offline.  The  report  is 
available  here:  https://ec.europa.eu/info/files/report-public-consultation-european-democracy-action-plan-
edap_en.  

8   For  example,  evidence  collected  around  the  time  of  the  2019  European  Parliament  elections  revealed 
continuous disinformation activity by Russian sources aiming to interfere in the election process (Report on 
the implementation of the action plan against disinformation (JOIN(2019) 12 final, 14.6.2019)). The 2019 
Report  on  the  elections  to  the  European  Parliament  (COM(2020)  252  final)  later  concluded  that  isolated 
cyberattacks,  data  protection  and  other  elections-related  complaints  had  been  received,  but  that  a  covert, 
coordinated large-scale effort to interfere in the elections had not been identified. 

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2.1

  Transparency of political advertising and communication 

Compliance with the traditional rules linked to political campaigning can be particularly 
challenging  in  the  online  context.  The  rules  are  often  difficult  to  enforce  or  ineffective 
online,  or  the  competent  authorities  may  not  have  the  powers  or  means  to  address  online 
activity. The cross-border potential of online activity brings opportunities, but also adds to 
the  challenge,  as  issues  related  to  elections  are  largely  governed  by  rules  applicable  only 
within a particular jurisdiction or may not have been formulated to take the borderless online 
space into account. 

There is a clear need for more transparency in political advertising and communication, 
and the commercial activities surrounding it. Stronger enforcement and compliance with the 
General Data Protection Regulation (GDPR)9 rules is of utmost importance. 

Citizens, civil society and responsible authorities must be able to see clearly the source and 
purpose  of  such  advertising.  In  the  online  environment,  it  is  often  difficult  to  recognise 
paid-for political material and distinguish it from other political content, not least because 
it can often appear as ‘organic’ content shared or created by other users. This creates legal 
uncertainties  for  service  providers  and  other  operators,  in  particular  online  intermediaries, 
political  consultancies  and  related  firms,  but  also  for  political  parties,  campaign 
organisations,  candidates  and  for  the  public  more  widely10,  and  affects  accountability  and 
oversight. 

New techniques used by intermediaries/service providers to target advertising on the basis 
of  users’  personal  information  enable  political  adverts  to  be  amplified  and  tailored  to  an 
individual’s  or  a  group’s  specific  profiles,  often  without  their  knowledge.  Micro-targeting 
and behavioural profiling techniques can rely on data improperly obtained, and be misused 
to  direct  divisive  and  polarising  narratives.  This  process  makes  it  much  harder  to  hold 
politicians to account for the messaging and opens new way for attempts to manipulate the 
electorate11. Other concerns are the concealment and/or misrepresentation of key information 
such as the origin, intent, sources and funding of political messages12. 

To address these concerns, in 2021, the Commission will present a legislative proposal on 
the transparency of sponsored political content. The proposal will complement the rules 

9   Regulation 2016/679 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, OJL119, 4.5.2016. 
10   Many respondents to the public consultation (including from business and civil society) said that the lack of 
transparency  and  clear  definitions  caused  difficulties  and  uncertainties,  in  particular  when  it  came  to 
distinguishing  paid-for  political  material  from  other  political  content.  Respondents  support  stronger 
disclosure rules, including transparency on the origin of the content (96% of respondents), the creation of 
open and transparent archives and registries of political ads (91%) and requiring political parties to disclose 
their campaign finances (82%). 82% supported criteria for requiring the micro-targeting of political content 
to be publicly disclosed in a clear and transparent way for every advert. 

11   Irrespective of its actual impact, the Facebook-Cambridge Analytica scandal,  where millions of Facebook 
users' personal data was acquired without their consent and used predominantly for political advertising , is 
a revealing example of clear intent to engage in such manipulation by exploiting legal loopholes and taking 
advantage of weak safeguards for how social media protects its users’ personal data. It showed how data 
analytics,  paired  with  micro-targeting  techniques  and  psychological  profiling,  can  be  used  to  mislead, 
suppress turnout and manipulate voting behaviour. 

12   2019 EP election report (COM(2020) 252 final). 

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on online advertising in of the forthcoming Digital Services Act (DSA), with the aim to have 
dedicated rules in place sufficiently ahead of the May 2024 European Parliament elections. 
It  will  target  the  sponsors  of  paid  content  and  production/distribution  channels,  including 
online  platforms,  advertisers  and  political  consultancies,  clarifying  their  respective 
responsibilities and providing legal certainty. It will ensure that relevant fundamental rights 
and  standards  are  upheld  as  effectively  online  as  they  are  offline.  The  Commission  will 
further assess whether a targeted approach is needed during election periods. 

The initiative will determine which actors and what type of sponsored content fall within the 
scope  of  enhanced  transparency  requirements.  It  will  support  accountability  and  enable 
monitoring  and  enforcement  of  relevant  rules,  audits  and  access  to  non-personal  data,  and 
facilitate due diligence. The Commission will also look at further restricting micro-targeting 
and  psychological  profiling  in  the  political  context.  Certain  specific  obligations  could  be 
proportionately  imposed  on  online  intermediaries,  advertising  service  providers  and  other 
actors, depending on their scale and impact (such as for labelling, record-keeping, disclosure 
requirements,  transparency  of  price  paid,  and  targeting  and  amplification  criteria).  Further 
provisions could provide for specific engagement with supervisory authorities, and to enable 
co-regulatory codes and professional standards.  

Building on the interdisciplinary exchanges between Member States in the framework of the 
European  Cooperation  Network  on  Elections  established  in  2019  ahead  of  the  elections  to 
the European Parliament to allow for concrete and practical exchanges on a range of topics 
relevant to ensuring free and fair elections13, the proposed legislation will be complemented 
by support measures and guidance for Member States and other actors, such as national 
political parties and competent authorities, taking into account the limits of EU competence 
in this area.  

Actions: 

  Propose,  in  2021,  legislation  to  ensure  greater  transparency  in  the  area  of  sponsored 

content in a political context (‘political advertising’) 

  Adopt support measures and guidance for political parties and Member States 

  Clearer rules on the financing of European political parties 

2.2
The  funding  of  European  political  parties  is  governed  by  EU  law14.  The  2019  European 
Parliament  election  report highlighted the need to  strengthen some of the rules in  order to 
prevent external interference, in particular by improving transparency as regards sources of 
financing for European political parties so as to tackle indirect funding by foreign interests 
channelled  through  national  means  or  private  donations15.  In  2021,  the  Commission  will 

13  https://ec.europa.eu/info/policies/justice-and-fundamental-rights/eu-citizenship/electoral-rights/european-

cooperation-network-elections_en.  

14   Regulation (EU, Euratom) 2018/673 of 3 May 2018 amending Regulation (EU, Euratom) No 1141/2014 on 
the  statute  and  funding  of  European  political  parties  and  European  political  foundations  (OJ  L  114I  , 
4.5.2018, p. 1); Regulation (EU, Euratom) 2019/493 of 25 March 2019 amending Regulation 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). 

15   84% of respondents to the public consultation supported more transparency on the financing of European 

political parties. 

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propose a  review of the legislation on the funding of European political  parties with  a 
view to addressing the financing of European political parties from outside the EU, revising 
the  audit  requirements,  strengthening  the  links  between  European  financing  and  national 
campaigns, and facilitating transparency and auditing. The goal is to have the new rules in 
place in sufficient time ahead of the May 2024 European Parliament elections. 

The Commission will also consider developing web-based software tools to assist the work 
of civil society in the area of political financing and financial transparency, for example in 
detecting  and  exposing  possible  fraud  and  irregularities  in  political  parties’  published 
accounts. 

Actions: 

  Propose,  in  2021,  revision  of  Regulation  No  1141/2014  on  the  statute  and  funding  of 

European political parties and European political foundations 

2.3

  Strengthened cooperation in the EU to ensure free and fair elections 

The  organisation  of  national  elections  is  a  Member  State  competence  informed  by 
international  standards,  with  some  issues  such  as  data  protection  governed  by  the  broader 
framework  of  EU  law.  Dedicated  EU  law  governs  European  Parliament  elections  and  the 
voting rights of mobile EU citizens, while most aspects relevant to the electoral process still 
rest  on  national  law.  Experience  in  the  run-up  to  the  2019  European  Parliament  elections 
showed how closer coordination and cooperation at national and EU level can make a key 
contribution in this respect.  

The Commission will also propose a new operational EU mechanism to support resilient 
electoral processes. It will be organised and coordinated through the European Cooperation 
Network on Elections to support deployment of joint expert teams and exchanges on issues 
such as the cybersecurity  of elections and online forensics16, in  close cooperation with  the 
Network  and  Information  Systems  Cooperation  Group  and  the  EU’s  Rapid  Alert  System. 
The Commission will continue to facilitate strengthened cooperation among Member States 
competent  authorities  in  addressing  specific  challenges  (e.g.  linked  to  election  periods, 
elections observation, independent electoral oversight and effective remedies) and covering 
monitoring  (including  online),  threat  identification,  capacity  building,  the  operation  of 
national  elections  networks  and  engagement  with  the  private  sector.  Options  for  mutual 
support, including an online forum, joint training, pooled resources and expertise as well as 
online  monitoring  capabilities  will  be  explored.  Marking  electoral  processes  or  aspects  of 
their administration as critical infrastructure could render these efforts more effective17. The 
Commission will organise a high level event bringing together various authorities to address 
the challenges related to electoral processes as well as empowering citizens to participate as 
voters and candidates in the democratic process. 

