COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS European Commission Guidance on Strengthening the Code of Practice on Disinformation
Date: 2021-05-26
Institutions: Directorate-General for Communications Networks, Content and Technology, European Commission
Subjects: Internet, advertising, coronavirus disease, disinformation, dissemination of information, epidemic, freedom of expression, information, research, service

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 26.5.2021  COM(2021) 262 final  COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS European Commission Guidance on Strengthening the Code of Practice on Disinformation  
 
 
1 

INTRODUCTION  

The  COVID-19  crisis  has  starkly  illustrated  the  threats  and  challenges  disinformation 
poses  to  our  societies.  The  ‘infodemic’  –  the  rapid  spread  of  false,  inaccurate  or 
misleading  information  about  the  pandemic  –  has  posed  substantial  risks  to  personal 
health,  public  health  systems,  effective  crisis  management,  the  economy  and  social 
cohesion.  The pandemic has also elevated the role digital technology plays in our lives, 
making  it  increasingly  central  to  how  we  work,  learn,  socialise,  provide  for  material 
needs,  and  participate  in  the  civic  discourse.  It  has  raised  the  stakes  to  ensure  that  the 
online ecosystem is a safe space, and it has shown that, despite considerable efforts made 
to date, there is an urgent need to step-up efforts to fight disinformation1.  

From its inception2, the EU approach to countering disinformation has been grounded in 
the protection of freedom of expression and other rights and freedoms guaranteed under 
the  EU  Charter  of  Fundamental  Rights.  In  line  with  those  rights  and  freedoms,  rather 
than criminalising  or prohibiting disinformation  as such, the  EU strategy  aims  to  make 
the online environment and its actors more transparent and accountable, making content 
moderation  practices  more  transparent,  empowering  citizens  and  fostering  an  open 
democratic debate3. To this end, the EU has sought to mobilise all relevant stakeholders, 
including public authorities, businesses, media, academics and civil society.   

A  centrepiece  of  EU  efforts  has  been  the  self-regulatory  Code  of  Practice  on 
Disinformation4.  In  force  since  October  2018,  the  Code’s  signatories  now  comprise 
major  online  platforms  active  in  the  EU  as  well as,  inter  alia,  major  trade  associations 
representing the European advertising sector. The Commission considers the Code to be 
a  substantial,  first-of-its-kind  achievement.  It  has  provided  an  innovative  tool  for 
ensuring  greater  transparency  and  accountability  of  online  platforms,  as  well  as  a 
structured  framework  for  monitoring  and  improving  the  platforms’  policies  on 
disinformation.  

Nevertheless,  the  Commission’s  Assessment  of  the  Code  of  Practice  in  20205  has 
revealed significant shortcomings. These include inconsistent and incomplete application 
of  the  Code  across  platforms  and  Member  States,  limitations  intrinsic  to  the  self-
regulatory  nature  of  the  Code,  as  well  as  gaps  in  the  coverage  of  the  Code’s 
commitments.  The  assessment  also  highlighted  the  lack  of  an  appropriate  monitoring 
mechanism,  including  key  performance  indicators  (KPIs),  lack  of  commitments  on 
access  to  platforms’  data  for  research  on  disinformation  and  limited  participation  from 
stakeholders,  in  particular  from  the  advertising  sector.  Therefore,  the  Commission 
announced in the European Democracy Action Plan6 (EDAP) that it will issue guidance 
for strengthening the Code, as part of comprehensive actions to address disinformation in 

1  Joint  Communication  on  Tackling  COVID-19  Disinformation  –  Getting  the  facts  right  (JOIN  (2020) 8 
final). 
2  In  the  Action  Plan  against  Disinformation  (JOIN  (2018)  36  final),  the  European  Commission  and  the 
High Representative set out a comprehensive strategy to counter disinformation in the EU.    
3  While  online  platforms’  terms  and  conditions  may  cover  also  content  which  is  harmful  but  not  illegal, 
when  disinformation  constitutes  illegal  content  (e.g.  hate  speech  or  terrorist  content),  the  relevant 
legislative remedies apply). 
4 https://ec.europa.eu/digital-single-market/en/code-practice-disinformation  
5 SWD (2020) 180 final. 
6 COM (2020) 790 final.  

1 

 
 
                                                 
the online environment, and that it will present specific legislation on the transparency of 
political advertising.  

To step up the fight against disinformation, the Digital Services Act7 (DSA) proposed by 
the  Commission  sets  out  a  co-regulatory  framework  through  Codes  of  Conduct  for 
addressing  systemic  risks  linked  to  disinformation.  Furthermore,  it  introduces  wide-
ranging transparency measures around content moderation and advertising, and proposes 
binding and enforceable legal obligations for very large online platforms8 to assess and 
address  systemic  risks  for  fundamental  rights  or  presented  by  the  intentional 
manipulation of their service.  

The  Guidance  is  based  on  the  Commission’s  experience  to  date  in  monitoring  and 
evaluating  the  Code9  and  on  the  Commission’s  report  on  the  2019  elections10.  It  also 
contributes  to  the  Commission’s  response  to  the  December  2020  European  Council 
conclusions11.  To  collect  input  to  the  Guidance,  the  Commission  organised  multi-
stakeholder discussions12 as well as a workshop for Member States. 

This  Guidance  sets  out  the  Commission’s  views  on  how  platforms  and  other  relevant 
stakeholders should step up their measures to address gaps and shortcomings in the Code 
and  create  a  more  transparent,  safe  and  trustworthy  online  environment.  One  area,  in 
particular,  where  the  Code  has  failed  to  achieve  sufficient  progress  is  in  the 
demonetisation  of  disinformation,  where  online  advertisements  still  continue  to 
incentivise the dissemination of disinformation13. Online platforms and all other players 
of the online advertising ecosystem should thus take responsibility and work together to 
defund  disinformation.  Furthermore,  the  revised  Code  should  step  up  commitments  to 
limit  manipulative  behaviour,  strengthen  user  empowerment  tools,  increase  the 
transparency of political advertising, and further empower the research and fact-checking 
community.  The  Guidance  also  lays  out  the  cornerstones  for  an  improved,  robust 
framework for the monitoring of the strengthened Code. The strengthened Code should 
also  aim  to  achieve  a  broader  participation  with  new  signatories,  including  additional 
online platforms active in the EU as well as other relevant players. 

7  Proposal  for  a  Regulation  of  the  European  Parliament  and  the  Council  on  a  Single  Market  For  Digital 
Services (Digital Services Act) and amending Directive 2000/31/EC (COM (2020) 825 final). References 
to the DSA in this document are to be understood as to the text as proposed by the Commission. 
8  The  DSA  proposal  defines  very  large  platforms  in  Art.  25  as  online  platforms  which  provide  their 
services to a number of average monthly active recipients of the service in the Union corresponding to 10% 
of the Union’s population. 
9 Commission’s September 2020 Assessment (SWD (2020) 180 final) 
10  Report  on 
the  2019  elections 
https://ec.europa.eu/info/files/com_2020_252_en.pdf_en 
11 https://www.consilium.europa.eu/media/47296/1011-12-20-euco-conclusions-en.pdf  
12  A 
available  here:  https://digital-
strategy.ec.europa.eu/en/library/summary-multi-stakeholder-discussions-preparation-guidance-strengthen-
code-practice-disinformation  
13  Evidence  also  shows  that  revenues  from  online  advertisements  still  contribute  significantly  to  the 
monetisation of disinformation websites, including advertising from large brands unwittingly placed next 
report 
to 
and 
https://disinformationindex.org/2020/03/why-is-ad-tech-giving-millions-to-eu-disinformation-sites/ 
Avaaz report https://secure.avaaz.org/campaign/en/youtube_climate_misinformation/) 

the  European  Parliament 

the  discussions  with 

Disinformation 

disinformation 

summary  of 

(2020)  113 

stakeholder 

content 

Global 

(SWD 

Index 

final) 

(e.g. 

to 

is 

2 

 
 
                                                 
Strengthening the Code offers an early opportunity for stakeholders to design appropriate 
measures in view of the adoption of the proposed DSA. Notably, the Guidance also aims 
at evolving the existing Code of Practice towards a ‘Code of Conduct’ as foreseen in its 
Article  35.  Very  large  platforms14  in  particular,  will  benefit  from  participating  in  the 
strengthened  Code  in  anticipation  of  new  obligations  applicable  to  them  under  the 
proposed  DSA,  in  particular  with  regard  to  risk  assessment,  risk  mitigation,  user 
empowerment,  and  transparency  around  advertising.  Smaller  platforms  and  other 
stakeholders  will  also  benefit  from  subscribing  to  appropriate  commitments  under  the 
strengthened  Code  to  gain  from  its  best  practices  and  to  protect  themselves  against 
reputational risks presented by the misuse of their systems to spread disinformation. 

Without  prejudice  to  the  final  agreement  of  the  co-legislators  on  the  DSA  or  on  the 
Commission’s  legislative  initiative  on  the  transparency  of  political  advertising,  the 
strengthened Code of Practice can serve as a tool for online platforms to improve their 
policies  and  mitigate  risks  linked  to  disinformation  that  their  services  present  to 
democracy.  

The  strengthening  of  the  Code  is  not  only  a  provisional  step.  This  Guidance  calls  for 
developing the Code into a strong, stable, flexible instrument that makes online platforms 
more transparent, accountable and responsible by design.  

2  COVID-19 MONITORING – RESULTS AND LESSONS LEARNED 

In  addition  to  the  lessons  learned  through  the  evaluation  of  the  Code  of  Practice,  new 
insights have been gathered under the monitoring programme set up following the Joint 
Communication on Tackling COVID-19 disinformation15, during which online platform 
signatories to the Code have been reporting monthly on actions taken to combat COVID-
19 disinformation in the EU.  

The  monitoring  programme  has  not  only  provided  an  in-depth  overview  of  the  actions 
taken to counter disinformation around COVID-19 based on the Code’s commitments, it 
has also put the Code through a ‘stress test’.  

