Disinformation affecting the EU : tackled but not tamed. Special report No 09, 2021.
Date: 2021-09-15
Institutions: European Court of Auditors
Subjects: Internet, action programme, communications policy, digital literacy, disinformation, dissemination of EU information, information technology, mass media, performance audit, report, social media

EN 

2021 

09 

Special Report  Disinformation affecting the EU: 

tackled but not tamed 

 
 
 
2 

Paragraph 

I-IX 

01-13 

14-18 

19-107 

19-42 

20-24 

25-31 

32-42 

Contents 

Executive summary 

Introduction 

Audit scope and approach 

Observations 

The EU action plan against disinformation was relevant when 
drawn up, but incomplete 

The EU action plan was broadly consistent with experts’ and stakeholders’ 
views on disinformation 

The EEAS and the Commission did not establish clear coordination 
arrangements to implement the EU action plan 

A piecemeal monitoring and reporting framework and the lack of long-term 
funding undermine the EU action plan’s accountability 

The implementation of the EU action plan is broadly on track, but 
has revealed a number of shortcomings 

43-107 

The strategic communications task forces play an important role but are not 
adequately staffed or funded to deal with emerging threats 

The RAS has brought Member States together but has not lived up to its full 
potential 

The code of practice made online platforms adopt a stance against 
disinformation but stopped short of making them accountable 

Lack of a coherent media literacy strategy and fragmentation of EU actions 
dilutes their impact 

Conclusions and recommendations 

44-64 

65-76 

77-89 

90-107 

108-120 

 
 
3 

Annexes 

Annex I — Main EU institution departments and offices fighting 
disinformation 

Annex II — EU spending on actions against disinformation (in 
euro) 

Annex III — Assessment of projects against disinformation (Pilot 
Projects, Preparatory Actions, H2020) 

Annex IV — Assessment of the actions included in the EU action 
plan on Disinformation 

Annex V — The code of practice on disinformation 

Annex VI — Chronology of the main EU actions as a response to 
the 2020 COVID-19 pandemic and “infodemic” 

Acronyms and abbreviations 

Glossary 

Replies of the Commission and the EEAS 

Audit team 

Timeline 

 
 
 
 
4 

Executive summary 

I Disinformation has been present in human communication since the dawn of 
civilisation and the creation of organised societies. What has changed in recent years, 
however, is its sheer scale and the speed with which false or misleading information 
can reach its intended and unintended audiences through social media and new 
technologies. This may cause public harm. 

II The European Council, in its conclusions of 28 June 2018, invited the EU’s High 
Representative for Foreign Affairs and Security Policy and the Commission to present 
an action plan with specific proposals for a coordinated response to disinformation. 
The EU action plan against disinformation, presented on 5 December 2018, includes 
ten specific actions based on four priority areas or ‘pillars’, and consolidates the EU’s 
efforts to tackle disinformation. EU spending on tackling disinformation has been 
relatively low to date: €50 million between 2015 and 2020. 

III The purpose of the audit was to assess whether the EU action plan against 
disinformation was relevant when drawn up and delivering its intended results. The 
audit covered the period from the run-up to the adoption of the EU action plan against 
disinformation in December 2018 until September 2020. This report is the first 
comprehensive, independent assessment of its relevance and the results achieved. 
Overall, we conclude that the EU action plan was relevant but incomplete, and even 
though its implementation is broadly on track and there is evidence of positive 
developments, some results have not been delivered as intended. 

IV The EU action plan contains relevant, proactive and reactive measures to fight 
disinformation. However, even though disinformation tactics, actors and technology 
are constantly evolving, the EU action plan has not been updated since it was 
presented in 2018. It does not include comprehensive arrangements to ensure that 
any EU response against disinformation is well coordinated, effective and 
proportionate to the type and scale of the threat. Additionally, there was no 
monitoring, evaluation and reporting framework accompanying the EU action plan, 
which undermines accountability. 

V The European External Action Service’s three strategic communications task forces 
have improved the EU’s capacity to forecast and respond to disinformation in 
neighbouring countries. However, they are not adequately resourced or evaluated, 
and their mandates do not cover some emerging threats.  

 
 
5 

VI The EUvsDisinfo project has been instrumental in raising awareness about Russian 
disinformation. However, the fact that it is hosted by the European External Action 
Service raises some questions about its independence and ultimate purpose, as it 
could be perceived as representing the EU’s official position. The rapid alert system has 
facilitated information sharing among Member States and EU institutions. 
Nevertheless, Member States are not using the system to its full potential for 
coordinating joint responses to disinformation and common action. 