16   The  acquisition  and  use  of  online  data  for  justice  purposes  (e.g. in  the  monitoring  and  enforcement  of 

relevant rules) require supervising authorities to have specialist capabilities and appropriate powers. 

17  For example, Regulation (EU) 2019/452 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) includes electoral infrastructure as 
one of the potential elements of critical infrastructure to be taken into account when assessing if the effects 
of foreign direct investment is likely to affect security or public order. 

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Specific  measures  at  EU  level  will  be  taken  to  protect  election  infrastructures  against 
cyber-attacks18.  In  this  context,  the  compendium  on  cyber  security  of  election 
technology19 will be updated and further practical exercises will be organised to explore risk 
and  preparedness,  drawing  on  joint  work  by  the  European  Cooperation  Network  on 
Elections and the Network and Information Systems Cooperation Group. The upcoming EU 
cybersecurity  strategy  will  provide  a  cross-cutting  framework,  accompanied  by  legislative 
proposals to enhance the security of network and information systems and the protection of 
critical infrastructures.  

The  Commission  will  focus  on  strengthening  cooperation  between  Member  States  and 
relevant  regulatory  authorities  on  parity  of  treatment  and  balanced  media  coverage 
during  elections,  given  that  traditional  media  and  online  platforms  are  not  subject  to  the 
same  obligations.  Further  guidance  in  this  area  could  be  facilitated  at  EU  level  benefiting 
also from the expertise of national media regulators in the European Regulators Group for 
Audiovisual Media Services (ERGA)20 and of self-regulatory media bodies. This work will 
also  draw  on  expertise  in  the  European  Cooperation  Network  on  Elections  and  the  EU’s 
Rapid  Alert  System.  Upholding  standards  of  journalistic  and  editorial  integrity  is 
particularly important in the electoral context. 

The  Commission  will  also  strengthen  the  knowledge  base  and  explore  ways  of  helping 
citizens  and  national  electoral  authorities  to  build  resilience  against  threats  to  the 
electoral process. This could include studies, pilot projects, support for education for active 
citizenship, and helpdesks or similar shared resources. 

IT is used in elections to tally votes and transmit results, or (albeit rarely in the EU) in the 
form  of  electronic  voting  machines  or  electronic  voting.  While  Member  States  have 
traditionally  been  reluctant  to  introduce  IT  more  generally  in  the  voting  process,  the 
COVID-19 pandemic and the need for physical distancing has prompted renewed interest in 
electronic  voting  solutions21.  The  Commission  will  prepare  a  compendium  of  e-voting 
practices22,  together  with  Member  States  and  in  close  cooperation  with  the  Council  of 

18   Building  on  past  recommendations  on  EU  elections,  on  Directive  (EU)  2016/1148  of  6  July  2016 
concerning measures for a high common level of security of network and information systems across the 
Union (OJ L 194, 19.7.2016, p. 1–30), which is due for revision this year, and on related recommendations 
(C(2018)  5949  final  and  C(2018)  900  final).  In  the  public  consultation,  respondents  cited  cyberattacks 
among  the  main  threats  to  election  integrity,  in  particular  due  to  increasing  reliance  on  the  internet  for 
sharing and accessing information on elections, political parties and campaigns. A well-evidenced example 
of  such  attacks  are  ‘hack  and  leak’  operations,  such  as  in  the  case  of  Russian  intelligence  agencies 
obtaining  and  disseminating  documents  from  the  Democratic  National  Committee  during  the  2016  US 
Presidential election campaign. 

19    http://ec.europa.eu/newsroom/dae/document.cfm?doc_id=53645.  
20   ERGA  report  (2018);  https://erga-online.eu/wp-content/uploads/2019/01/ERGA-2018-07-SG1-Report-on-

internal-plurality-LQ.pdf. 

21   See  Flash Eurobarometer 431 on  Electoral rights (2015), which assessed public concerns regarding risks 
associated  with  voting  electronically,  online  or  by  post.  It  found  that,  while  people  understood  the 
usefulness  of  e-voting  to  help  those  with  certain  specific  needs,  they  were  concerned  about  voting 
confidentiality  and  reliability.  The  findings  of  Special  Eurobarometer  477  (2018)  on  Democracy  and 
elections,  which  looked  at  respondents’  concerns  about  voting  electronically,  online  or  by  post,  were 
similar. In 2016, the European Parliament gave the Commission a pilot grant for a Study on the benefits and 
drawbacks of remote voting, which includes a comprehensive survey of national experience with e-voting 
and other remote voting tools. 

22   This issue will also be addressed in the 2020 Citizenship Report. 

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Europe, which has already issued substantial guidance in this area, including on accessibility 
for persons with disabilities and older persons. 

Cooperation  and  exchange  on  electoral  matters,  making  best  use  of  existing  structures, 
will  be  strengthened  with  countries  in  the  EU’s  immediate  neighbourhood  and  beyond,  as 
well as with international organisations such as the Council of Europe23, UNESCO and the 
OSCE Office for Democratic Institutions and Human Rights24 to facilitate the exchange of 
best  practice  and  provide  support  on  common  challenges,  such  as  tackling  foreign 
interference  and  disinformation  in  the  electoral  context.  Work  is  already  under  way  with 
partner  countries  through  democracy  support  and  the  EU  Election  Observation  Missions, 
whose  mandate  has  been  extended  to  monitor  online  electoral  campaigns,  social  media 
monitoring  and  give  recommendations  in  this  area.  For  these  recommendations  to  be 
effectively followed up it will be necessary to consolidate their capacity to provide concrete 
technical  support  to  governments  and  civil  society  in  building  policy  frameworks,  secure 
infrastructures, regulatory capacity and oversight, as well as to share experience in detecting, 
analysing and countering hybrid threats, including disinformation. 

Actions: 

  Set up a new joint operational mechanism and other support measures, building on 
the  work  of  the  European  Cooperation  Network  on  Elections,  to  promote  resilient 
electoral  processes  and  take  further  practical  measures  to  protect  election 
infrastructure against threats, including against cyber-attacks 

  The  Commission  will  organise  a  high-level  event  bringing  together  various 

authorities related to elections to address the challenges outlined in this plan 

  Strengthen cooperation on parity of treatment and balanced media coverage during 

elections 

  Prepare a compendium of e-voting practices 

  Facilitate cooperation between EU networks and partner countries and international 
organisations to build capacity and exchange best practices in countering electoral 
threats and promote high international standards in the use of new technologies 

  Consolidate  the  capacity  of  EU  election  observation  missions  in  third  countries  to 
their  

observe  and  assess  online  election  campaigns  and 
recommendations 

follow-up  on 

to 

2.4

  Promoting democratic engagement and active participation beyond elections 

Efforts  to  support  a  vibrant  civil  society  and  to  promote  and  enhance  democratic 
participation  will  be  at  the  core  of  the  Commission’s  work  in  many  areas,  from  EU 
citizenship, equality and non-discrimination, youth, education, culture and research policies 
to the use of EU funds both within the Union and in its neighbourhood. 

23   The Council Conclusions on EU priorities for cooperation with the Council of Europe 2020-2022 of 13 July 

2020 identify democracy as one of the three priority pillars of cooperation. 

24   Organization  for  Security  and  Co-operation  in  Europe  (OSCE)  –  Office  for  Democratic  Institutions  and 

Human Rights (ODIHR); https://www.osce.org/odihr.  

8 

 
 
 
                                                 
New steps in participatory and deliberative democracy have been taken in several Member 
States  getting  people  involved  in  decision-making  and  empowering  them  on  matters  of 
public  concern25.  Improving  transparency  and  involving  citizens  in  policy-  and  decision-
making enhances democratic legitimacy and trust. Initiatives in this area are closely linked 
and complementary to the work to promote EU citizenship rights including electoral rights 
and inclusive democratic participation, which will be detailed in the Commission’s 2020 EU 
citizenship report. 

The  Commission  will  continue  to  promote  participatory  and  deliberative  democracy, 
building on examples such as the Climate Pact, upcoming projects under the Horizon 2020 
Green  Deal  and  European  Citizens’  Initiatives26,  as  well  as  citizen  participation  in  the 
shaping of EU policies and existing laws27. The Commission’s annual Rule of Law report28 
also assesses the inclusiveness of the legislative process and civil society involvement. The 
Conference  on  the  Future  of  Europe,  a  pan-European  exercise  in  participatory  and 
deliberative democracy,  aims at  enabling people  from  across the EU to  make proposals  to 
shape  future  EU  policies.  The  Conference  will  be  a  catalyst  for  new  forms  of  public 
participation  at  the  European,  national,  regional  and  local  levels.  In  addition,  the  new 
generation of Citizens’ Dialogues will also foster innovative forms of citizens’ participation 
and deliberation, including at transnational level.  

The Commission encourages Member States to make best use of relevant EU structural and 
investment funds to support and reinforce civil society capacities at both national and local 
level  and  involve  civil  society  organisations  in  the  partnership  with  the  different  levels  of 
public administration, including by building a deliberative democracy infrastructure. This 
will allow for better civic participation and public engagement in the shaping of priorities, 
including for the Next Generation EU initiative in each Member State. The tools developed 
to support the Conference for the Future of Europe, such as its multilingual digital platform, 
will enable citizens and stakeholders to put forward proposals and organise debates beyond 
the duration of the Conference itself. 