The  platforms’  reports  show  that  the  Code’s  commitments  have  been  implemented 
through  effective  actions  in  various  areas,  such  as  increased  visibility  of  authoritative 
sources  on  their  services;  development  and  deployment  of  new  tools  and  services  to 
facilitate  access  to  reliable  information;  actions  to  address  content  containing  false  or 
misleading  information  likely  to  cause  physical  harm  or  impair  the  effectiveness  of 
public health policies; expressly prohibiting advertising that exploits the crisis or spreads 
disinformation about COVID-19.  

Overall,  the  programme  has  demonstrated  that  the  Code  provides  an  agile,  structured 
framework that can be deployed and translated into decisive action by signatories to fight 
disinformation  in  crisis  situations  and  which  is  complementary  to  obligations  under 
applicable  regulatory  frameworks.  The  Code  also  provided  a  useful  structure  for 
monitoring these measures  in  an extraordinary situation,  dynamically shifting the focus 
as the crisis evolved (e.g. to focus on disinformation around COVID-19 vaccines).  

14 In the sense of Art. 25 of the DSA as proposed by the Commission. For the definition, see footnote 8.  
15 Joint Communication on Tackling COVID-19 Disinformation  – Getting the facts right (JOIN (2020) 8 
final).  

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At  the  same  time,  the  COVID-19  programme  highlighted  a  number  of  shortcomings  of 
the existing monitoring framework of the Code of Practice: 

  Quality of reporting. There are substantial variations in the consistency, quality and 
level of detail of the reporting. The lack of sufficiently granular data, particularly at 
Member  State  level,  meant  that  the  information  provided  often  did  not  reveal 
whether reported actions were implemented across all Member States or in all EU 
languages. Moreover, the lack of a common, agreed reporting template remains an 
obstacle for more efficient monitoring and cross-platform comparisons.  

  KPIs.  While  the  quality  and  the  granularity  of  the  reporting  improved  over  time, 
the data provided is still not always adequate and sufficiently detailed to measure 
the  extent  to  which  commitments  are  implemented  or  the  effect  of  the  actions 
taken.  
Independent  assessment.  The  COVID-19  monitoring  has  confirmed  the  need  for 
independent  verification of the signatories’ reports,  in  particular whether reported 
policies and actions  have been implemented at  Member State level  and  in  all EU 
languages,  and  whether  the  reporting  sufficiently  addresses  disinformation 
concerns at national level16.  

 

  Lack  of  sufficient  fact-checking  coverage.  During  the  COVID-19  ‘infodemic’ 
signatories  have  increased  fact-checking  activities  on  their  services  which  are 
becoming  available  also  to  users  of  private  messaging  apps.  However,  content 
labelled as false by independent fact-checkers tends to resurge across platforms due 
to the lack of a centralised fact-checks repository.  

  Continued  monetisation  of  disinformation  through  advertisement  placements. 
Despite actions to limit the monetisation of disinformation, relevant research shows 
that problems persist in this area17.  

3  HORIZONTAL ISSUES TO BE ADDRESSED 

3.1  Reinforced commitments to achieve the Code’s objectives 

The  commitments  of  the  current  Code  of  Practice  are  not  sufficiently  effective  in 
providing  a  comprehensive  response  to  the  disinformation  phenomena.  There  is  a  need 
for stronger and more specific commitments in all areas of the Code to address gaps and 
shortcomings, including new and emerging risks. To ensure that the Code stays a living 
instrument, signatories should set up a permanent mechanism for its regular adaptation.  

3.2  Expanded scope  

The ‘infodemic’ around the COVID-19 pandemic has demonstrated that misinformation18 
(false  or  misleading  information  spread  without  a  malicious  intent)  can  also  pose 

16 As  foreseen in the June 2020 Communication, the European Regulators Group for Audiovisual Media 
Services is assisting the Commission with the COVID-19 monitoring programme. 
17  GDI  research  in  January  and  February  2021  on  France,  Germany,  Italy  and  Spain  highlights  that  the 
majority of ad tech companies do not have specific COVID-19 disinformation content policies or that those 
policies  are  violated  and  continue  to  fund  news  sites  flagged  publicly  as  purveyors  of  disinformation: 
https://disinformationindex.org/2021/02/ad-funded-covid-19-conspiracy-sites-a-look-at-the-eu/. 
Avaaz 
research in August 2020 highlighted that content from the top 10 websites spreading health misinformation 
had almost four times as many estimated views on Facebook as equivalent content from the websites of 10 
leading health institutions: https://secure.avaaz.org/campaign/en/facebook_threat_health/. 

4 

 
 
 
                                                 
substantial public harm if it becomes viral. While the main target remains disinformation 
in  the  narrow  sense19,  in  the  strengthened  Code  signatories  should  commit  to  have  in 
place  appropriate  policies  and  take  proportionate  actions  to  mitigate  the  risks  posed  by 
misinformation,  when  there  is  a  significant  public  harm  dimension  and  with  proper 
safeguards  for  the  freedom  of  speech.  Users  need  to  be  empowered  to  contrast  this 
information  with  authoritative  sources  and  be  informed  where  the  information  they  are 
seeing  is  verifiably  false.  In  line  with  this,  depending  on  their  nature,  not  all 
commitments of the Code would apply to misinformation.  

The  present  Guidance  uses  –  for  the  ease  of  reference  –  the  overarching  term 
‘disinformation’  to  refer  to  the  different  phenomena  to  be  addressed,  while  clearly 
acknowledging  the  important  differences  between  them20.  Disinformation  in  this  sense 
includes  disinformation  in  the  narrow  sense,  misinformation,  as  well  as  information 
influence operations21 and foreign interference22 in the information space, including from 
foreign  actors,  where  information  manipulation  is  used  with  the  effect  of  causing 
significant public harm. 

3.3  Broadened participation  

The  current  Code’s  signatories  include  major  online  platforms  operating  in  the  EU. 
However,  wider  participation  from  both  established  and  emerging  platforms  could 
provide a more comprehensive and coordinated response to the spread of disinformation. 
Potential  new  signatories  may  include  providers  of  online  services  which  disseminate 
information  to  the  public,  such  as  smaller  social  media  or  search  services  (e.g.  players 
offering services at national or regional level or on a specialised/topical basis). Given the 
relevant  compliance  burdens,  including  reporting  obligations,  commitments  under  the 
strengthened Code should take into  account  the size of the signatories’ services. While 
very  large  online  platforms  will  need  to  take  robust  measures  to  address  the  relevant 
systemic risks under the proposed DSA, the measures applicable to smaller or emerging 
services should not impose a disproportionate burden on them.  

to  fuel  disinformation  and 
Private  messaging  services  can  also  be  misused 
misinformation,  as  observed  in  recent  electoral  campaigns  and  during  the  COVID-19 
pandemic23.  Such  service  providers  could  be  signatories  of  the  Code,  committing  to 
specific  measures  appropriate  for  this  type  of  services,  without  any  weakening  of  the 
encryption often used by this type of services, and with due regard to the protection of 
privacy and the right to private and family life including communications.  

18 EDAP defines misinformation as follows: ‘misinformation is false or misleading content shared without 
harmful intent though the effects can be still harmful, e.g. when people share false information with friends 
and family in good faith’. 
19  EDAP  defines  disinformation  as  follows:  ‘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’. 
20 Where relevant, the Guidance distinguishes between the different subcategories. 
21 As defined in EDAP: ‘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’. 
22  As  defined  in  EDAP:  ‘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 agents’. 
23  ‘Stop  the  virus  of  disinformation’,  United  Nations  Interregional  Crime  and  Justice  Research  Institute 
(UNICRI), http://www.unicri.it/sites/default/files/2020-11/SM%20misuse.pdf  

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In order to increase the Code’s impact on the demonetisation of disinformation, a broader 
participation  of  stakeholders  from  the  advertising  ecosystem  beyond  the  circle  of  the 
Code’s  current  signatories  (European  and  national  associations  from  the  advertising 
sector) is key. The Code would benefit in particular from more involvement of brands (in 
particular  those  with  substantial  online  advertisement  spending)  as  well  as  other 
participants  of  the  online  advertising  sector  (e.g.  ad  exchanges,  ad-tech  providers, 
communication  agencies)  and  other  players  providing  services  that  may  be  used  to 
monetise  disinformation  (e.g.  e-payment  services,  e-commerce  platforms,  crowd-
funding/donation systems)24.  

New signatories could also include other stakeholders that can have a significant impact 
through  their  tools,  instruments,  solutions  or  relevant  specific  expertise,  including  fact-
checkers,  organisations  providing  ratings  relating  to  disinformation  sites  or  assessing 
disinformation, as well as providers of technological solutions that can support the efforts 
to address disinformation. Such organisations can contribute considerably to the efficient 
implementation of the Code and its success. 

3.4  Tailored commitments  

To  facilitate  broader  participation,  the  strengthened  Code  should  include  tailored 
commitments that correspond to the diversity of services provided by signatories and the 
particular roles they play in the ecosystem.  

Signatories should sign up to the commitments that are relevant for their services. While 
participation in the Code and subscription to its commitments remains voluntary, in order 
to  ensure  the  Code’s  effectiveness  as  a  risk  mitigation  tool,  signatories  should  not,  in 
principle, opt out of commitments that are relevant for their services. Where signatories 
opt  not  to  subscribe to  a particular commitment relevant  for their services, they  should 
provide a public justification, in the spirit of recital 68 of the proposed DSA. Signatories 
that are providing tools, instruments or solutions to fight disinformation could subscribe 
to  appropriate  commitments  and  support  other  signatories  of  the  Code  with  their 
expertise. Any reporting requirements for such organisations should be adapted to their 
mission.  