VII With the code of practice, the Commission has established a pioneering 
framework for engagement with online platforms. We found that the code of practice 
fell short of its goal of holding online platforms accountable for their actions and their 
role in actively tackling disinformation. 

VIII The report also highlights the absence of a media literacy strategy that includes 
tackling disinformation, and the fragmentation of policy and actions to increase 
capacity to access, understand and interact with media and communications. Finally, 
we found there was a risk that the newly created European Digital Media Observatory 
would not achieve its objectives. 

IX Based on these conclusions, we recommend that the European External Action 
Service and the Commission: 

o 

o 

o 

o 

o 

o 

improve the coordination and accountability of EU actions against disinformation 
(European External Action Service and Commission); 

improve the operational arrangements of the StratCom division and its task forces 
(European External Action Service); 

increase participation in the rapid alert system by Member States and online 
platforms (European External Action Service); 

improve the monitoring and accountability of online platforms (Commission); 

adopt an EU media literacy strategy that includes tackling disinformation 
(Commission); 

take steps to enable the European Digital Media Observatory to fulfil its ambitious 
objectives (Commission). 

 
 
6 

Introduction 

01 The European Commission1 defines “disinformation” as the “creation, 
presentation and dissemination of verifiably false or misleading information for the 
purposes of economic gain or intentionally deceiving the public, which may cause 
public harm”. Such public harm includes threats to democratic political and policy-
making processes as well as to the protection of EU citizens' health, the environment 
or security. 

02 The Commission’s definition of disinformation excludes misleading advertising, 
reporting errors, satire and parody, or clearly identified partisan news and 
commentary. Unlike hate speech or terrorist material, for example, false or misleading 
information is not illegal on its own. 

03 The EU’s legitimacy and purpose rest on a democratic foundation, which depends 
on an informed electorate expressing its democratic will through free and fair 
elections. Any attempt to maliciously and intentionally undermine or manipulate 
public opinion therefore represents a grave threat to the EU itself. At the same time, 
combatting disinformation represents a major challenge, as it should not impair the 
freedom of opinion and expression enshrined in the EU Charter of Fundamental Rights. 

04 The term “disinformation” emerged in the early 20th century and has been used 
extensively ever since. In recent years, the internet has amplified the scale and speed 
with which false information is reaching audiences, often anonymously and at minimal 
cost. 

05 EU efforts to combat disinformation date back to March 2015, when the 
European Council2 invited the EU’s High Representative for Foreign Affairs and Security 
Policy (the “High Representative”), in cooperation with the Member States and EU 
institutions, “to develop an action plan on strategic communication to address Russia’s 
ongoing disinformation campaigns”. This led to the creation of the strategic 
communications division (“StratCom”) and the first of its task forces within the 
European External Action Service (EEAS), with a mandate to counter disinformation 
originating outside the EU (Russia) and design and disseminate positive strategic 
communications in the EU’s eastern neighbourhood – known as the East strategic 

1  Communication on tackling online disinformation, COM(2018) 236 final of 26 April 2018. 

2  EUCO 11/15 (Point 13) European Council meeting (19 and 20 March 2015) – Conclusions. 

 
 
                                                      
7 

communications task force. In 2017, two more StratCom task forces were created: one 
for the southern neighbourhood and another for the Western Balkans (see also 
paragraphs 45-49). 

06 In late 2017, the Commission set up a high-level expert group to offer concrete 
advice on tackling disinformation. The group delivered its report in March 20183, 
which formed the basis for the Commission’s “Communication on tackling online 
disinformation: a European approach”4 (April 2018). This Communication outlined key 
overarching principles and objectives to guide action to raise public awareness about 
disinformation, as well as the specific measures the Commission intended to take. 

07 The European Council, in its conclusions of 28 June 20185, invited the EU’s High 
Representative for Foreign Affairs and Security Policy and the Commission to “present 
an action plan by December 2018 with specific proposals for a coordinated EU 
response to the challenge of disinformation, including appropriate mandates and 
sufficient resources for the relevant EEAS Strategic Communications teams”. 

08 Based on the April 2018 communication, the Commission published an EU action 
plan against disinformation in December 2018 (hereinafter: the “EU action plan”). It 
sets out ten specific actions based on four priority areas or ‘pillars’ targeting society as 
a whole, as shown in Table 1 below. 