Deliberative  democracy  will  also  be  supported  under  the  Horizon  2020  and  its  successor, 
Horizon Europe programme, through research, innovation and the transfer of knowledge on 
how it operates in practice, the challenges it faces and the impacts it can have29. In addition, 
the  Commission  will  continue  to  support  research  to  develop  a  better  understanding  of 
people’s  dissatisfaction  with  democracy  and  how  it  can  be  addressed  through  democratic 

25   E.g. the recent Convention citoyenne sur le climat in France demonstrated the importance of including and 
empowering citizens when addressing a complex public problem such as the reduction of carbon emissions. 
In  Ireland,  citizen  assemblies  have  fed  into  informed  decisions  over  very  divisive  social  issues  such  as 
abortion.  Other  institutionalised  processes  include  citizens’  councils  in  parts  of  Austria  (Vorarlberg)  and 
Belgium  (Parliament  of  the  German-speaking  Community  of  Belgium  (2019),  Was  passiert  beim 
Bürgerdialog?). See also OECD (2020), Innovative citizen participation and new democratic institutions: 
catching the deliberative wave (OECD Publishing, Paris). 

26   https://europa.eu/citizens-initiative/_en. 
27  https://ec.europa.eu/info/law/better-regulation/have-your-say. 
28   https://ec.europa.eu/info/publications/2020-rule-law-report-communication-and-country-chapters_en.  
29   The  programme’s  key  strategic  orientations  include  the  creation  of  a  ‘more  resilient,  inclusive  and 
democratic European society’. Projects from the last calls  for proposals of Horizon 2020  will focus  inter 
alia  on  democratising  territorial  cohesion  (experimenting  with  deliberative  citizen  engagement  and 
participatory budgeting in EU regional and urban policies) and cities as arenas of political innovation in the 
strengthening of deliberative and participatory democracy. 

9 

 
 
                                                 
innovation,  including  civic  engagement  and  deliberative  democracy  initiatives.  The  new 
Creative  Europe  Programme  will  offer  new  opportunities  to  actors  in  the  cultural  and 
creative sector for work related to democracy and civic participation. The Commission will 
also continue to promote and to defend the freedom of artists to create without censorship or 
intimidation. 

The Commission will also ensure the  mainstreaming of equality in action at all levels to 
promote  access  to  democratic  participation,  also  in  line  with  the  principles  of  the 
European  Pillar  of  Social  Rights.  This  entails  inclusiveness  and  equality  in  democratic 
participation,  gender  balance  in  politics  and  decision-making,30  and  proactive  steps  to 
counter  anti-democratic  attacks  and  hate  speech  seeking  to  dissuade  women31,  LGBTIQ 
persons and minority groups from being politically active. Particular attention will be paid to 
disadvantaged young people, people with a minority racial or ethnic background32, persons 
with  disabilities33,  persons  with  or  groups  with  lower  levels  of  digital  literacy  and  digital 
engagement (e.g. low-income households without easy internet access or older persons). 

Promoting active citizenship among young people is an important feature of the EU youth 
strategy  (2019-2027)34.  The  EU  youth  dialogue  will  be  reinforced  by  youth  participation 
activities  under  Erasmus+  and  the  European  Youth  Portal.  The  new  European  Solidarity 
Corps  programme  will  offer  a  wider  range  of  opportunities  for  civic  engagement  by 
supporting  communities  in  need  in  the  EU  and  elsewhere.  The  Rights  and  Values 
programme will finance curricula promoting young people’s civic, political and democratic 
engagement  in  support  of  civil  society  organisations’  efforts  to  encourage  and  facilitate 
active  participation.  Externally,  the  Development,  Education  and  Awareness  Programme 
contributes  to  actively  engaging  the  youth  in  addressing  global  challenges  and  raising 
awareness on universal values.  

Further effort will be put into the fight against online hate speech, which can deter people 
from  expressing  their  views  and  participating  in  online  discussions.  In  2021,  the 
Commission will propose an initiative to extend the list of EU crimes under Article 83(1) 
of the Treaty on the Functioning of the European Union to cover hate crime and hate speech, 
including  online  hate  speech.  Work  under  the  Code  of  conduct  on  tackling  illegal  hate 
speech35  will  also  continue.  These  efforts  will  also  contribute  to  increasing  the  safety  of 
journalists  (see  section  3.1).  Tackling  illegal  content  online  while  promoting  freedom  of 
expression is one of the core objectives of the Digital Services Act. 

30   The  2020-2025  gender  equality  strategy  (COM(2020) 152)  includes  measures  to  enhance  women’s 
participation  in  political  decision-making.  It  underlines  the  importance  of  promoting  the  participation  of 
women as voters and candidates in the 2024 EP elections. European political parties requesting EU funding 
are encouraged to be transparent about the gender balance of political party members. 

31   https://www.europarl.europa.eu/RegData/etudes/STUD/2018/604979/IPOL_STU(2018)604979_EN.pdf.  
32   The  EU  anti-racism  action  plan  2020-2025  (COM(2020)  565)  underlines  that  there  are  hurdles  to 
democratic participation and representation for groups susceptible to marginalisation, such as people with a 
minority racial or ethnic background. 

33   In line with obligations under UN Convention on the Rights of Persons with Disabilities to which the EU 
and all its Member States are Party, and in particular Article 29 on participation on political and public life. 
34   The EU youth dialogue reaches more than 50 000 young people in each of its 18-month cycles and is one of 
https://ec.europa.eu/youth/policy/youth-

the biggest single participatory processes for citizens in the EU; 
strategy/youthgoals_en.  

35   https://ec.europa.eu/info/policies/justice-and-fundamental-rights/combatting-discrimination/racism-and-

xenophobia/eu-code-conduct-countering-illegal-hate-speech-online_en.   

10 

 
 
                                                 
Actions: 

  Encourage the use of  EU structural funds to  fund civil  society and build capacity and 
for  deliberative  civic  engagement  and 

infrastructure 

institutional/administrative 
political participation 

  Use EU funds and opportunities under the EU youth strategy, citizenship education, the  
Creative  Europe  Programme  and  the  equality  agenda  to  foster  access  to  democratic 
participation and trust in democracy 

  Fight  against  hate  speech  and  promote  respect  in  the  public  debate  through  the 

extension the list of EU crimes to hate crime and hate speech 

3  STRENGTHENING MEDIA FREEDOM AND MEDIA PLURALISM 

Media freedom  and media pluralism  are essential  to  our democracies and are enshrined in 
the  Charter  of  Fundamental  Rights.  Free  and  pluralistic  media  are  key  to  hold  power  to 
account and to help citizens make informed decisions. By providing the public with reliable 
information,  independent  media  play  an  important  role  in  the  fight  against  disinformation 
and the manipulation of democratic debate.  

Attacks, abuses of defamation laws and other forms of intimidation and pressure, including 
by organised crime, are damaging the environment in which journalists work36. The media 
sector  also  faces  the  challenges  of  the  digital  transformation  and  the  role  of  platforms  as 
gatekeepers  for  online  news  distribution.  The  COVID-19  pandemic  has  exacerbated  these 
trends. It led to major advertising losses, hitting in particular small and local media37.  
There  have  been  new  violations  of  media  freedom38,  sometimes  in  the  name  of  fighting 
online disinformation. In 2020, no less than 90 countries worldwide, including some in the 
EU and its Neighbourhood, have imposed restrictions on media freedoms on the grounds of 
COVID-1939. 

There is a clear need to improve the online and physical safety of journalists, and to provide 
them and others actors involved in protecting the public interest with tools against abusive 
litigation. Better public disclosure of information on who owns or controls media outlets and 
the transparent and fair distribution of state advertising can also protect media pluralism.  
Alongside this European Democracy Action Plan, the Media and Audiovisual Action Plan40 
will address the financial viability of the media sector, help the media industry recover and 
fully seize the opportunity of the digital transformation, and further support media pluralism. 
These  plans  form  a  comprehensive  approach  for  the  media  sector  and  build  on  the  work 

36   European University Institute, (2020) Media Pluralism Monitor Report. The Media Pluralism Monitor, co-
funded by the EU, provides a comprehensive assessment of the media pluralism landscape across Europe: 
https://cmpf.eui.eu/mpm2020-results/. 

37   News  publishing  saw  its  advertising  revenues  drop  between  30%  and  80%  and  TV  by  20%,  during 

generalised lockdowns in Q2 2020; see COM(2020) 784.  

38   https://ipi.media/wpfd-2020-covid-19-accelerating-a-global-decline-in-media-freedom/. 
39   https://rsf.org/en/news/nearly-half-un-member-countries-have-obstructed-coronavirus-coverage.  
40   COM(2020) 784.  

11 

 
 
                                                 
done  by  the  European  Parliament  and  the  Council.41  The  European  Human  Rights  and 
Democracy  Action  Plan  also  provides  concrete  guidance  for  external  actions  in  support to 
free and pluralistic media around the world, especially in support to safety and protection of 
journalists.  