3.5  European Digital Media Observatory  

To  provide  an  effective  contribution  to  addressing  the  issue  of  disinformation,  it  is 
crucial  to  have  the  support  of  a  multidisciplinary  community  including  fact-checkers, 
academic  researchers  and  other  relevant  stakeholders.  To  contribute  to  the  creation  of 
such  community  and  facilitate  its  work,  the  European  Digital  Media  Observatory 
(EDMO)25  was  established.  By  providing  support  to  independent  researchers  and  fact-
checkers, EDMO and its national hubs will increase their capacity to detect and analyse 
disinformation campaigns. EDMO can play an important role in achieving several of the 
Code’s  objectives.  It  is  thus  expected  that  signatories  of  the  Code  will  cooperate  with 
EDMO as appropriate.  

24  ‘How  COVID-19  conspiracists  and  extremists  use  crowdfunding  platforms  to  fund  their  activities’, 
EUDisinfoLab https://www.disinfo.eu/publications/how-covid-19-conspiracists-and-extremists-use-
crowdfunding-platforms-to-fund-their-activities/  
25 https://edmo.eu/  

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3.6  Rapid Alert System 

As  outlined  in  the  2018  Action  Plan  against  Disinformation26,  online  platforms  should 
cooperate with  the EU Rapid  Alert System,  which connects  all EU Member States and 
relevant  EU  Institutions  to  enable  joint  responses  to  disinformation  by  information 
sharing  and  providing  timely  alerts  on  disinformation  campaigns.  Building  on  this,  the 
strengthened Code should explore opportunities for reinforcing such cooperation, notably 
by  facilitating  an  informal  exchange  between  the  signatories  to  present  their  work  and 
findings,  as  well  as  to  ensure  close,  streamlined  and  coherent  links  on  a  national  level 
between all the Member States and the signatories as appropriate. This should also take 
into account the cooperation with EDMO, as mentioned above. 

4  SCRUTINY OF AD PLACEMENTS  

As  explained,  decisive  action  to  demonetise  the  purveyors  of  disinformation  is  key  for 
the  Code’s  success.  The  strengthened  Code’s  commitments  should  therefore  take  more 
granular,  tailored  action  to  address  disinformation  risks  linked  to  the  distribution  of 
online  advertising,  keeping  in  mind  upcoming  regulatory  requirements  in  the  proposed 
DSA applicable to all online advertising, including political and issue-based advertising 
and, to the extent applicable, the announced initiative on political advertising.  

4.1  Demonetising disinformation  

The  Code  should  strengthen  commitments  aimed  at  defunding  the  dissemination  of 
disinformation  on  signatories’  own  services  or  on  third-party  websites27.  To  improve 
transparency  and  accountability  around  ad  placements,  signatories  participating  in  ad 
placements, including ad-tech companies28, should identify the criteria they use to place 
ads, and adopt measures that enable verification of the landing/destination place of ads, 
with the aim of avoiding the placement of advertising next to disinformation content or 
in  places  that  are  known  for  repeated  publication  of  disinformation.  Platforms  should 
commit, in particular, to tighten eligibility requirements and content review processes for 
content  monetisation  and  ad  revenue  share  programmes  on  their  services  to  bar 
participation  by  actors  that  systematically  post  content  debunked  as  disinformation29. 
Furthermore, platforms should  also  commit to  strengthen relevant policies and exercise 
due diligence with a view to excluding participation in the ad networks or ad exchanges 
of websites that persistently purvey disinformation content. 

Commitments in this area should also build on and improve the availability and uptake of 
brand safety tools, which should integrate information  and analysis from  fact-checkers, 
researchers and other relevant stakeholders providing information e.g. on the sources of 
disinformation  campaigns.  Supported  by  such  information  and  tools,  brand  owners  and 
other  advertisers  should  commit  to  do  their  utmost  to  avoid  the  placement  of  their 

26 JOIN (2018) 36 final. 
27  Evidence  also  shows  that  revenues  from  online  advertisements  still  contribute  significantly  to  the 
monetisation of disinformation websites, including advertising from large brands unwittingly placed next 
to  disinformation  content.  For  example,  the  Global  Disinformation  Index  estimates  that  around  $  76 
million  dollars  per  year 
targeting  Europe: 
flow 
https://disinformationindex.org/2020/03/why-is-ad-tech-giving-millions-to-eu-disinformation-sites/. 
28 A limited number of ad-tech companies has already adopted such policies. 
29  See  for  instance  Avaaz’s  2020  Report,  ’Why  is  YouTube  Broadcasting  Climate  Misinformation  to 
Millions?’: https://secure.avaaz.org/campaign/en/youtube_climate_misinformation/. 

to  disinformation  sites 

revenues 

in  ad 

7 

 
 
                                                 
advertising  next  to  disinformation  content  or  in  places  that  repeatedly  publish 
disinformation.  

4.2 

Improving cooperation between relevant players  

Achieving tangible results requires the close cooperation of different players within the 
advertising  ecosystem. To this end, as set  out  in Section 3.3,  a broader participation of 
stakeholders  from  the  advertising  ecosystem  is  key.  The  strengthened  Code  should 
provide a framework for such widened participation strengthening the cooperation of all 
relevant actors and further facilitating ongoing cross-industry initiatives in this area30.  

As  part  of  the  strengthened  Code,  all  actors  involved  in  buying,  selling  and  placing 
digital advertising should commit to exchange best practices and strengthen cooperation. 
Such  cooperation  should  facilitate  the  integration  and  flow  of  information  across  the 
whole  advertising  value  chain,  in  particular  information  relevant  for  identifying 
purveyors of disinformation in full respect of all relevant data protection rules.   

Cross-platform  cooperation  could  also  include  the  exchange  of  information  on 
disinformation  ads  refused  by  one  platform  to  prevent  their  appearance  on  other 
platforms  –  for  example,  by  the  creation  of  a  common  repository  of  rejected  ads  –  for 
awareness of other platforms whose services may also be affected.  

Actions  to  defund  disinformation  should  be  broadened  by  the  participation  of  players 
active  in  the  online  monetisation  value  chain,  such  as  online  e-payment  services,  e-
commerce platforms and relevant crowd-funding/donation systems.  

4.3  Commitments to address advertising containing disinformation 

Under  the  strengthened  Code,  signatories  should  commit  to  design  appropriate  and 
tailored  advertising  policies  that  address  the  misuse  of  their  advertising  systems  for 
propagating  disinformation31.  They  should  enforce  these  policies  consistently  and 
effectively. To this  end,  signatories should cooperate with  fact-checkers to identify  ads 
that  contain  disinformation  which  has  been  fact-checked  and  debunked.  To  ensure 
consistent  implementation,  signatories  should  commit  to  adapt  their  current  ad 
verification  and  review  systems  to  ensure  that  ads  placed  through  or  on  their  services 
comply  with  their  advertising  policies  in  respect  of  disinformation.  Signatories  should 
also  commit  to  explain  clearly  to  advertisers  which  advertising  policies  have  been 
violated when they reject or remove disinformation ads or disable advertising accounts32.  

30  The  Global  Alliance  for  Responsible  Media,  launched  in  June  2019  under  the  auspices  of  the  World 
Federation of Advertisers (WFA), includes platform and advertising sector signatories of the Code, as well 
other  notable  stakeholders  across  the  advertising  ecosystem.  It  is  developing  a  set  of  industry-wide 
common definitions and standards for how  harmful content is categorised across platforms, approved by 
advertisers,  and  implemented  by  platforms  in  their  advertising  products  and  brand  safety  tools.  Notably, 
the  Alliance is pursuing a  separate  category  for disinformation and  misinformation to  be included in  the 
set.  See  WFA  ‘Interim  Report  on  Activities  related  to  the  EU  Code  of  Practice  on  Disinformation’, 
September 2020, p. 2: https://ec.europa.eu/newsroom/dae/document.cfm?doc_id=69683 
31  Evidence  shows  the  persistence  of  online  ads  containing  disinformation  that  fact-checkers  have 
identified  and  debunked.  See 
‘Facebook  Approved  Ads  With  Coronavirus  Misinformation’: 
https://www.consumerreports.org/social-media/facebook-approved-ads-with-coronavirus-misinformation/. 
32 As the Commission has noted, platforms’ policies pursue a range of objectives, some of which are not 
specifically  tailored  to  tackle  disinformation  –  e.g.  unsupported  commercial  claims,  deceptive  business 
practices. See SWD (2020) 180 final.  

8 

 
 
                                                 
5  POLITICAL ADVERTISING AND ISSUE-BASED ADVERTISING  

‘Political advertising’ and ‘issues based advertising’33 play an important role in shaping 
political campaigns and public debates around key societal issues. Such online paid-for 
content can have a decisive role in forming the public opinion and influence the outcome 
of elections. The organisation of elections in the EU is largely regulated at Member State 
level,  with  various  relevant  rules  affecting  political  advertising  including  their 
transparency.  In  EDAP,  the  Commission  announced  legislation  to  strengthen  the 
transparency  of  political  advertising.  To  ensure  the  adequate  level  of  transparency  and 
accountability  in  this  area,  the  Code’s  commitments  need  further  strengthening,  in 
support of the wider legal framework.  

The  revision  of  the  Code  in  this  area  will  need  to  take  into  account  the  Commission’s 
upcoming legislative proposal on the transparency of sponsored political content and the 
relevant  provisions  of  the  proposed  DSA.  A  strengthened  Code  will  serve  as  an 
important vehicle to deliver tangible progress to support the existing legal framework, as 
well as to pave the way towards strengthened legislation and through the new legislative 
framework  once  it  is  in  place  and  to  devise  industry-led  solutions  to  support  its 
implementation and achieve continued progress in this area.  

For  a  consistent  and  effective  application  of  the  commitments,  a  shared  understanding 
among signatories of ‘political advertising’ and ‘issue-based advertising’ is needed which 
adequately  takes  into  account  the  existing  applicable  national  legal  frameworks.  The 
signatories  should  make  sure  that  they  comply  with  applicable  laws  and  align  their 
practices  with  the  upcoming  legislation  on  the  transparency  of  sponsored  political 
content. 