3  Final report of the High Level Expert Group on Fake News and Online Disinformation. 

4  See footnote 1. 

5  EUCO 9/18 European Council meeting (28 June 2018) – Conclusions. 

 
 
                                                      
8 

Table 1 – The pillars and actions of the EU action plan against 
disinformation 

Pillar 

I. Improving the 
capabilities of EU 
institutions to detect, 
analyse and expose 
disinformation 

II. Strengthening 
coordinated and joint 
responses to 
disinformation 

Actions 

(1) 

Strengthen the strategic communications task forces and EU 
delegations with additional resources (human and financial) to 
detect, analyse and expose disinformation activities 

(2)  Review the mandates of the South and Western Balkans strategic 

communications task forces. 

(3)  By March 2019, establish a rapid alert system among Member States 

and EU institutions that works closely with other existing networks 
(such as NATO and G7) 
Step up communication before the 2019 European Parliament 
elections 
Strengthen strategic communications in the Neighbourhood. 

(4) 

(5) 

III. Mobilising private 
sector to tackle 
disinformation 

(6)  Closely and continuously monitor the implementation of a code of 
practice to tackle disinformation, including pushing for rapid and 
effective compliance, with a comprehensive assessment after 12 
months 

IV. Raising awareness 
and improving societal 
resilience 

(7)  With Member States, organise targeted campaigns to raise 

awareness of the negative effects of disinformation, and support 
work of independent media and quality journalism 
(8)  Member States should support the creation of teams of 

multi-disciplinary independent fact-checkers and researchers to 
detect and expose disinformation campaigns 

(9)  Promotion of media literacy, including through Media Literacy Week 
(March 2019) and rapid implementation of the relevant provisions of 
the Audio-visual Media Services Directive 

(10)  Effective follow-up of the Elections Package, notably the 

Recommendation, including monitoring by the Commission of its 
implementation 

Source: ECA, based on the EU action plan. 

09 There is no EU legal framework governing disinformation apart from article 11 of 
the Charter on Fundamental Rights on the Freedom of expression and information, 
and a series of policy initiatives. Responsibility for combatting disinformation lies 
primarily with the Member States6. The EU's role is to support the Member States with 
a common vision and actions aimed at strengthening coordination, communication 
and the adoption of good practices. Annex I presents the main departments and 
offices of the EU institutions involved in the implementation of the EU action plan. As 
Annex II shows, EU spending on tackling disinformation has been relatively low to 
date: €50 million between 2015 and 2020. 

6  Articles 2-6 of Treaty on the functioning of the European Union. 

 
 
                                                      
9 

10 In December 20197, the Council confirmed that the EU action plan “remains at 
the heart of the EU’s efforts” to combat disinformation, and called for it to be 
reviewed regularly and updated where necessary. It also invited the EEAS to reinforce 
its strategic communication work in other regions, including sub-Saharan Africa. The 
European Parliament has also on numerous occasions expressed the importance of 
strengthening efforts to combat disinformation8. 

11 In early 2020, almost immediately following the COVID-19 outbreak, an 
unprecedented wave of misinformation, disinformation and digital hoaxes appeared 
on the internet, which the World Health Organization described as an “infodemic”9. 
This posed a direct threat to public health and economic recovery. In June 2020, the 
European Commission and the High Representative published a communication 
entitled “Tackling COVID-19 disinformation - Getting the facts right”10, which looked at 
the steps already taken and concrete actions to follow against disinformation 
regarding COVID-19. 

12 On 4 December 2020, the Commission presented the “European democracy 
action plan”11, part of which is dedicated to strengthening the fight against 
disinformation. It builds on existing initiatives in the EU action plan against 
disinformation. Furthermore, the Commission also issued a proposal for a Digital 

7  Council Conclusions on the “Complementary efforts to enhance resilience and counter 

hybrid threats”, paragraph 30 (10 December 2019). 

8  European Parliament resolution of 15 June 2017 on Online platforms and the Digital Single 

Market (2016/2276(INI)); European Parliament resolution of 3 May 2018 on media 
pluralism and media freedom in the European Union (2017/2209(INI); European Parliament 
resolution of 25 October 2018 on the use of Facebook users’ data by Cambridge Analytica 
and the impact on data protection (2018/2855(RSP)); European Parliament resolution on 
foreign electoral interference and disinformation in national and European democratic 
processes (2019/2810(RSP)). 