  Safety of journalists 

3.1
The  2020  Rule  of  Law  report42  showed  that  physical  and  online  threats  and  attacks  on 
journalists  are  on  the  rise  in  several  Member  States.  Smear  campaigns  are  frequent  and 
overall  intimidation  and  politically  motivated  interference  have  become  commonplace.  In 
recent  years, Europe has witnessed brutal attacks on free media, with the  assassinations of 
journalists, notably Daphne Caruana Galizia in  Malta, Jan Kuciak and his  fiancée Martina 
Kušnírová in Slovakia. One common trait of these murders was that they were preceded by 
physical and legal threats to the victims. An ever-growing number of journalists are targets 
of threats, increasingly via online means. Journalists are targets of harassment, hate speech 
and  smear  campaigns,  at  times  even  initiated  by  political  actors,  in  Europe  and  beyond43. 
Female journalists are particularly targeted. The 2020 Rule of Law Report noted that such 
pressure has a ‘chilling effect’ on journalists. This can lead to self-censorship and reduce the 
space for public debate on important issues. 

In  April  2016,  recognising  the  damage  that  threats  to  journalists  do  to  the  functioning  of 
democratic  society,  the  Committee  of  Ministers  of  the  Council  of  Europe  adopted  a 
Recommendation on the protection of journalism and safety of journalists and other media 
actors44.  The  Council  of  Europe  has  also  set  up  a  dedicated  Platform  to  Promote  the 
Protection of Journalism and Safety of Journalists45 to monitor alerts. Public authorities have 
a  duty  to  protect  freedom  of  expression  and  journalists’  safety  by  providing  an  enabling 
legal  environment,  taking  criminal  threats  against  journalists  seriously  and  vigorously 
prosecuting attacks. However, the safety of journalists has continued to deteriorate, with the 
Platform registering an ever growing number of alerts46, and the Recommendation needs to 
be implemented better47.  

41   In particular, the recent report by the European Parliament on strengthening media freedom and the Council 

conclusions on safeguarding a free and pluralistic media system. 

42   COM(2020) 580 final. 
43   See European University Institute, (2020) Media Pluralism Monitor Report. The Media Pluralism Monitor, 
co-funded  by  the  EU,  provides  a  comprehensive  assessment  of  the  media  pluralism  landscape  across 
Europe: https://cmpf.eui.eu/mpm2020-results/. 

44   CM/Rec(2016) 4.  This  was  accompanied  by  guidelines  on  prevention,  protection,  prosecution  and  the 
promotion of information, education and awareness-raising with the aim of enhancing journalists’ safety. 
45   The platform facilitates the compilation, processing and dissemination of information on serious concerns 
about  media  freedom  and  journalists’  safety  in  Council  of  Europe  member  states,  as  guaranteed  by 
Article 10 of the European Convention on Human Rights. It aims to improve the protection of journalists, 
action on threats and violence against media professionals and the Council of Europe’s early warning and 
response capacity. 

46   In 2015-2019, it registered a total of 652 alerts, 78% of which remain unresolved. Between March and June 
2020  alone,  a  total  of  126  alerts  were  registered  across  Europe.  See  Council  of  Europe  (2020),  Annual 
report  by  the  partner  organisations  to  the  Council  of  Europe  Platform  to  Promote  the  Protection  of 
Journalism and Safety of Journalists. 

47   https://rm.coe.int/safety-implementation-guide-en-16-june-2020/16809ebc7c. 

12 

 
 
                                                 
While the situation is alarming, a number of good practices have been developed in several 
Member  States48.  These  include  cross-border  initiatives,  e.g. the  Press  Freedom  Police 
Codex  is  an  initiative  developed  by  media  freedom  organisations  to  promote  dialogue 
between police forces and media actors49. The Commission is committed to facilitating the 
exchange and dissemination of best practices to foster a safer space for journalists across the 
EU.  

representatives  of 

regulatory  authorities, 

The  Commission  will  organise  a  structured  dialogue  involving  Member  States  and  their 
journalists,  self-regulatory  bodies 
media 
(media/press  councils)  and  civil  society,  and  bringing  in  the  expertise  of  the  Council  of 
Europe,  OSCE  and  UNESCO50.  This  dialogue  will  take  place  within  the  European  News 
Media Forum that the Commission will set up to strengthen cooperation with stakeholders 
on  media-related  issues51.  Involving  Member  States’  judiciary,  prosecution  and  law 
enforcement  authorities  is  essential  for  effectively  addressing  threats  faced  by  journalists 
and reducing impunity for the perpetrators.  

The Commission will propose in 2021 a recommendation on the safety of journalists. It 
will aim to tackle further safety issues, including those highlighted in the 2020 Rule of Law 
report,  ensure  better  implementation  by  Member  States  of  the  standards  in  the  Council  of 
Europe Recommendation, and draw particular attention to threats against women journalists. 
Securing  stable  funding52  is  also  critical  for  ensuring  that  journalists  are  supported.  For 
example,  the  Media  Freedom  Rapid  Response  pilot  project53  focuses  on  developing 
coordinated  rapid  responses  to  violations  of  press  and  media  freedom,  including  legal  aid 
and practical support (e.g. shelters) for journalists in need in Member States and candidate 
countries.  

The  EU  actively  promotes  and  supports  journalists’  safety  in  its  external  actions  and 
policies54. It will continue to monitor and strengthen the media environment outside the EU 
with a focus on fostering pluralism of independent media and safety of journalists and use 
public  diplomacy  to  respond  to  threats  and  obstructions  to  journalists.  The  EU  Protect 
Defenders  Mechanism  provides  financial  and  legal  support  and  relocation  for  hundreds  of 
journalists  every  year55.  This  work  will  continue,  as  will  legal  support  for  journalists  and 
media  houses  through  thematic  and  bilateral  programmes,  especially  in  cases  of  judicial 
harassment and abusive use of cybersecurity laws.  

48   Documented  by  the  2020  Rule  of  Law  report.  For  example,  in  Belgium,  the  Flemish  Association  of 
Journalists set up a specific hotline for aggression against journalists. In Italy, a coordination centre dealing 
with acts against journalists has been set up. In the Netherlands, the PersVeilig protocol aimed at reducing 
threats, violence and aggression against journalists was concluded between the public prosecution service, 
the police, the Society of Editors-in-Chief and the Association of Journalists. Sweden has set up national 
contact points and allocated resources to support journalists and better investigate hate crimes. 

49   Press Freedom Police Codex, European Centre for Press and Media Freedom (ECPMF). 
50   United Nations Educational, Scientific and Cultural Organization. 
51   COM(2020)784.  
52   These  are  key  objectives  under  the  proposed  2021-2027  Creative  Europe  programme,  which  for  the  first 

time earmarks funds to promote media pluralism. 

53   https://www.mfrr.eu/ 
54   In line  with the  2014 EU Human Rights Guidelines on freedom of expression online and offline; see  EU 

Action Plan on Human Rights and Democracy 2020-2024, (JOIN/2020/5 final, 25.3.2020).  

55   425 journalists were directly supported in 2019. 

13 

 
 
                                                 
Actions: 

  Recommendation  on  the  safety  of  journalists  in  2021,  taking  into  account  new  online 

threats faced in particular by women journalists 

  Structured  dialogue,  under  the  European  News  Media  Forum,  with  Member  States, 
the 

international  organisations 

to  prepare  and 

implement 

stakeholders  and 
recommendation 

  Sustainable  funding  for  projects  with  a  focus  on  legal  and  practical  assistance  to 
journalists  in  the  EU  and  elsewhere,  including  safety  and  cybersecurity  training  for 
journalists and diplomatic support 

3.2

  Fighting abusive use of strategic lawsuits against public participation  

Strategic lawsuits against public participation (SLAPPs) are a particular form of harassment 
increasingly  used  against  journalists  and  others  involved  in  protecting  the  public  interest. 
They are groundless or exaggerated lawsuits initiated by state organs, business corporations 
or  powerful  individuals  against  weaker  parties  who  express  criticism  or  communicate 
messages that are uncomfortable to the litigants, on a matter of public interest. Their purpose 
is to censor, intimidate and silence critics by burdening them with the cost of a legal defence 
until they abandon their criticism or opposition. While civil society actors can be vulnerable 
to such initiatives, the nature of journalists’ work makes them particularly exposed56. 
A recent study57 shows that SLAPPs are increasingly used across many Member States, in 
an environment where hostile activity against journalists is growing58. While most result in 
acquittals, they still raise serious concerns, as they can interrupt the work of journalists and 
affect  their  credibility.  Given  the  imbalance  in  power  and  resources,  SLAPPs  can  have  a 
devastating  impact  on  the  victims’  financial  resources  and  produce  ‘chilling  effects’, 
dissuading or preventing them from pursuing their work in the public interest. SLAPPs are 
often used in combination with threats to physical safety – Daphne Caruana Galizia had 47 
such lawsuits pending against her in Malta and abroad at the moment of her assassination. 

SLAPPs  rely  on  national  law,  but  they  can  be  more  complex  and  more  costly  to  defend 
when  deliberately  brought  in  another  jurisdiction  or  when  they  exploit  differences  in 
national procedural and private international law. SLAPPs often have a cross-border nature. 
The fact  that online media content is  accessible across jurisdictions may  open the way for 
forum shopping and hamper effective access to justice and judicial cooperation. 