5.1  Efficient labelling of political and issue based ads 

The  Code  should  include  strengthened  commitments  ensuring  the  transparency  and 
public disclosure of both  political  and issue-based ads, taking into account  the relevant 
provisions in the proposed DSA34, the upcoming legislative initiative on transparency of 
political advertising, and without prejudice to existing regulatory frameworks. These ads 
should  be  clearly  and  effectively  labelled  and  distinguishable  as  paid-for  content,  and 
users should be able to understand that the content displayed contains advertising related 
to  political  or  societal  issues.  The  strengthened  Code  could  include  a  set  of  common 
criteria  and  examples  on  the  marking  and  labelling  of  political  and  issue-based  ads. 
Where  relevant,  signatories  should 
the 
effectiveness  of  labels  in  informing  users35.  The  Code  should  include  commitments 
aiming at ensuring that labels remain in place when users share political or issue-based 
ads in an organic way36, so that they continue to be clearly identified as ads.  

integrate  relevant  research 

improve 

to 

33  While  there  is  currently  no  common  definition  of  issue-based  ads  in  the  Code,  there  seems  to  be 
agreement  that  issue-based  ads  are  ads  that  include  sponsored  content  on  societal  issues  or  related  to  a 
debate of general interest that might have an impact on public discourse. Examples of such issues include 
climate change, environmental issues, immigration or COVID-19. 
34 Article 24 in particular. 
35  Dobber  et  al.,‘Effectiveness  of  online  political  ad  disclosure  labels:  empirical  findings’,  March  2021: 
https://www.uva-icds.net/wp-content/uploads/2021/03/Summary-transparency-discloures-
experiment_update.pdf. 
36 Organic content is free content that users share with each other without paying for it. This also includes 
situations where users share with each other sponsored content which then becomes organic content.  

9 

 
 
                                                 
5.2  Verification and transparency commitments for political and issue-based ads 

Signatories who display political and issues-based ads should ensure that the identity of 
the  advertiser  is  visible  to  users,  including  a  specific  commitment  setting  out 
transparency obligations in line with the requirements in the proposed DSA37.  

Signatories  should  also  make  reasonable  efforts  to  ensure,  through  effective  identity 
verification  and  authorisation  systems,  that  all  the  necessary  conditions  are  met  before 
allowing the placement of these types of ads.  

5.3  Transparency in messaging platforms 

The revised Code of Practice should include new, tailored commitments addressing the 
use of messaging platforms for the dissemination of political and issue-based ads, in full 
respect  of  the  General  Data  Protection  Regulation  (GDPR)  and  EU  requirements  for 
privacy  in  electronic  communications  services.  The  abovementioned  requirement  that 
when  sponsored  political  content  is  shared  between  users,  it  should  continue  to  be 
labelled  as  paid-for  content,  should  also  apply  to  the  extent  possible  to  sponsored 
political  content  shared  over  messaging  platforms.  To  this  end,  signatories  should 
develop  solutions  which  are  compatible  with  the  encryption  technology  often  used  by 
messaging platforms, without any weakening of the encryption. 

5.4  Targeting of political ads 

Micro-targeting  of  political  advertising  may  raise  various  concerns.  It  raises  issues  of 
compliance  with  data  protection  rules,  as  micro-targeting  is  based  on  personal 
information and sometimes includes sophisticated psychological profiling techniques38. It 
can affect the right of voters to receive information, since micro-targeting allows political 
advertisers to send tailored messages to targeted audiences, while other audiences may be 
deprived of this information. Micro-targeting makes it difficult to fact-check or scrutinise 
such ads, and for individuals to assert their rights, including as regards data protection. 
This in turn may increase the risk of political polarisation39.  

The  strengthened  Code  should  contribute  to  limit  or  avoid  the  risks  associated  with 
micro-targeting  of  individuals  with  political  and/or  issues-based  advertising.  In  this 
regard,  full  compliance  with  the  GDPR  and  other  relevant  laws  should  be  ensured,  in 
particular  acquiring  valid  consent  where  required40.  Access  to  information  should  be 
facilitated  to  enable  the  competent  authorities  to  perform  their  monitoring  and 
enforcement function. 

37 DSA proposal, Article 30.  
38  Specific  transparency  obligations  are  included  in  the  DSA  proposal  as  well  as  in  the  proposal  for  the 
Digital Markets Act. 

the 

consequences 

for  Germany’,  Big  Data  &  Society,  November 

39 See, for instance, Papakyriakopoulos et. al, ‘Social media and microtargeting: Political data processing 
and 
doi 
10.1177/2053951718811844, or Lewandowsky et al., ‘Understanding the influence of online technologies 
on political behaviour and decision-making’, EUR 30422 EN, Publications Office of the European Union, 
Luxembourg. 
40  For  more  guidance,  see  the  European  Data  Protection  Board  Guidelines  05/2020  on  consent  under 
Regulation 2016/679 and Guidelines 08/2020 on the targeting of social  media users (providing examples 
on when consent is required for targeted advertising). 

2018, 

10 

 
 
                                                 
Signatories  should  commit  to  ensure  that  citizens  are  clearly  informed  when  they  are 
being micro-targeted and be given meaningful information on the criteria and data used 
for this purpose. They should implement strong related transparency measures, including 
dedicated  searchable  ad  libraries  with  all  micro-targeted  ads  served  to  specific  user 
groups41, accompanied by information on targeting and delivery criteria.  

5.5 

Improved ad repositories and minimum functionalities for the application 
programming interfaces (APIs)  

The  strengthened  Code  should  ensure  that  signatory  platforms  commit  to  improve  the 
completeness and quality of the information in their repositories of political ads, so that 
these effectively contain all sponsored political content served. These repositories should 
provide current, regularly updated information on the volume and budget of political ads 
served  by  political  advertisers  in  the  Member  States,  the  number  of  times  each  ad  has 
been  displayed  online,  and  the  targeting  criteria  used  by  the  advertiser,  taking  into 
account  the  relevant  provisions  in  the  proposed  DSA  and  the  upcoming  legislative 
proposal on political advertising42.  

Some  platforms  have  developed  application  programming  interfaces  (APIs)  or  other 
interfaces  enabling  users  and  researchers  to  perform  customised  searches  within  their 
political ad repositories. However, the functionalities of these APIs are very limited. The 
strengthened  Code  should  ensure  that  APIs  for  platforms’  political  ads  repositories 
include a set of minimum functionalities, as well as a set of minimum search criteria that 
enable users and researchers to perform customised searches to retrieve real-time data in 
standard  formats  and  allow  for  easier  cross-platform  comparison,  research  and 
monitoring.  If  repositories  for  issue-based  ads  are  established,  they  should  have 
comparable API functionalities and search capabilities. Commitments should also ensure 
wide  access  to  APIs  and  that  functionalities  of  the  APIs  are  regularly  updated  to  meet 
researchers’ needs.  

6 

INTEGRITY OF SERVICES  

The  strengthened  Code  should  provide  for  comprehensive  coverage  of  current  and 
emerging forms of manipulative behaviour used to spread disinformation. It should take 
account  of  the  evolving  nature  of  and  the  broader  risks  associated  with  the  spread  of 
disinformation, for example the fact that disinformation campaigns can be part of hybrid 
threats  to  security,  in  particular  in  combination  with  cyberattacks43.  It  should  include 
tailored  commitments 
transparency  and 
accountability  regarding  actions  that  signatories  take  to  limit  manipulative  behaviour 
which,  according  to  their  relevant  terms  of  service,  are  not  permitted  on  signatories’ 
services,  also  in  view  of  the  upcoming  regulatory  requirements  set  out  in  the  proposed 
DSA44.  

to  address  vulnerabilities  and  ensure 

41 For instance, ad libraries, if equipped with the necessary  data, can be used to verify online equal time 
exposure to political messages. 
42 See DSA proposal, Article 30. 
43 Joint Communication on Increasing resilience and bolstering capabilities to address hybrid threats (JOIN 
(2018) 16 final) 
44  Article  26(1)  point  c  of  the  DSA  proposal  identifies  the  ‘intentional  manipulation’  of  services  as  a 
systemic risk, against which very large platforms must take risk mitigation measures.  

11 

 
 
                                                 
6.1  Common understanding of impermissible manipulative behaviour 

To  ensure  a  consistent  approach,  the  strengthened  Code  should  ensure  that  signatories 
agree on a cross-service understanding of manipulative behaviour not permitted on their 
services, including ‘inauthentic behaviour’, without prejudice to existing EU and national 
laws.  That  understanding  should  be  wide  enough  to  cover  the  full  range  of  behaviours 
through  which  malicious  actors  may  attempt  to  manipulate  services.  To  this  end, 
signatories should draw up a comprehensive list of manipulative tactics, techniques and 
procedures  (TTPs)  that  constitute  impermissible  inauthentic  behaviour  across  their 
services. The techniques identified should be sufficiently defined to enable comparisons 
of  the  prevalence  of  impermissible  behaviours  across  platforms,  as  well  as  the 
effectiveness  of  actions  taken  to  counter  them.  The  common  understanding  should 
provide  a  shared  vocabulary  for  signatories,  regulators,  civil  society  and  other 
stakeholders to discuss problems  of online disinformation and manipulation both in the 
context of the Code of Practice and in other fora, such as the EU Rapid Alert System and 
Elections  Cooperation  Network,  and  in  preparation  of  the  application  of  the  proposed 
DSA. This work should take into account the rapidly developing situation regarding the 
TTPs and reflect these possible changes when developing terminology and definitions. 