9  World Health Organisation “Let’s flatten the infodemic curve”. 

10  JOIN(2020) 8 final, 10 June 2020. 

11  Communication on the European Democracy Action Plan, COM(2020) 790 final of 

3 December 2020. 

 
 
                                                      
10 

Services Act12 proposing a horizontal framework for regulatory oversight, 
accountability and transparency of the online space in response to the emerging risks. 

13 Figure 1 provides a timeline of the main EU initiatives since 2015. 

Figure 1 – Timeline of main EU initiatives against disinformation 

3/2015 – Launch 
of the EEAS East 
StratCom Task 
Force

9/2018 – Package 
of measures 
securing European 
Elections and Code 
of Practice against 
Disinformation

11/2018 – Launch of 
the Social Observatory 
for Disinformation and 
Social Media Analysis

3/2019 – Setup of the 
Rapid Alert System and 
European Media 
Literacy Week

6/2020 – Communication 
on “Tackling COVID-19 
disinformation - Getting 
the facts right” and launch 
of the European Digital 
Media Observatory 

2015

2018

2019

2020

4/2018 – Communication on 
tackling online disinformation: 
a European approach

12/2018 – EU 
action plan 
against 
Disinformation

1-5/2019 –
Reporting from 
online platforms 
on the Code of 
Practice

12/2020 –
European 
Democracy 
action plan 
and proposal 
for a Digital 
Services Act

Source: ECA. 

12  Proposal for a regulation of the European Parliament and of the Council on a single market 

for digital services (Digital Services Act) and amending Directive 2000/31/EC, 
COM(2020) 825 final of 15 December 2020. 

 
 
 
 
 
                                                      
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Audit scope and approach 

14 This audit report comes two years after the adoption of the EU action plan 
against disinformation. It is the first comprehensive, independent assessment of its 
relevance and the results achieved, thereby contributing to the regular review of the 
EU action plan requested by the Council. 

15 The aim of our audit was to ascertain whether the EU action plan against 
disinformation is relevant and delivering its intended results. To answer this question, 
we addressed two sub-questions: 

o 

o 

Is the EU action plan relevant for tackling disinformation and underpinned by a 
sound accountability framework? 

Are the actions in the EU action plan being implemented as planned? To answer 
this sub-question, we assessed the status of the actions under each of the four 
pillars of the plan. 

16 The audit covered the period from the run-up to the adoption of the EU action 
plan against disinformation in December 2018 until September 2020. Where possible, 
this report also refers to recent developments in this area after this date, such as the 
Commission’s presentation of the European democracy action plan and the proposal 
for a Digital Services Act in December 2020 (see paragraph 12). However, as these 
documents were published after we had completed our audit work, they are beyond 
the scope of this audit. 

17 The audit included an extensive desk review and analysis of all available 
documentation on the structures put in place, and the actions planned and 
implemented through the EU action plan. We sent a survey to the 27 Member States’ 
Rapid Alert System contact points, with a response rate of 100 %. We also held 
meetings with numerous stakeholders such as the EEAS and relevant Commission 
directorates-general (DGs), the European Parliament, the Council, Commission 
representations, NATO, the NATO-affiliated Strategic Communication Centre of 
Excellence in Latvia, national authorities, online platforms, journalist and fact-checking 
organisations, audio-visual media services regulating bodies which provide advice to 
the Commission, academics and experts, project managers/coordinators and an 
external expert. 

 
 
18 We also assessed 20 out of 23 projects the Commission identified as being 
directly related to fighting disinformation through media literacy. Annex III 
summarises our assessment of these projects. 

12 

 
 
 
 
13 

Observations 

The EU action plan against disinformation was relevant when 
drawn up, but incomplete 

19 For this section, we examined whether the EU action plan had been relevant 
when first drawn up, i.e. whether it addressed the needs identified by experts and 
other stakeholders. We also assessed whether it had been reviewed and updated. We 
looked at the events and sources it was based on, and assessed whether it contains 
adequate coordination arrangements for communication and the elements necessary 
for measuring implementation performance and ensuring accountability. 

The EU action plan was broadly consistent with experts’ and 
stakeholders’ views on disinformation 

20 Fighting disinformation is a highly technical domain that requires input and 
expertise from a diverse range of professionals. Public consultation is also essential to 
establish the views and priorities of stakeholders and to understand the threat better. 

21 We found that the Commission had relied on appropriate external expertise and 
undertaken a comprehensive public consultation13 as a basis for the EU action plan. 
The EU action plan largely addressed the suggestions and concerns expressed in these 
documents. 