In 2021 the Commission will present an initiative to protect journalists and civil society 
against  SLAPPs.  To  prepare  this  work,  the  Commission  is  carrying  out  a  mapping  study 
and will be running  a technical  focus  group to  gather feedback on the type of legal  aid  or 
support  that  could  be  envisaged  for  SLAPP  victims.  Also,  a  new  expert  group  will  be 

56   SLAPPs  are  typically  launched  against  individual  journalists,  activists,  human  rights  defenders  or  civil 
society  organisations  that  have  a  public  watchdog  function.  See  the  policy  paper  signed  by  100  NGOs, 
Ending gag lawsuits in Europe, protecting democracy and fundamental rights; 
https://www.ecpmf.eu/ending-gag-lawsuits-in-europe-protecting-democracy-and-fundamental-rights/ 
57   https://ec.europa.eu/info/sites/info/files/ad-hoc-literature-review-analysis-key-elements-slapp_en.pdf 
58   The Council of Europe’s Platform is monitoring alerts relating to SLAPPs; see  Hands off press freedom: 
attacks on media in Europe must not become a new normal, annual report by the partner organisations to 
the Council of Europe Platform to Promote the Protection of Journalism and Safety of Journalists (2020). 

14 

 
 
                                                 
 
established to gather legal practitioners, journalists, academics, members of civil society and 
professional  organisations,  with  the  aim  to  bring  together  expertise,  exchange  and 
disseminate  best  practices  on  legal  support  for  journalists  and  other  actors  confronted 
with  SLAPP  cases.  Dedicated  judicial  training  should  also  help  judges  to  know  how  to 
identify abusive litigation and use the available tools to address it59. Relevant cross-border 
aspects will also be examined in the context of the evaluation by 2022 of the Rome II and 
Brussels Ia Regulations60.  

Actions: 

  Set up expert group on SLAPPs in early 2021 

  Present initiative to protect journalists and civil society against SLAPPs in late 2021 

3.3

  Closer cooperation to develop and implement professional standards 

Transparency and compliance with professional norms and standards are essential for public 
trust in the media. Increasing commercial, and sometimes political, pressure puts a strain on 
media  independence  and  journalists’  ability  to  follow  codes  of  conduct  and  standards  of 
excellence. 

Since  2019,  the  Commission  has  been  co-funding  a  pilot  project  on  media  councils  in  the 
digital era61, which aims to raise the profile of media self-regulation bodies. As a next step, 
the Commission will promote stronger cooperation between national media councils, other 
media self-regulatory bodies, independent media regulators and networks of journalists. The 
goal  will  be  to  identify  more  clearly  the  challenges  faced  and  develop  policy 
recommendations to foster journalistic standards in the EU.  

At  the  same  time,  the  Commission  will  continue  to  support  self-regulatory  initiatives 
promoting  professional  standards62,  including  charters  of  editorial  independence,  and 
discussions  on  the  challenges  faced  by  journalists.  In  particular,  dedicated  support  will  be 
provided  in  the  form  of  grants  under  the  cross-sectoral  strand  of  Creative  Europe  for 
collaborative  news  media  partnerships,  which  will  include  the  development  of  editorial 
standards, training of professionals and sharing of best practices.  

Actions: 

  Support EU cooperation between national media councils, other media self-regulatory 
bodies,  independent  media  regulators  and  networks  of  journalists,  and  initiatives 
fostering journalistic partnerships and standards  

59   Commission Communication ‘Ensuring justice in the EU — a European judicial training strategy for 2021-

2024’, COM(2020) 713 final. 

60  Regulation (EC) No 864/2007 of 11 July 2007 on the law applicable to non-contractual obligations (Rome 
II)  (OJ  L  199,  31.7.2007,  p.  40–49)  and  Regulation  (EU)  No  1215/2012  of  12  December  2012  on 
jurisdiction and the recognition and enforcement of judgments in civil and commercial matters (OJ L 351, 
20.12.2012, p. 1–32). 

61   https://ec.europa.eu/digital-single-market/en/news/pilot-project-media-councils-digital-age-0  
62   This  includes  the  development  of  structural  and  procedural  indicators  for  trustworthiness  by  the  media 
sector, promoting compliance with professional norms and ethics. The Commission co-funds for example 
the implementation of the Journalism Trust Initiative  https://jti-rsf.org/en  

15 

 
 
                                                 
3.4

  Additional measures to support media pluralism 

Transparency of media ownership is essential for assessing the plurality of media markets. 
The Council of Europe has also underlined the importance of transparency in  enabling the 
public  to  evaluate  the  information  and  opinions  disseminated  by  the  media63.  The  public 
consultation  for  this  action  plan  found  widespread  support  for  clear-cut  obligations  on  all 
media outlets and companies to publish detailed information about their ownership64. 
The revised Audiovisual Media Services Directive65 (AVMSD) is an important step towards 
ensuring  high  transparency  standards  in  the  European  media  sector,  encouraging  national 
legislation requiring transparency  of ownership of media service  providers66. The deadline 
for  Member  States  to  transpose  the  Directive  was  19 September 2020  and  transposition  is 
currently  being  assessed.  The  2020  Rule  of  Law  report  showed  that,  while  some  Member 
States  have  well-developed  systems  in  place  to  ensure  transparency  of  media  ownership, 
others have no such system or face obstacles to effective public disclosure67. 

To improve the understanding and public availability of media ownership information,  the 
Commission will co-finance the new Media Ownership Monitor, a pilot project setting up 
a  publicly  available  database  containing  relevant  information  on  media  outlets,  which  the 
Commission  intends  to  eventually  expand  to  cover  all  Member  States.  Building  on  the 
results  of  that  project  and  on  the  revised  AVMSD,  the  European  Regulators  Group  for 
Audiovisual Media Services could develop further guidance in this area. 

Given  the  serious  impact  of  the  COVID-19  pandemic,  the  Commission  calls  on  Member 
States to support media in a way that respects and promotes media independence, freedom 
and pluralism68. The responsibility for ensuring that the news media sector can continue to 
offer products and services promoting pluralistic information, while competing in open and 
efficient markets, lies primarily with the Member States. Existing State aid rules clarify the 
conditions  under  which  public  support  may  be  granted  by  Member  States.  In  order  to 
facilitate  support  from  national  authorities,  the  Council  has  invited  the  Commission  to 
evaluate the application of State aid rules to the press sector. The Commission is assessing 
the  need  for  appropriate  action69.  In  addition,  the  State  aid  Temporary  Framework  of  19 

63   Recommendation  CM/Rec(2018) 11  of  the  Committee  of  Ministers  to  member  states  on  media  pluralism 

and transparency of media ownership. 

64  e.g. 88%  of  respondents  were  in  favour  of  obligations  on  all  media  outlets  and  companies  to  publish 

detailed information about their ownership on their website. 

65  Directive (EU) 2018/1808 of 14 November 2018 amending Directive 2010/13/EU on the coordination of 
certain provisions laid down by law, regulation or administrative action in Member States concerning the 
provision  of  audiovisual  media  services  (Audiovisual  Media  Services  Directive)  in  view  of  changing 
market realities (OJ L 303, 28.11.2018, p. 69). 

66  Article 5(2) of Directive (EU) 2018/1808. 
67  In order to provide better overview of the media transparency rules, an interactive database presenting the 
national  legislative  frameworks  in  this  regard  will  be  published  as  part  of  an  independent  study  on  the 
implementation of the AVMSD. 

68  See also COM/2020/575 final and JOIN(2020) 8 final. 
69   To facilitate support to the press, and enhance the transparency and predictability of State aid control in this 
repository 
and  will 
sector, 
has  made 
(https://ec.europa.eu/competition/sectors/media/sa_decisions_to_media.pdf) 
case 
practice.  Regularly  updated  information  on  aid  granted  by  Member  States  is  also  accessible  in  the 
transparency register. 

an 
containing 

the  Commission 

regularly 

relevant 

update 

online 

16 

 
 
                                                 
March  2020  also  applies  to  sector  specific  measures,  such  as  aid  to  the  press,  music,  and 
audiovisual sectors70.  

State  financial  support  through  public  interest  advertising  can  be  crucial,  especially  for 
non-profit, community media and other less commercial forms of journalism. Nevertheless, 
without  appropriate  safeguards  to  protect  media  independence,  state  advertising  can  be 
used to put indirect political pressure on the media71. Transparent rules and fair criteria for 
the  allocation  of  advertising  can  mitigate  the  risks  in  this  area.  In  particular,  setting  up 
publicly accessible contract  registers that publish awarded contracts  and their amendments 
(as supported by the Commission’s 2017 public procurement strategy72) can help.  

The  Commission  will  also  analyse  existing  national  media  diversity  and  concentration 
rules  to  see  whether  and  how  they  ensure  a  plurality  of  voices  in  digital  media  markets, 
especially in the light of the growing role of online platforms. It will map options to address 
challenges  in  this  area  and  further  support  media  diversity  in  complementarity  with 
competition  tools,  rules  on  freedom  of  establishment  and  the  revised  AVMSD.  The  latter 
allows Member States to take measures to ensure the appropriate prominence of audiovisual 
media services  of general  interest,  to meet  objectives such as media pluralism,  freedom  of 
speech and cultural diversity. 73 The Commission will encourage a common approach on this 
matter, as outlined in the Media and Audiovisual Action Plan.  