6.2  Strengthened commitments to limit impermissible manipulative behaviour 

The  strengthened  Code  should  set  out  new  commitments  in  the  area  of  impermissible 
manipulative behaviour, covering the full range of manipulative techniques and requiring 
effective  responses  to  counter  them.  The  commitments  should  require  signatories  to 
address  evolving  manipulative  techniques,  such  as  hack-and-leak  operations,  account 
takeovers, the creation of inauthentic groups, impersonation, deepfakes, the purchase of 
fake  engagements  or  the  opaque  involvement  of  influencers.  Furthermore,  the 
commitments should not only require signatories to publish relevant policies, but should 
also  lay down baseline elements,  objectives,  and benchmarks for measures deployed to 
counter impermissible manipulative behaviours. The strengthened Code should take into 
consideration  the  transparency  obligations  for  AI  systems  that  generate  or  manipulate 
content and the list of manipulative practices prohibited under the proposal for Artificial 
Intelligence Act45. 

6.3  Adjusting commitments, cooperation and transparency 

To ensure its continuing relevance and adequacy, the strengthened Code should establish 
a  mechanism  through  which  its  commitments  can  be  adjusted  over  time  based  on  the 
latest evidence on the conducts and TTPs employed by malicious actors. 

Signatories should commit to set up channels of exchange between their respective trust, 
cybersecurity  and  safety  teams.  These  channels  of  exchange  should  facilitate  the 
proactive  sharing  of  information  about  influence  operations  and  foreign  interference  in 
information  space  on  the  signatories’  services  to  prevent  the  resurgence  of  such 
campaigns  on  other  platforms.  Results  and  lessons  learned  should  be  included  in  the 

45 COM (2021) 206 final. 

12 

 
 
                                                 
signatories’  yearly  monitoring  reports,  discussed  in  the  permanent  task-force46,  and  be 
made available on a regular basis in common data formats47.  

Commitments shall ensure that all policies and measures are clearly communicated to the 
users, including via the transparency centre48. Signatories should also commit to make all 
actions  against  impermissible  manipulative  behaviour  subject  to  an  internal  complaint 
handling system, taking into consideration the relevant provisions in the proposed DSA49.  

7  EMPOWERING USERS  

Empowering users is key to limiting the impact of disinformation. A better understanding 
of  the  functioning  of  online  services,  as  well  as  tools  that  foster  more  responsible 
behaviour online or that enable users to detect and report false and/or misleading content, 
can dramatically limit the spread of disinformation. The Code’s commitments in this area 
should  be  widened  to  cover  a  broad  range  of  services,  including  for  example  tailored 
commitments  for  messaging  services.  They  should  also  include  mechanisms  to  appeal 
against  actions  taken  by  signatories  as  follow-up  to  users’  reports.  Signatories  should 
also specifically consider the situation of children who can be particularly vulnerable to 
disinformation. 

7.1  Commitment to measures enhancing media literacy 

Several signatories have made efforts in the area of media literacy providing users with 
relevant tools. Under the strengthened Code, signatories should commit to continue these 
efforts  and  commit  in  particular  to  a  stronger  involvement  of  the  media  literacy 
community in the design and implementation of tools and assessment of media literacy 
campaigns  on  their  services,  including  to  protect  children.  These  efforts  could  also  be 
aligned  with  the  Commission’s  initiatives  in  the  area  of  media  literacy50,  including  the 
new Digital Education Action Plan (2021-2027)51, to exploit relevant synergies. To this 
end, the Commission’s Media Literacy Expert Group52 and EDMO can provide support to 
establish a permanent framework for discussion.  

7.2  Commitment to ‘safe design’ 

The design and architecture of online services have a significant impact on the behaviour 
of users53. Signatories should therefore commit to assess the risks their systems pose and 
design  the  architecture  of  their  services  in  a  way  that  it  minimises  risks  linked54  to  the 

46 Regarding the Permanent Task Force, see Section 9.2.3 further below. 
47 This should also take into account the AMITT (Adversarial Misinformation and Influence Tactics and 
Techniques) Framework: https://cogsec-collab.org/   
48 Regarding the Transparency Centre, see Section 9.2.2 further below. 
49  Notably  Article  17,  which  already  applies  to  decisions  incompatible  with  their  terms  and  conditions, 
including  decisions  to  remove  or  disable  access  to  content,  do  suspend  or  terminate  the  provision  of  the 
service in whole or in part to the recipient or decisions to suspend or terminate the recipient’s account. 
50 See in particular the actions set out in the European Democracy Action Plan, (COM (2020) 790 final) 
and the Media and Audiovisual Action Plan (COM (2020) 784 final).  
51 The Digital Education Action Plan (COM (2020)624 final) puts forward a proposal to develop guidelines 
for  teachers  and  educators  in  view  of  tackling  disinformation  and  promoting  digital  literacy  through 
education and training.  
52 https://digital-strategy.ec.europa.eu/en/policies/media-literacy  
53 See e.g. Lewandowsky et al., ‘Understanding the influence of online technologies on political behaviour 
and decision-making’, EUR 30422 EN, Publications Office of the European Union, Luxembourg, 2020. 
54 See DSA proposal, Article 26(1) point c on related risk assessment. 

13 

 
 
                                                 
spread  and  amplification  of  disinformation55.  This  could  also  include  pre-testing  of  the 
systems’  architecture.  Signatories  should  also  invest  in  research  and  develop  product 
features and designs that enhance users’ critical thinking as well as the responsible and 
safe use of their services.  

Online  platforms  could  also  work  together  with  providers  of  technological  solutions  to 
integrate in their services solutions which allow to check authenticity or accuracy or to 
identify the provenance or source of digital content56.  

The  providers  of  AI-enabled  online  systems  also  should  take  into  consideration  the 
relevant provisions in the proposed Artificial Intelligence Act. 

7.3  Accountability of recommender systems 

By determining the order in which information is presented, recommender systems have 
a significant impact on what information is actually accessed by users. It is of paramount 
importance  that  signatories  under  the  strengthened  Code  commit  to  make  their 
recommender  systems  transparent  regarding  the  criteria  used  for  prioritising  or  de-
prioritising  information,  with  the  option  for  users  to  customise  the  ranking  algorithms. 
All  this  should  be  done  with  due  regard  to  the  principle  of  media  freedom  taking  into 
account the requirements in the relevant provisions of the DSA proposal57.  

Commitments  should  also  include  concrete  measures  to  mitigate  risks  of  recommender 
systems  fuelling  the  viral  spread  of  disinformation,  such  as  the  exclusion  from  the 
recommended content of false and/or misleading information where it has been debunked 
by  independent  fact-checkers  and  of  webpages,  and  actors  that  persistently  spread 
disinformation.  

7.4  Visibility of reliable information of public interest  

The COVID-19 pandemic has underlined the importance, in particular in times of crisis, 
of promoting information of public interest that is reliable, such as information provided 
by  health  authorities  related  to  measures  preventing  the  disease  or  to  the  safety  of 
vaccines58.  Signatories  implemented  various  solutions  to  provide  users  with  such 
information  and  make  it  visible  and  easy  to  access.  Building  on  this  experience, 
signatories  to  the  strengthened  Code  should  commit  to  further  develop  and  apply  such 

information  panels:  https://support.google.com/youtube/answer/9229632?hl=en; 
fact-checker: 
notice 

55 Simple technical interventions (for example, pop-up messages asking users if they really wish to share 
links that they have not viewed) can prompt users to scrutinise the content before they disseminate it and 
thus help limit the spread of false and/or misleading information by users acting in good faith. Examples: 
‘Check  it  out  before  you  Tweet  it’  prompt  implemented  by  Twitter:  https://help.twitter.com/en/using-
twitter/how-to-retweet;  
YouTube  fact-check 
Facebook 
pop-up 
https://www.facebook.com/journalismproject/programs/third-party-fact-checking/faqs; 
TikTok  ‘Know  your  Facts 
vaccine-misinformation. 
56  In  Section  3.3,  the  Guidance  invites  stakeholders  that  can  make  a  contribution  through  their  tools, 
instruments or solutions contributing to the fight against disinformation, to become new signatories of the 
Code. 
57 Notably, Articles 26, 27 and 29. 
58 COVID-19 monitoring reports provide data regarding views or click-through rates of information panels 
and  banners  providing  such  information:  https://digital-strategy.ec.europa.eu/en/library/reports-march-
actions-fighting-covid-19-disinformation-monitoring-programme  

tool’:  https://newsroom.tiktok.com/en-gb/taking-action-against-covid-19-

debunked 

content 

sharing 

before 

by 

a 

14 

 
 
                                                 
specific  tools  (e.g.  information  panels,  banners,  pop-ups,  maps  and  prompts)  that 
prioritise  and  lead  users  to  authoritative  sources  on  topics  of  particular  public  and 
societal interest or in crisis situations.  

To deepen the existing Code’s commitment59 on the prioritisation of relevant, authentic 
and  authoritative  content,  signatories  should  also  commit  to  publishing  information 
outlining  the  methodology  their  recommender  systems  employ  in  this  regard.  This 
information should be included in the transparency centre. The Code’s signatories should 
consider  ensuring  that  this  information  can  be  verified  by  third  parties  or  through  an 
independent  audit,  taking  into  consideration  also  the  relevant  provisions  in  the  DSA 
proposal. 

7.5  Warnings issued to users that interact or have interacted with false or 

misleading content 

The  debunking  of  false  and/or  misleading  information  is  crucial  to  curbing  the 
disinformation  phenomena60.  Several  signatories  have  established  cooperation  with 
independent  fact-checkers  and/or  have  created  in-house  moderation  teams  to  provide 
labels  for  false  or  misleading  content.  However,  the  Code  currently  does  not  include 
relevant  commitments.  Accordingly  –  complementing  new  commitments  to  ensure  the 
consistent  application  of  fact-checking,  as  discussed  below  in  Section  8.3  –  signatories 
should  commit  to  provide,  for  all  EU  languages  in  which  their  service  is  provided, 
systems  for  the  regular  and  consistent  labelling  of  content  identified  as  false  or 
misleading  and  for  issuing  targeted  warnings  to  users  that  have  interacted  with  such 
content.  Signatories  should  commit  to  inform  users  why  particular  content  or  accounts 
have been labelled, demoted or otherwise affected by measures taken, as well as the basis 
for such action. Signatories should commit to design their labelling and warning systems 
in accordance with up-to-date scientific evidence on how to maximise the impact of such 
interventions, ensuring in particular that they are designed to capture users’ attention61. 