Actions: 

  Set  up  the  Media  Ownership  Monitor  and  develop  further  possible  guidance  on  the 

transparency of media ownership  

  Foster measures for the transparent and fair allocation of state advertising 

  Map options for further support for media diversity and foster a European approach on 

the prominence of audiovisual media services of general interest 

4  COUNTERING DISINFORMATION 

It is important to distinguish between different phenomena that are commonly referred to as 
‘disinformation’ to allow for the design of appropriate policy responses:  

70   Aid  granted  under  the  Temporary  Framework  may  be  cumulated  with  aid  under  de  minimis  Regulations 
(Commission Regulations (EU) No 1407/2013, No 1408/2013, No 717/2014, and No 360/2012.), which is 
exempt  from  the  notification  obligation,  provided  that  the  provisions  and  cumulation  rules  of  those 
Regulations are respected. There have been cases in 2020 concerning Denmark, Italy and Luxembourg. 
71  The 2020 Rule of Law report showed that many Member States lack specific rules  for the distribution of 
state advertising, with little transparency on distribution criteria, amounts allocated and beneficiaries. The 
Commission will continue to examine this issue in the context of its future annual reports. 

72  Commission  Communication  on  Making  public  procurement  work 

in  and 

for  Europe 

(COM(2017) 572 final). 

73   Article  7a  and  Recital  25  of  the  revised  AVMSD.  Regarding  these  provisions,  a  specific  subgroup  of 
ERGA  was  set  up  in  2020  to  facilitate  a  common  understanding  of  its  scope  and  potential  appropriate 
measures, which would guarantee that audiovisual media services of general interest are given appropriate  
prominence as well as types of regulatory approaches Member States can take.  

17 

 
 
 
                                                 
  misinformation is false or misleading content shared without harmful intent though the 
effects  can  still  be  harmful,  e.g. when  people  share  false  information  with  friends  and 
family in good faith;  

  disinformation is false or misleading content that is spread with an intention to deceive 

 

or secure economic or political gain and which may cause public harm; 
information  influence  operation  refers  to  coordinated  efforts  by  either  domestic  or 
foreign actors to influence a target audience using a range of deceptive means, including 
suppressing independent information sources in combination with disinformation; and  
  foreign interference in the information space,  often carried out  as part of a broader 
hybrid operation, can be understood as coercive and deceptive efforts to disrupt the free 
formation  and  expression  of  individuals’  political  will  by  a  foreign  state  actor  or  its 
agents74. 

For  each  type  of  these  phenomena,  and  depending  on  the  actor,  channel  and  impact, 
different  policy  responses  are  required,  in  accordance  with  fundamental  rights  and 
democratic standards. For example, misinformation, where there is no intention to deceive, 
cause  public  harm  or  make  an  economic  gain,  can  be  tackled  essentially  by  proactive 
communication,  providing  reliable  information  and  raising  awareness  of  the  need  to 
critically  assess  content  and  sources.  To  address  the  other  phenomena,  where  there  is  a 
harmful  intent,  a  more  robust  response  is  needed  and  our  capabilities  need  to  be 
continuously developed. Along these lines, and building on progress achieved75, this action 
plan  sets  out  further  action  to  counter  disinformation,  foreign  interference  and  influence 
operations. 

Reducing the incentives in the online environment that allow for the amplification of such 
content  is  an  important  response  element  as  well.  Information  influence  operations  and 
foreign  interference  call  for  a  stronger  and  well-coordinated  response,  using  other 
instruments and approaches76. In this context, the Commission services and the EEAS will 
work  with  Member  States,  civil  society  and  industry  towards  refined  common  definitions 
and methodologies in  order to  address  different  categories of disinformation and influence 
activities. The European Parliament has set up a special committee on Foreign Interference 
in  all Democratic Processes in  the European  Union, including Disinformation (INGE) that 
can also contribute to this issue. The EU will also continue to invest in research in this area 
and strengthen its strategic communication and awareness raising activities. 
In  the  joint  2018  Action  Plan  against  Disinformation77,  also  building  on  the  experience  of 
the EEAS East  Stratcom Task Force to  address  Russia’s disinformation  campaign, the EU 
set  out  its  approach  to  disinformation.  This  was  followed  by  specific  steps  to  address  the 

for 

74   See  also  Pamment,  J.,  The  EU’s  role  in  fighting  disinformation:  Taking  back  the  initiative,  Carnegie 
at: 
Endowment 
https://carnegieendowment.org/2020/07/15/eu-s-role-in-fighting-disinformation-taking-back-initiative-pub-
82286. 

Peace  Working 

International 

available 

Paper, 

2020; 

July 

75   For an overview of EU action against disinformation see JOIN(2020) 8 final, p. 2. 
76   Pamment, J., The EU’s role in fighting disinformation: Crafting a new disinformation framework, Carnegie 
Endowment 
at 
https://carnegieendowment.org/2020/07/15/eu-s-role-in-fighting-disinformation-taking-back-initiative-pub-
82286. 

Peace  Working 

International 

September 

available 

Paper, 

2020; 

for 

77   JOIN(2018) 36 final. 

18 

 
 
                                                 
disinformation  wave  during  the  COVID-19  pandemic78  as  well  as  in  relation  to  the 
development of a safe and effective vaccine. The EU’s work in this area will continue to be 
firmly rooted in European values and principles and fully safeguard freedom of expression. 
The  actions  presented  below  aim  to  prevent  the  manipulative  amplification  of  harmful 
content by increasing transparency, curbing manipulative techniques and reducing economic 
incentives  for  spreading  disinformation,  as  well  as  introduce  deterrence  by  imposing  costs 
on actors engaged in influence operations and foreign interference. They do not seek to and 
cannot interfere with people’s right to express opinions or to restrict access to legal content 
or limit procedural safeguards including access to judicial remedy.  

A more transparent and accountable digital ecosystem allowing to assess the spread, reach 
and the degree of coordination behind disinformation campaigns is paramount. The EU will 
support  the  important  work  of  journalists,  civil  society  organisations  and  researchers  to 
maintain a healthy and varied information space, notably with respect to fact-checking. 

4.1

  Improving EU and Member State capacity to counter disinformation 

Online and offline influence operations can be relatively cheap to carry out and have limited 
downsides  for  those  acting  with  malign  intent,  which  partly  explains  their  proliferation.79 
Information  can  also  be  weaponised  by  foreign  actors80.  For  example,  foreign  actors  and 
certain  third  countries  (in  particular  Russia81  and  China82)  have  engaged  in  targeted 
influence  operations  and  disinformation  campaigns  around  COVID-19  in  the  EU,  its 
neighbourhood  and  globally,  seeking  to  undermine  democratic  debate,  exacerbate  social 
polarisation and improve their own image. When foreign actors use manipulative tactics to 
mislead EU citizens for their own gain, the threat to democracy demands a comprehensive, 
collective response. At the same time, the threat of disinformation by domestic actors is also 
growing83. 

A prerequisite for effective responses to disinformation, both when it occurs in isolation and 
when  it  is  part  of  a  broader  influence  operation  or  foreign  interference,  is  a  thorough 
understanding of the challenges. Disinformation by spreading outright false content is only 
one technique used, others include distortion of information, misleading the audience and 
manipulative  tactics  such  as  fake  profiles  and  false  engagement  to  artificially  amplify 
narratives on specific political issues and exploit existing divisions in society.  

78   Joint  Communication  of  the  European  Commission  and  the  High  Representative,  Tackling  COVID-19 

disinformation  getting the facts right (JOIN(2020) 8 final). 

79   For example report by the NATO StratCom Center of Excellence, which shows that an entire industry has 
developed  around  the  manipulation  of  social  media,  including  the  purchase  of  fake  accounts,  fake 
engagement and others, that can be found easily on the internet at a low price.  

80   See for example Information Manipulation – A challenge for our democracies, French Ministry for Europe 

and Foreign Affairs and the Ministry of Defence.  

81   www.EUvsDisinfo.eu has identified over 500 examples of pro-Kremlin disinformation on COVID-19 in its 

publicly available database which holds over 10.000 examples of pro-Kremlin disinformation.  

82  The  EEAS  has  described 

foreign 

states’  activities 

in 

its  public  analytical 

report  e.g.: 

https://euvsdisinfo.eu/eeas-special-report-update-short-assessment-of-narratives-and-disinformation-
around-the-covid19-pandemic-updated-23-april-18-may/ 

83  Pamment, J., The EU’s role in fighting disinformation: Taking back the initiative, Carnegie Endowment for 
International Peace Working Paper, July 2020; available at: https://carnegieendowment.org/2020/07/15/eu-
s-role-in-fighting-disinformation-taking-back-initiative-pub-82286. 

19 

 
 
                                                 
The  new  threat  landscape  calls  for  even  closer  cooperation  within  the  EU,  with  relevant 
stakeholders in civil society, academia and private industry, and with international partners. 
Only  by  pooling  existing  knowledge  on  hybrid  threats84  across  different  sectors  (e.g. 
disinformation,  cyber  operations  and  election  interference)  can  the  EU  develop  the 
comprehensive understanding of the threat landscape that it needs to respond effectively to 
disinformation  and influence operations.  The EU Security  Union Strategy85  puts  particular 
focus  on  the  systematic  mainstreaming  of  hybrid  considerations  into  policy  making,  to 
address the heightened risk of hybrid attacks by state and non-state actors, through a mix of 
cyber-attacks, damage to critical infrastructure, disinformation campaigns, and radicalisation 
of the political narrative.  

The  Commission  and  the  High  Representative  will  strengthen  cooperation  structures  in 
this  area  within  the  EU,  but  also  with  international  partners.  The  Rapid  Alert  System  will 
continue to cooperate with international partners such as NATO, the G7, but possibilities to 
engage with other relevant organisation such as the EU Agency for Cybersecurity (ENISA), 
the European Digital  Media Observatory  (EDMO)86 and Europol will also  be explored, as 
appropriate.  

In addition to the Rapid Alert System, the European Cooperation Network on Elections, is 
also working to develop effective responses to disinformation, when part of a broader hybrid 
threat, by supporting cooperation between Member States and facilitating engagement with 
international  entities  like  the  Council  of  Europe  and  the  OSCE  Office  for  Democratic 
Institutions  and  Human  Rights,  as  part  of  its  comprehensive  approach  to  free  and  fair 
elections in Europe. Regular cooperation and participation in joint meetings of the relevant 
structures  working  on  disinformation  will  allow  to  put  their  vast  knowledge  to  best  use, 
developing a multi-disciplinary response to disinformation. 

The  EU  institutions  will  ensure  that  their  internal  coordination  on  disinformation  is 
strengthened,  with  a  clear  protocol  for  action  to  pull  together  knowledge  and  resources 
quickly  in  response  to  specific  situations,  for  example  ahead  of  European  Parliament 
elections.  This  would  build  on  the  approach  taken  for  COVID-19,  where  a  system  of 
reinforced  coordination  has  been  set  up  in  response  to  the  tougher  challenges.  Member 
States are invited to invest more in the relevant networks and ensure (also at national level) 
proper  coordination  between  those  who  represent  them  in  various  fora,  so  as  to  ensure 
effective cooperation and coherent, comprehensive responses. 

The  EU  has  steadily  improved  its  abilities  to  expose  information  influence  methods  by 
foreign  actors  and  has  called  out  perpetrators.  However,  with  the  continuously  changing 
threat  landscape,  the  EU  needs  to  use  more  systematically  the  full  range  of  tools  in  its 
toolbox  for  countering  foreign  interference  and  influence  operations,  and  further 

84   To date, the process of building all-source situational awareness on hybrid threats within the EU is led by 

INTCEN and its Hybrid Fusion Cell. 

85   COM/2020/605 final. 
86  EDMO was set up in October 2020. It is based on the work of an independent multidisciplinary community 
of  researchers,  fact-checkers  and  other  relevant  stakeholders,  aiming  to  contribute  to  increased  resilience 
and a better understanding of disinformation. In addition, cooperation between the RAS and the European 
Cooperation Network on Elections will be reinforced to allow to make better use of the vast knowledge of 
these two networks.    

20 

 
 
                                                 
develop  them  including  by  imposing  costs  on  the  perpetrators87,  in  full  respect  of 
fundamental rights and freedoms. Possible ways of doing so range from publicly identifying 
commonly  used  techniques  (so  as  to  render  them  operationally  unusable)  to  imposing 
sanctions following repeated offences. The response toolbox needs to be further developed. 
The  Commission  and  the  HR/VP  will  explore  conceptual  and  legal  aspects  of  devising 
appropriate  instruments,  seeking  synergies  with  the  EU’s  Framework  for  a  joint  EU 
diplomatic response to malicious cyber activities (‘cyber diplomacy toolbox’)88. 

The  EU  will  continue  to  support  work  to  build  resilience  in  third  countries,  to  equip 
societies and democratic governments with the means to respond to external disinformation 
threats and to raise awareness of European values and EU-supported projects, in particular 
in  the  European  Neighbourhood  and  Enlargement  region.  This  includes  efforts  aimed  at 
communicating  more  effectively  the  Union’s  policies  and  values,  strengthening  the  media 
environment,  including  support  for  greater  media  freedom  and  pluralism,  and  raising 
awareness and building resilience against disinformation and influence operations. 

Actions: 

  Develop the EU’s toolbox for countering foreign interference and influence operations, 
including  new  instruments  that  allow  imposing  costs  on  perpetrators,  as  well  as 
strengthening the EEAS strategic communication activities and taskforces 

  Put  in  place  a  new  protocol  to  strengthen  existing  cooperation  structures  to  fight 

disinformation, both in the EU and internationally 

  Develop  a  common  framework  and  methodology  for  collecting  systematic  evidence  on 
foreign interference and a structural dialogue with civil society, private industry actors 
and other relevant stakeholders to regularly review the threat situation 

 

Increase  support  for  capacity-building  of  national  authorities,  independent  media  and 
civil  society  in  third  countries  to  detect  and  respond  to  disinformation  and  foreign 
influence operations 

4.2

  More obligations and accountability for online platforms 

Information  exchanged  on  social  media  platforms  has  become  increasingly  important  for 
news consumption and political debate. However, online platforms can be used by malicious 
operators  for  disseminating  and  amplifying  false  and  misleading  content  and  have  been 
criticised  for  the  lack  of  transparency  in  the  use  of  algorithms  to  distribute  content  online 
and  for  targeting  users  on  the  basis  of  the  vast  amount  of  personal  data  generated  from 
online activity. 

Systems  such  as  ranking  and  recommender  algorithms,  which  facilitate  citizens’  access  to 
relevant  information,  can  also  be  manipulated,  in  particular  through  coordinated  and 
inauthentic  actions,  to  facilitate  the  wide  dissemination  of  disinformation  on  online 

87  74%  of  respondents  to  the  public  consultation  were  in  favour  of  imposing  costs  on  states  that  conduct 
organised  disinformation  campaigns.  Civil  society  organisations  stressed  the  need  to  make  the  threat  of 
targeted sanctions more credible and frequent, thereby raising the cost of foreign influence operations and 
deterring interference. 

88   https://www.consilium.europa.eu/en/press/press-releases/2017/06/19/cyber-diplomacy-toolbox.  

21 

 
 
                                                 
platforms. A diligent inspection by the platform and meaningful transparency towards users 
and researchers, can help better understand and address such threats. 

These and other problems specific to disinformation were identified in a recent evaluation of 
the Code of practice on disinformation89 (which platforms and other stakeholders joined on a 
voluntary  basis).  In  the  Commission’s  view,  a  more  robust  approach  based  on  clear 
commitments  and  subject  to  appropriate  oversight  mechanisms  is  necessary  to  fight 
disinformation more effectively. 

The  Digital  Services  Act  (DSA)  will  propose  a  horizontal  framework  for  regulatory 
oversight,  accountability and transparency of the online space in  response to  the emerging 
risks.  It  will  propose  rules  to  ensure  greater  accountability  on  how  platforms  moderate 
content, on advertising and on algorithmic processes. Very large platforms will be obliged to 
assess the risks their systems pose  not only as regards illegal content and products but also 
systemic risks to the protection of public interests and fundamental rights, public health and 
security.  In  this  context,  very  large  platforms  will  also  need  to  develop  appropriate  risk 
management tools and take measures to protect the integrity of their services against the use 
of  manipulative  techniques.  The  DSA  will  provide  users  with  meaningful  possibilities  to 
challenge the platforms’ decisions to remove or label content. 
The DSA will also establish a co-regulatory backstop90 for the measures which would be 
included in a revised and strengthened Code of practice on disinformation. Based on this co-
regulatory  approach,  the  Commission  will  steer  efforts  with  targeted  actions  addressing 
issues specific to disinformation on three pillars: 

 

the  Commission  will  issue  guidance,  in  parallel  to  the  opening  of  the  co-legislative 
discussions  on  the  DSA,  setting  out  how  platforms  and  other  relevant  stakeholders 
should step up their measures to address the shortcomings identified in the assessment 
of  the  Code  of  practice  on  disinformation.  Given  the  sensitivity  of  the  issues,  the 
Commission  will  follow  a  multi-stakeholder  approach  involving  not  only  platforms 
but also other stakeholders, such as advertisers, media, civil society, fact-checkers and 
academia; 

  subsequently,  the  Commission  will  call  upon  signatories  and  relevant  stakeholders’ 
groups,  including  in  cooperation  with  ERGA,  to  strengthen  the  Code  of  Practice 
according to the guidance; 
the Commission will also set up a more robust framework for recurrent monitoring 
of the strengthened Code of Practice. This framework will build on the experience of 
the COVID-19 disinformation monitoring exercise91. 

 

In addition, stronger enforcement of the General Data Protection Regulation (GDPR)92 in 
respect  of  online  platforms  and  other  players  influencing  the  spread  of  disinformation  is 

89   SWD(2020) 180 final. 
90   A large number of respondents support the option of pursuing the Code of practice on disinformation and 
combining it with some form of regulation. This approach is notably supported by regulators, civil society 
organisations and academia. 

91   JOIN(2020) 8 final. 
92   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 (OJ L 119, 4.5.2016, p. 1). 

22 

 
 
                                                 
needed,  in  line  with  the  September  2020  guidance  from  the  European  Data  Protection 
Board93.  