7.6  Functionality to flag harmful false information 

Although  some  signatories  already  provide  a  dedicated  functionality  for  users  to  flag 
false and/or misleading information, this feature is not yet available on all services. The 
strengthened Code should contain a dedicated commitment requiring relevant signatories 
to  offer  user-friendly,  effective  procedures  on  their  services,  enabling  users  to  flag 
disinformation  with  the potential  to  cause  public  or  individual  harm.  This  functionality 
should  also  support  labelling  systems  and  mechanisms  to  help  the  identification  of 
resurging  false  information  content  already  labelled  as  false  in  other  languages  or  on 
other services, with full respect for the freedom of expression. The commitment should 
specify  that  the  functionality  needs  to  be  duly  protected  from  abuse  (i.e.  the  tactic  of 
‘mass-flagging’ to silence other voices) and available in all EU Member State languages 
in  which  their  services  are  provided.  Actions  taken  by  signatories  on  flagged  content 
should respect  the freedom  of expression and not  be disproportionate. Measures in  this 
area could include applying a transparent fact-checking procedure to the flagged content 
with  subsequent  follow-up  actions,  such  as  labelling  the  content  where  relevant. 
Signatories  should  commit  to  provide  users  with  follow-up  information  about  reported 

59 See commitment 8 of the Code of Practice on Disinformation. 
60 The Debunking Handbook 2020: https://sks.to/db2020.  
61 Optimisations can for instance relate to the visual design, the point in time or the graphical presentation 
of the intervention. 

15 

 
 
                                                 
content,  such  as  whether  the  content  was  reviewed  and,  if  so,  the  results  of  the 
assessment  and  any  action  taken  with  respect  to  the  content.  Users  whose  content  or 
accounts have been subject to such measures should likewise be informed to understand 
the  reasons  behind  the  actions  taken  and  have  access  to  an  appropriate  and  transparent 
mechanism to appeal and seek redress against the measures applied.  

7.7  Availability of indicators for informed online navigation 

It  is  not  an  aim  of  the  strengthened  Code  to  evaluate  the  veracity  of  editorial  content. 
However,  given  the  abundance  of  information  available  online,  users  face  challenges 
regarding  which  information  sources  to  consult  and  trust.  Indicators  of  trustworthiness, 
focused  on  the  integrity  of  the  source,  developed  by  independent  third  parties,  in 
collaboration  with  the  news  media,  including  associations  of  journalists  and  media 
freedom  organisations,  as  well  as  fact-checkers,  can  support  users  in  making  informed 
choices62.  

Signatories  could  facilitate access  to  such indicators providing users with the choice to 
use  them  on  their  services.  In  this  case,  the  strengthened  Code  should  ensure  that 
signatories  provide  transparency  regarding  such  third-party  indicators,  including  about 
their methodology. 

The  implementation  of  such  trustworthiness  indicators  should  be  fully  in  line  with  the 
principles of media freedom and pluralism. To this end, it should be left for the users to 
decide if they want to use such tools63. 

7.8  Measures to curb disinformation on messaging apps 

In addition to recent initiatives developed in cooperation with fact-checkers64, signatories 
that provide private messaging applications should test and implement technical features 
helping  users  to  identify  disinformation  disseminated  through  such  services.  Such 
solutions  should  be  compatible  with  the  nature  of  these  services  and  in  particular  the 
right to private communications, without any weakening of the encryption. Such features 
could, for example, help users to verify whether particular content they receive has been 
fact-checked  as  false.  This  could  be  achieved  e.g.  through  solutions  that  make  visible 
fact-checking  labels  when  content  from  social  media  is  disseminated  over  a  messaging 
app.  Signatories  could  also  consider  solutions  that  enable  users  to  check  content  they 
received over a messaging application against a repository of fact-checks.  

8  EMPOWERING THE RESEARCH AND FACT-CHECKING COMMUNITY  

In view of their key contribution to an effective strategy for tackling disinformation, the 
strengthened Code should set out a framework for robust access to platform data by the 
research and fact-checking community and adequate support for their activities.  

62  Examples  of  such  indicators  can  be  the  Global  Disinformation  Index  (GDI),  the  Journalism  Trust 
Initiative (JTI) or the Trust Project, as well as the service NewsGuard. 
63 Tools for assessing the trustworthiness of information sources, such as so-called trust marks, should be 
made available to users to consult if they so wish. Users could also be given the option of having signals 
relating to the trustworthiness of media sources fed into the automated systems that select and rank content 
appearing in their user feeds. 
64  Fact-checking  organisations,  supported  by  some  providers  of  messaging  applications,  give  users  of 
messenger  apps  the  possibility  to  have  messages  they  received  via  such  private  channels  fact-checked: 
https://faq.whatsapp.com/general/ifcn-fact-checking-organizations-on-whatsapp/?lang=en  

16 

 
 
                                                 
8.1  Access to signatories’ data for research on disinformation  

the  proper 
By  offering  evidence-based  analysis,  researchers  are  essential 
understanding of the evolution of the risks linked to disinformation65 and can contribute 
to  the  development  of  risk  mitigation  mechanisms.  This  work  critically  depends  on 
access to platform data. The proposed DSA provides a regulatory mechanism for vetted 
researchers  to  have  access  to  data  for  research  on  the  risks  stemming  from  platforms’ 
services66. The strengthened Code should create a framework that, already in the interim 
before the DSA’s adoption, allows researchers the necessary access to platform data and 
also facilitates in the long term the development of a specific framework for data access 
tailored for conducting research on the disinformation phenomena. 

to 

8.1.1  General framework for access to data  

For the strengthened Code, relevant signatories, in particular platforms, should commit to 
co-creating a robust framework for access to data for research purposes. The conditions 
for  access  should  be  transparent,  open  and  non-discriminatory,  proportionate  and 
justified. Where personal data are concerned, the conditions have to be GDPR compliant. 
In  general,  access  conditions  to  any  data  should  respect  the  right  to  private 
communications  and  appropriately  protect  the  rights  and  legitimate  interests  of  all 
concerned parties. 

Signatories should develop the framework in cooperation with the research community, 
EDMO  and  relevant  national  authorities.  Commitments  should  include  a  detailed 
timeline for the progress expected in the design and implementation of the framework.  

The  framework  should  contemplate  different  access  to  data  regimes  with  appropriate 
safeguards for i) anonymised and non-personal data and for ii) data requiring additional 
scrutiny,  including  personal  data.  The  framework  should  provide  for  the  possibility  of 
real-time  access  to  certain  types  of  data,  in  order  to  enable  the  prompt  assessment  of 
emerging or evolving risks and the design of appropriate mitigation measures. 

While the framework is in development, signatories should pilot temporary solutions. For 
example,  the  use  of  ‘sandboxes’  could  provide  access  to  relevant  platform  data  for 
research on specific topics for a limited number of researchers informing the design of 
the framework and test operational solutions for wider access to data across platforms.  

8.1.2  Access to anonymised and non-personal data 

The  strengthened  Code  should  include  a  commitment  to  provide,  wherever  practicable, 
continuous,  real-time,  stable  and  harmonised  access  to  anonymised,  aggregate  or 
otherwise  non-personal  data  for  research  purposes  through  APIs  or  other  open  and 
accessible technical solutions allowing full exploitation of the datasets.  

Access  to  data  solutions  should  facilitate  the  search  and  analysis  of  the  data.  Relevant 
signatories  should  ensure  that  the  functionalities  of  access  systems  meet  researchers’ 
needs  and  are  interoperable.  Commitments  should  ensure  procedures  for  reporting  the 

65 This is as well crucial for informing signatories, the Commission, the competent national authorities and 
the public. 
66 Article 31 in particular. 

17 

 
 
                                                 
malfunctioning  of  access  systems,  and  for  restoring  access  and  repairing  faulty 
functionalities in a reasonable time.  

8.1.3  Access to data requiring additional scrutiny, including personal data  

Data  which  might  expose  personal  information,  including  sensitive  one67,  require 
additional  security  and  safeguards.  Confidential  information,  in  particular  trade  secrets, 
or  data  linked  to  the  security  of  the  platforms’  services  also  deserves  appropriate 
protection.  At  the  same  time,  the  framework  for  access  to  data  should  at  least  allow 
academic researchers to have access to datasets necessary to understand sources, vectors, 
methods and propagation patterns that characterise the disinformation phenomenon.  

To  this  end,  the  Code  should  set  up  a  transparent  procedure  involving  all  relevant 
stakeholders,  in  particular,  platforms  and  the  research  community,  to  define  the 
conditions applicable for access to these datasets. In principle, the conditions should be 
standardised and uniform  across platforms. The procedure should regulate  inter alia  (i) 
the minimum standards and qualification for researchers to whom access will be granted, 
(ii)  the  minimum  categories  of  data  that  will  be  made  available,  (iii)  the  technical  and 
organisational security measures to be observed in the processing of such data, including 
purpose limitation and data minimisation; and (iv) in respect of pseudonymised data, any 
measures necessary to prevent reattribution68.  

8.1.4  Role of EDMO  

In view of its independence and its coordination functions, EDMO could provide support 
in the area of access to data, including guidance on inter alia the categories of data to be 
made available, the purposes for which data may be processed, and appropriate security 
measures  for  the  processing  of  personal  data  and  for  preventing  the  reattribution  of 
anonymised data.  

Facilitated by EDMO, work is being undertaken to explore the possibilities of a code of 
conduct  under  Article  40  of  the  GDPR  aimed  at  ensuring  the  proper  application  of 
privacy  and  data  protection  requirements  to  the  sharing  of  personal  data  by  platforms 
with researchers. The GDPR provides general conditions of processing of personal data 
also in the form of sharing of personal data by platforms with researchers.  Such a code 
would  reduce  legal  uncertainties  and  risks  for  platforms  providing  access  to  data  and 
ensure a secure and harmonised environment for processing of personal data for research 
purposes69. The strengthened Code should commit signatories to facilitate, as necessary, 
the development of the code of conduct under Article 40 of the GDPR. 