Based  on  the  guidance  issued  by  the  Commission,  the  strengthened  Code  of  Practice  will 
aim to address the following objectives: 

  monitor the impact of disinformation and the effectiveness  of platforms’ policies, 
on the basis of a new methodological framework which includes principles for defining 
Key  Performance  Indicators  (KPIs).  In  this  context,  timely  information  on  platforms’ 
policies  and  access  to  relevant  data,  needs  to  be  available  to  allow,  amongst  others, 
measuring progress against the KPIs; 

  support adequate visibility of reliable information of public interest94 and maintain 
a  plurality  of  views:  by  developing  accountability  standards  (co-created  benchmarks) 
for  recommender  and  content  ranking  systems  and  providing  users  with  access  to 
indicators of the trustworthiness of sources; 

  reduce  the  monetisation  of  disinformation  linked  to  sponsored  content:  in 
cooperation with advertisers, limiting the false or misleading issue-based advertisement 
on  online  platforms  or  on  third-party  websites  as  well  as  the  placement  of  ads  on 
websites that are purveyors of disinformation95;  

  step  up  fact-checking,  by  establishing  transparent  standards  and  procedures  for 
open and non-discriminatory collaboration between fact-checkers and platforms and 
foster cooperation96; 

  strengthen  the  integrity  of  services  offered  by  online  platforms  by  developing 
limit  the  artificial  amplification  of  disinformation 

appropriate  measures  to 
campaigns;  

  ensure  an  effective  data  disclosure  for  research  on  disinformation,  by  developing  a 
framework  in  line  with  applicable  regulatory  requirements  and  based  on  the 
involvement of all relevant stakeholders (and independent from political influence). The 
European Digital Media Observatory (EDMO) can facilitate the development of such a 
framework.  The  Commission  notes  that  the  GDPR  does  not  a  priori  and  across  the 
board prohibit the sharing of personal data by platforms with researchers97. 

Actions: 

 

Issue  guidance  for  strengthening  the  Code  of  Practice  on  Disinformation  (Spring 
2021) 

93   https://edpb.europa.eu/our-work-tools/public-consultations-art-704/2020/guidelines-082020-targeting-

social-media-users_en. 

94  During  the  Covid-19  crisis  online  platforms  have  promoted  accurate  and  reliable  information  about 
COVID-19  from  the  WHO,  national  health  authorities  and  independent  media  outlets.  They  have 
implemented  new  tools  such  as  information  panels,  cards,  pop-ups,  maps  and  prompts  that  lead  users 
directly to reliable information sources in multiple languages. It is nevertheless important that citizens are 
always able to access a plurality of sources. 

95   The  Global  Disinformation  Index  recently  estimated  that  online  ad  spending  on  disinformation  domains 

amounted to $235 million a year: https://disinformationindex.org/  

96   Alongside  media  and  other  relevant  actors,  fact-checkers  have  a  specific  role  in  the  development  of 

trustworthiness indicators and the scrutiny of ad placement. 

97  See  in this respect also  Data protection rules as a pillar of citizens’ empowerment and EUs approach to 
digital  transition  -  two  years  of  application  of  the  General  Data  Protection  Regulation,  SWD/2020/115 
final, page 27.  

23 

 
 
                                                 
  Convene the signatories of the Code of Practice and relevant stakeholders groups to 

strengthen the code according to the guidance  

  Set up a permanent framework for the monitoring of the code  

4.3

  Empowering citizens to make informed decisions 

Everyone  has  a  role  to  play  in  combatting  disinformation  and  misinformation.  Media 
literacy,  including  critical  thinking,  is  an  effective  capacity  helping  citizens  of  all  ages  to 
navigate the news environment, identify different types of media and how they work, have a 
critical  understanding  of  social  networks  and  make  informed  decisions98.  Media  literacy 
skills help citizens check information before sharing it, understand who is behind it, why it 
was  distributed  to  them  and  whether  it  is  credible.  Digital  literacy  enables  people  to 
participate in the online environment wisely, safely and ethically. 

Countering disinformation and the use of hate speech through education and training as well 
as the promotion of open political debates is crucial for effective participation in society and 
democratic  processes  and  is  an  important  priority  in  the  Digital  Education  Action  Plan99. 
Over  40%  of  young  people  consider  that  critical  thinking,  media  and  democracy  are  ‘not 
taught sufficiently’ in school. In this context, promoting citizenship education is key in view 
of  ensuring  that  young  people  are  equipped  with  the  social  and  civic  competences  to  be 
open-minded, think critically and fully participate in our diverse societies. Along this line, 
ensuring academic freedom in higher education institutions is also at the core of all higher 
education policies developed at EU-level. 

The Commission will increase its efforts to strengthen media literacy from various angles 
and  further  support  national  media  literacy  campaigns,  in  cooperation  with  the  European 
Digital  Media  Observatory  (EDMO)  and  the  Media  Literacy  Expert  Group.  The  revised 
Audiovisual Media Services Directive requires Member States to promote the development 
of  media  literacy  skills.  It  also  obliges  video-sharing  platforms  to  set  up  effective  media 
literacy  tools  and  raise  user  awareness.  These  are  further  developed  under  the  Media  and 
Audiovisual Action Plan, under which citizens are to be equipped with the necessary skills 
to understand fully the mechanisms that shape online interaction among users, including via 
a media literacy toolbox and guidelines to Member States. 

The Commission will support media literacy projects under the new cross-sectoral strand of 
the  Creative  Europe  programme.  Media  literacy  projects  will  also  be  supported  across 
various  other  programmes  involving  young  people  and  schools  (e.g.  Erasmus+  and  the 
European  Solidarity  Corps).  In  2021,  the  priority  theme  for  the  ‘etwinning’  action  (which 
helps schools, teachers and students across the EU to collaborate via new technologies) will 
be  ‘media  literacy  and  disinformation’.  EDMO  and  the  multidisciplinary  community 
coordinated  by  it,  will  provide  support  to  national  media  literacy  campaigns  aiming  at 
strengthening  citizens’  ability  to  assess  the  quality  and  veracity  of  online  information, 
including citizens with additional needs. Through the work of its national hubs, the EDMO 
will  identify  specific  issues  to  be  tackled.  The  Commission  will  also  scale  up  its  efforts 

98   Also, the new European digital identity proposal announced for 2021 will make it easier to carry out tasks 
and  access  services  online  across  Europe  and  ensure  that  people  have  greater  control  and  peace  of  mind 
over what data they share and how it is used. 

99   COM(2020) 624 final. 

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within the next edition of the European media literacy week.  It will also  cooperate closely 
with international organisations such as UNESCO.  

In addition, the Commission will work on developing common guidelines for teachers and 
educational staff to foster digital literacy and tackle disinformation through education and 
training, as set out in the Digital Education Action Plan. In this context, it will engage with 
multiple stakeholders, including civil society, European technology companies and carriers, 
broadcasters,  journalists,  the  Media  Literacy  Expert  Group,  EDMO,  national  authorities, 
parents, students and young people. The guidelines will go hand in hand with new initiatives 
to develop innovative ways to fight disinformation, such as an EUvsDisinfo hackathon. 

The Commission will support the involvement of journalists in media literacy activities, in 
particular  through  ‘back-to-school’  initiatives  enabling  them  to  discuss  their  work  and  the 
role of the media with school pupils. 

Support  for  civil  society  (including  funding)  will  be  a  key  element  of  action  to  tackle 
disinformation. The Commission will support initiatives aimed at helping civil society actors 
to participate in public debate. It will also help to strengthen cooperation across civil society 
at  European  level.  This  could  be  supported  by  several  programmes  in  the  new  financing 
period100,  in  particular  the  proposed  Rights  and  Values  programme  for  the  period  2021-
2027101.  

Actions: 

  Support new innovative projects to fight disinformation under various EU programmes, 
in  particular  by  civil  society  organisations  and  higher  education  institutions,  with 
journalists’ involvement 

 

Increase support and funding for and diversifying initiatives, including by civil society 
organisations,  to  promote  media  literacy  and  help  citizens  identify  disinformation, 
within the EU and beyond 

5  CONCLUSION 

In July 2019, President von der Leyen called for a new push for European democracy, with a 
greater  say  for  Europeans  and  for  Europe  altogether  to  strive  for  more  in  nurturing, 
protecting and strengthening our democracy. 

This  European  democracy  action  plan,  taken  together  with  the  new  European  rule  of  law 
mechanism,  the  new  Strategy  to  strengthen  the  application  of  the  Charter  of  Fundamental 
Rights102 as well as the package of measures taken to  promote and protect  equality  across 
the EU, will be a key driver for the new push for European democracy to face the challenges 
and reap the benefits of the digital age. The commitment to democracy is also embedded in 
the EU’s external action, and a central pillar of its work with accession and neighbourhood 
countries. 

100  Including under the proposals for Erasmus+, European Solidarity Corps and the Media programme. 
101  COM (2018) 383 final of 7.6.2018. 
102 COM(2020) 711. 

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The  gradual  delivery  of  the  set  of  measures  proposed  in  the  action  plan  will  ensure  that 
Europe  has  a  stronger  democratic  underpinning  to  take  up  the  challenges  of  the 
unprecedented economic, climate and health crises we face, in full respect for our common 
principles and values. The Commission will review the implementation of the action plan in 
2023,  a  year  ahead  of  the  elections  to  the  European  Parliament,  and  reflect  on  whether 
further steps are needed. 

The Commission looks forward to the further engagement of the European Parliament and 
the  Council  as  well  as  of  the  wide  circle  of  national  actors,  public  and  private,  beyond 
government authorities, who will be instrumental to ensure the resilience of our democracy.  

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