8.1.5  Access to data for other stakeholders 

Other  stakeholders,  such  as  civil  society  organisations,  non-academic  research  centres 
and  investigative  journalists,  also  play  important  roles  in  the  detection  and  analysis  of 
disinformation campaigns, the formulation of policy responses, as well as the promotion 

67 In the sense of Article 9 of GDPR. 
68 As required by GDPR, when it comes to the personal data their disclosure needs to be based  on a clear 
legal basis with appropriate safeguards, including the regime of Article 9 for the special categories of data. 
69 The stakeholder discussion showed support from the Code’s signatories and the research community to 
this 
https://digital-strategy.ec.europa.eu/en/library/summary-multi-stakeholder-discussions-
preparation-guidance-strengthen-code-practice-disinformation. 

initiative: 

18 

 
 
                                                 
of public awareness and social resilience. The signatories of the Code should allow,  in 
particular  in  Member  States  where  there  is  not  adequate  academic  capacity,  for  a 
sufficient level of access for such stakeholders consistent with privacy requirements and 
subject  to  reinforced  control  against  misuses  of  personal  data  and  the  reattribution  of 
pseudonymised data.  

8.2  Framework of cooperation between signatories and researchers   

To  foster  and  empower  a  larger  multi-disciplinary  community  of  independent 
researchers,  the  Code  should  establish  a  framework  for  transparent,  open,  and  non-
discriminatory  cooperation  between  signatories  and  the  EU  research  community 
regarding  resources  and  support  made  available  to  researchers.  This  framework  should 
allow  the  research  community  to  independently  manage  the  funds  made  available  by 
signatories  for  research  on  disinformation,  defining  scientific  priorities  and  transparent 
allocation procedures based on scientific merit. In this regard, EDMO could assist in the 
allocation of such resources.  

8.3  Collaboration with fact-checkers  

Fact-checkers  are  important  players  in  addressing  the  disinformation  phenomenon70. 
They assess and verify content based on facts, evidence and contextual information, and 
raise user awareness about disinformation online. The strengthened Code should foresee 
strengthened support to their work and increase the coverage of fact-checking activities 
across EU Member States and languages. 

8.3.1  Forms of cooperation  

In view of the significant gaps and uneven application of fact-checking activities across 
services and Member States71, platform signatories should commit to concrete steps, with 
clear targets  and timelines, to  extend their cooperation with  fact-checkers to  ensure the 
consistent  application  of  fact-checking  in  their  services.  Efforts  should  focus,  in 
particular, on Member States and languages where fact-checking is not yet provided 72. 

This  could  be  achieved  through  multilateral  agreements  between  platforms  and 
independent  fact-checking  organisations  that  meet  high  ethical  and  professional 
standards. Such agreements should be based on transparent, open and non-discriminatory 
conditions,  and  ensure  the  independence  of  fact-checkers.  The  agreements  should 
provide  for  fair  remuneration  to  fact-checkers  for  work  used  by  the  platforms,  foster 
cross-border  cooperation  between  fact-checkers,  and  facilitate  the  flow  of  fact-checks 
across signatories’ services.  

In  view  of  its  role  in  fostering  joint  fact-checking  activities,  EDMO  is  well-suited  to 
support  platforms  and  fact-checkers  in  developing  a  framework  for  collaboration, 

70  Fact-checking  organisations  regularly  publish  nonpartisan  reports  on  the  accuracy  of  statements  by 
public  figures  and  major  institutions  and  other  widely  circulated  claims  of  interest  to  society.  They  are 
independent and follow strict ethical and transparency rules such the one defined by the International Fact-
Checking  Network  (IFCN) (https://www.poynter.org/international-fact-checking-network-fact-checkers-
code-principles). 
71 https://www.disinfo.eu/publications/bulgaria%3A-the-wild-wild-east-of-vaccine-disinformation/  
72 EDMO fact-checking activities map in the EU: https://edmo.eu/fact-checking-activities/  

19 

 
 
                                                 
including  the  creation  of  a  common  interface  for  fact-checkers,  the  exchange  of 
information between fact-checkers, and the promotion of cross-border cooperation.73  

8.3.2  Use and integration of fact-checking in signatories’ services 

The  strengthened  Code  should  include  commitments  requiring  more  consistent  use  and 
integration  of  fact-checkers’  work  in  platforms’  services,  including  in  programmatic 
advertising  systems  and  in  video  content.  Platforms  should  commit  to  employ 
mechanisms  enabling  the  prompt  and  consistent  incorporation  of  fact-checks  into  their 
services  upon  notification  by  fact-checkers,  including  swift  and  efficient  labelling. 
Relevant  signatories  should  facilitate  the  creation  of  a  common  repository  of  fact-
checking  articles  (fact-checks)  produced  by  fact-checkers  and  explore  technological 
solutions  to  facilitate  its  efficient  use  across  platforms  and  languages  to  prevent  the 
resurgence of disinformation that has been debunked by fact-checkers74.  

8.3.3  Fact-checkers’ access to relevant information  

To  maximise  the  quality  and  impact  of  fact-checking,  the  strengthened  Code  should 
ensure that platform signatories commit to provide fact-checkers with automated access 
to  information  on  the  actions  they  have  taken  with  respect  to  fact-checked  content  and 
the  fact  checks.  The  information  should  quantify  (i)  user  interactions  over  time  (e.g. 
number of views, like, shares, comments before and after the fact-check)75 with content 
which has been fact-checked, and (ii) the reach of the fact-check over time in the online 
services  where  they  were  published.  Platforms  and  fact-checkers  should  agree  on  a 
common  interface  for  fact-checking  in  order  to  ensure  consistency  in  the  way  the 
platforms use, credit and provide feedback on the work of fact-checkers. Moreover, the 
Code should foresee regular exchange of information between relevant Code signatories 
and the fact-checking community aimed at further strengthening cooperation.  

9  MONITORING OF THE CODE  

The  strengthened  Code  should  be  complemented  with  a  robust  monitoring  system, 
building on the Commission’s experience to date in monitoring the Code, including the 
COVID-19 programme. The improved monitoring system should provide for the regular 
assessment  of  the  signatories’  implementation  of  the  Code  commitments,  spur 
improvements  in  their  policies  and  actions,  and  enable  evaluation  of  the  Code’s 
effectiveness  as  a  tool  for  tackling  disinformation.  The  improved  monitoring  system 
should reinforce the accountability of online platforms  in  the interim before the DSA’s 
adoption,  and  provide  a  framework  inter  alia  for  structured  dialogue  with  very  large 
platforms  on  the  development  and  deployment  of  risk  assessment  and  mitigation 
measures, in anticipation of the legal obligations foreseen for them in the proposed DSA.  

In view of these objectives, the Code’s existing commitments on monitoring should be 
reinforced  and extended  to  create  a robust  framework that incorporates the cornerstone 

73  To  further  support  the  work  of  European  fact-checkers,  their  cooperation  and  the  development  of 
commonly  agreed  professional  standards,  the  pilot  project  “Integrity  of  social  media”  will  support  the 
drafting of a Code for professional integrity for European fact-checkers in cooperation with EDMO. See: 
annual work programme, adopted under Commission Decision C (2020) 2259. 
74 Regarding the creation of a repository of fact-checks, signatories could seek synergies with EDMO. 
75  This  should  include  also  anonymised  demographics  and  localisation  of  those  sharing/receiving  fact-
checked content. 

20 

 
 
                                                 
elements  set  out  below.  The  strengthened  Code  should  ensure  in  particular  that 
signatories provide the information and data for the monitoring in standardised formats, 
with Member States breakdowns and on a timely basis.  

9.1  Key Performance Indicators 

The  monitoring  of  the  Code  should  be  grounded  on  KPIs  capable  of  measuring  the 
implementation and effectiveness of the Code’s commitments and the Code’s impact on 
the  disinformation  phenomenon.  To  this  end,  two  classes  of  KPIs  are  pertinent:  (i) 
service-level  indicators,  which  measure  the  results  and  impact  of  the  policies 
implemented  by  signatories  to  fulfil  their  commitments  under  the  Code,  and  (ii) 
structural indicators, which measure the overall impact of the Code on disinformation in 
the EU.  

9.1.1  Service-level indicators 

indicators.  Service-level 

Under  the  revised  Code,  signatories  should  commit  to  the  formulation  of  concrete 
the 
service-level 
implementation of the Code’s commitments and the impact of signatories’ policies. The 
indicators should be sufficiently flexible to cater to the different nature of the signatories’ 
services while allowing for consistent reporting and comparisons across services.  

indicators  should  effectively  measure 

The strengthened Code should require that signatories identify, report on and commit to a 
minimum set of qualitative and quantitative indicators aimed at evaluating inter alia: 

 

 

 

 

 

 

The impact of tools and features put in place to enhance user awareness and 
user  empowerment,  including  user  interactions  with  such  tools  and 
features76. 
The impact of tools and features that display or make more visible reliable 
information  of  public  interest,  including  user  interactions  with  such  tools 
and features77. 
The  number  of  fact  checks,  the  percentage  of  fact-checked  content  versus 
content flagged by users, and funding provided for fact-checking activities. 
The 
interactions  with 
information fact-checked as false or misleading78. 
The number of appeals in relation to actions taken on content by platforms 
as  a  result  of  flagging  of  disinformation  and  information  regarding  their 
outcome. 
The number of pages, accounts, profiles and groups sharing disinformation 
subject to actions reducing their visibility79 and the amount of such content 
shared. 

impact  of  fact-checking  activities  and  user 

76  Impact  could  be  measured  through  indicators  quantifying  the  level  of  interaction  (e.g.  views,  click- 
through  rates,  shares,  etc.)  of  users  with  such  tools  and  qualifying  users’  perception  regarding  the 
usefulness of such tools. Also, indicators should include data on the use of tools for flagging and reporting 
content perceived as false. 
77  Impact  could  be  measured  through  indicators  quantifying  the  level  of  interaction  (e.g.  views, 
impressions,  click-through  rates,  shares,  etc.)  of  users  with  such  tools  and  qualifying  users’  perception 
regarding the usefulness of such tools.  
78  Impact  could  be  measured  through  indicators  quantifying  the  level  of  interaction  (e.g.  views,  click- 
through rates,  shares)  with pieces of content before and after they are  labelled or demoted for being fact 
checked as false. Other indicators could also give information on how users’ interactions occur. 

21 

 
 
                                                 
 

 

 
 

 

 

The  impact  of  identified  impermissible  manipulative  behaviour,  including 
instances of content or accounts removed or demoted80.  
The  number  of  partnerships  between  the  Code’s  signatories’  from  the  ad 
industry  and  third-party  entities  assessing  the  quality  of  information 
sources.  
The impact of measures employed for the scrutiny of ad placements81.  
The  quantity  and  granularity  of  data  made  available  to  research  purposes 
and  the  number  of  European  research  organisations  having  access  to 
platforms’ data.  
The  amount  of  resources  made  available  by  signatories  for  research  on 
disinformation  and the number of European  research organisations having 
access to such resources. 
Information  regarding  the  human  workforce  involved  in  fulfilling  the 
Code’s commitments82.  

9.1.2  Structural indicators 

Signatories of the Code also should commit to contribute to the development of structural 
indicators  that  can  effectively  measure  the  overall  impact  of  the  Code  on  the 
disinformation  phenomenon.  As  further  described  below,  signatories  should  set  up  a 
permanent  task-force  whose  duties  will  include  developing,  testing  and  adjusting 
structural indicators.  

Structural indicators could, for example, be based on representative samples of users in 
various  Member  States  aimed  at  gauging  the  prevalence  of  persistent  purveyors  of 
disinformation83  in  the  online  media  diets  of  European  citizens84.  Such  indicators  could 
measure  public  engagement  with  information  sources,  as  well  as  regular,  standardised 
surveys to measure the exposure of citizens to disinformation.  

Until a more stable set of structural indicators is developed, signatories and stakeholders 
should  agree  upon  a  minimum  viable  set  of  structural  indicators  that  can  be  rapidly 
implemented and tested, working towards developing a stable set of effective structural 
indicators.  

9.2  Monitoring framework 

The  monitoring  framework  should  allow  the  regular  assessment  of  the  signatories’ 
implementation  of  Code  commitments,  including  changes  and  evolutions  of  pertinent 

79 Including measures such as down ranking content, as well as closing profiles and groups.  
80  Impact  could  be  measured  through  indicators  quantifying  the  level  of  interaction  (e.g.  views,  click- 
through rates, shares, etc.) with content, accounts and instances before they were removed and before and 
after they were demoted.  
81  Impact  could  be  measured  through  indicators  quantifying  the  number  of  ad  placements  displayed  on 
websites  identified  as  persistently  purveying  disinformation  and  the  number  of  ads  containing 
disinformation that were removed. 
82  This  includes  the  number  of  staff  employed  to  carry  out  activities  to  counter  disinformation  and  the 
languages covered by their activities. 
83  The  identification  of  online  purveyors  of  disinformation  should  be  based  on  a  clear  and  agreed 
methodology defined by a wider set of stakeholders, including academic researchers, fact-checkers, NGOs 
and civil society organisations. 
84 The  measuring mechanism for structural indicators could draw inspiration from what it is done by the 
audiovisual sector to measure audiences. 

22 

 
 
                                                                                                                                                 
policies  and  actions.  To  this  end,  the  signatories  should  report  regularly  to  the 
Commission on the implementation of their commitments, including relevant KPIs.  

Following  the  positive  experience  of  the  monitoring  programmes  during  the  2019  EU 
elections85 and the COVID-19 pandemic, the Commission will rely on the support of the 
European Regulators Group for Audiovisual Media Services (ERGA) on monitoring the 
implementation  of  the  Code  at  Member  State  level.  EDMO  and  its  hubs  should  also 
support  the  Commission  in  analysing  information  and  data  reported  by  the  signatories 
and in assessing the impact of the Code at national and EU level.  

Taking  into  account  the  expert  advice  and  support  from  ERGA  and  EDMO,  the 
Commission will regularly assess the progress made in the implementation of the Code, 
as  well  as  the  impact  of  the  Code  on  the  disinformation  phenomenon  and  publish  its 
conclusions.  The  Commission  may  also  provide  further  guidance  on  how  signatories 
should address remaining shortcomings and gaps in the Code. 

9.2.1  Regular reporting 

the 

Reporting obligations under the strengthened Code should take into account the size of 
signatories  and  the  type  of  services  they  provide.  Providers  of  online  services  that  are 
widely  used  at  EU  level  and  have  higher  risk  profiles  with  respect  to  the  spread  of 
disinformation  should  report  every  six  months  on 
the 
commitments  they  have  subscribed  to  and  should  provide  corresponding  service-level 
indicators.  They  should  also,  on  a  yearly  basis,  assess  the  risks  linked  to  the 
disinformation  phenomenon.  Other  Code  signatories  should  report  yearly  and  provide 
data  corresponding  to  their  activities.  Signatories  that  provide  tools,  instruments  or 
solutions to fight against disinformation, or that support the Code through the provision 
of  expertise,  should  also  report  on  their  activities  and  findings  that  are  relevant  for  the 
implementation and effectiveness of the Code on a yearly basis. The reporting should be 
carried  out  in  accordance  with  a  defined  schedule  that  sets  out  coverage  periods  and 
submission  deadlines.  Data  used  to  measure  the  KPIs  should  include  breakdowns  at 
Member State level. 

implementation  of 

The  reporting  should  be  based  on  a  harmonised  template  that  allows,  to  the  extent 
practicable, cross-platform comparisons. Moreover, signatories should agree on a set of 
standard  and  auditable  formats  for  providing  data  related  to  the  KPIs.  These  formats 
should  be  co-developed  with  relevant  stakeholders  from  the  permanent  task-force  and 
should  meet  standards  and  employ  methods  of  the  research  and  fact-checking 
community. Eventually, these formats should enable the continuous updating of a public 
dashboard made available through the transparency centre, as described below.  

9.2.2  Transparency centre 

To  enhance  transparency  and  accountability  around  the  implementation  of  the  Code, 
signatories  should  commit  to  create  and  maintain  a  publicly  accessible  transparency 
centre.  Signatories  should  indicate  in  the  transparency  centre  the  specific  policies  they 
adopted to implement each Code commitment they have subscribed to and provide basic 
information about how these policies are enforced, including geographical and language 
coverage.  It  should  also  feature  a  public  dashboard  displaying  relevant  KPIs.  The 

85 https://erga-online.eu/wp-content/uploads/2020/05/ERGA-2019-report-published-2020-LQ.pdf  

23 

 
 
                                                 
transparency  centre  should  be  designed,  in  particular,  with  a  view  to  enabling  cross-
service comparisons of the signatories’ progress in implementing Code commitments and 
achieving  measurable  impacts  in  the  fight  against  disinformation.  Signatories  should 
commit  to  keep  the  transparency  centre  regularly  updated  and  disclose  any  changes  to 
relevant policies no later than 30 days after a change is announced or implemented. 

9.2.3  Permanent task-force 

The  strengthened  Code  should  set  up  a  permanent  task-force  aimed  at  evolving  and 
adapting  the  Code  in  view  of  technological,  societal,  market,  and  legislative 
developments. The task-force should include Code’s signatories and representatives from 
EDMO,  ERGA  and  could  invite  relevant  experts  to  support  its  work.  The  task  force 
should  be  chaired  by  the  Commission  and  include  representatives  of  the  European 
External  Action  Service.  In  line  with  the  overall  objective  of  providing  input  for  the 
review  and  adaptation  of  the  Code,  the  activities  of  the  task  force  should  include  inter 
alia:  

  Establishing  a  risk  assessment  methodology  and  a  rapid  response  system  to  be 

used in special situations like elections or crises.  

  Reviewing the quality and effectiveness of the harmonised reporting template, as 
well as the formats and methods of data disclosure for monitoring purposes.  
  Optimising the quality and precision of data to be provided for the measurement 

of the indicators.  

  Contributing  to  the  assessment  of  the  quality  and  effectiveness  of  service-level 

indicators and their relevant adaptation. 

  Developing, testing and adjusting structural indicators and designing mechanisms 

to measure them at Member State level. 

  Providing  expert  input  and  up-to-date  evidence  relevant  to  the  Code’s 

commitments, such as inter alia new forms of inauthentic behaviour. 

10  CONCLUSION AND NEXT STEPS 

This  Guidance  sets  out  key  elements  that  are  required,  in  the  Commission’s  view,  to 
transform the Code into a stronger instrument for addressing disinformation and creating 
a safer and more transparent online environment.  

The  Commission  calls  upon  the  signatories  of  the  Code  to  convene  and  carry  out  the 
strengthening  of  the  Code,  in  line  with  this  Guidance.  The  Commission  invites  the 
signatories to provide a first draft of the revised Code in the autumn to allow for a proper 
discussion. It also invites potential new signatories to join the Code and take part in its 
revision,  including  established  and  emerging  platforms,  corporate  actors  and  other 
participants  in  the  online  advertising  sector,  as  well  as  other  stakeholders  that  can 
contribute resources or expertise to the Code’s effective functioning.  

Since  disinformation  is  a  borderless  phenomenon  and  in  order  to  strengthen  the  real 
impact of the Code of Practice, actions in the European neighbourhood would be useful, 
such as work with civil society, cooperation with media professionals and media literacy 
initiatives. 

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