22 At the time the EU action plan was published in December 2018, it presented a 
structured approach to address issues requiring both reactive (debunking and reducing 
the visibility of disinformation content) and proactive longer-term efforts (media 
literacy and measures to improve societal resilience). It emphasised the goal of 
protecting the upcoming 2019 European elections, as well as long-term societal 
challenges requiring the involvement of many different actors. 

23 Except in the area of media literacy, the Commission identified concrete actions 
to follow the main recommendations from the report of the independent ‘High-level 
expert group on fake news and online disinformation’ (HLEG). The HLEG, consisting of 
39 experts with different backgrounds, was set up in January 2018 by the Commission 
to advise on policy initiatives to counter disinformation online. This report, together 

13  European Commission public consultation on fake news and online disinformation. 

 
 
                                                      
14 

with the Commission’s April 2018 communication formed the basis for the EU action 
plan. 

24 Further evidence of the EU action plan’s relevance is that its actions sought to 
engage a broad array of key stakeholders in the area, including not only EU institutions 
and Member States, but also others such as the private sector, civil society, fact-
checkers, journalists and academia. 

The EEAS and the Commission did not establish clear coordination 
arrangements to implement the EU action plan 

25 The EU action plan against disinformation was not accompanied by an overall 
coordination framework to ensure that any EU response is effective and proportionate 
to the type and scale of the threat. Defining and coordinating communication 
workflows, for example, would make it possible to identify when to work together and 
in partnership with local actors and civil society to raise awareness about 
disinformation threats. 

26 A communication strategy ensures a coherent response when different actors are 
involved. Each of the EU action plan’s four pillars is under the responsibility of a 
different Commission DG or the EEAS. This creates the risk of them ‘working in silos’ 
(i.e. in parallel without cooperation or coordination) when it comes to communication, 
without any single body being in charge or having complete oversight of all 
communication to combat disinformation. 

27 The Commission’s Directorate-General for Communication (DG COMM) is 
responsible for external communication for the institution. DG COMM’s management 
plan for 2019 recognises its role in tackling disinformation and highlights the need for 
cooperation among DGs and other institutions, referring in particular to the 
Directorate-General for Communications Networks, Content and Technology 
(DG CNECT) and the Joint Research Centre. However, there is no mention of the EEAS 
or the StratCom task forces, which are also very much involved in positive 
communication and fighting disinformation. 

28 DG COMM has established an internal network against disinformation (IND). Its 
aims include improving coordination of communication activities on tackling 
disinformation, establishing an online repository of validated rebuttals, systematically 
detecting disinformation and coordinating the response, and promoting positive 
messaging. Eleven meetings took place between its inception in May 2018 and 

 
 
15 

January 2020. These meetings are broadly inclusive, with representatives from many 
Commission services and representations, the EEAS and other institutions, as well as 
other experts. However, the meetings so far have only involved representatives 
sharing information on action taken, with no connection to policy-making and no 
evidence of concrete follow-up actions or decisions taken to make the IND an effective 
coordination mechanism. 

29 DG COMM’s 2019 management plan had only one indicator related to 
disinformation (out of 102) and this only measured the number of IND meetings. 

30 In addition, the Commission representations play a vital role in the Commission’s 
external communication, through positive messaging and outreach, media briefings, 
debunking myths and fighting disinformation, and are expected to participate actively 
in the IND. Their myth-busting activities are listed on a page on each official 
representation website. These pages were often difficult to access as their location 
varied between representations: some (e.g. in Greece and Spain) included it under the 
news section, while others (e.g. in Poland and Ireland) did not. They were also not 
regularly updated. Some pages provided limited, often-anecdotal information and 
there were no statistics available on the number of visitors to these pages. 

31 Finally, DG COMM was developing a central web-based disinformation hub as a 
centralised portal bringing together all aspects of the EU institutions’ work on 
disinformation. Its launch was due in early 2020 but it has been cancelled for unclear 
reasons. 

A piecemeal monitoring and reporting framework and the lack of long-
term funding undermine the EU action plan’s accountability 

32 To ensure accountability, an action plan needs clear objectives and time-bound 
actions, accompanied by a number of indicators for monitoring performance. 
Provisions for financing, regular reporting, evaluation and revisions are also essential 
elements of an action plan. 

33 Some objectives in the EU action plan have generic wording such as “step up” or 
“strengthen”, which do not lend themselves to measurement. No overall KPIs exist for 
the EU action plan as a whole. In addition, half of the actions (actions 1, 2, 4, 5 and 8) 
have no KPIs and the actions are either not clearly defined or time bound (see also 
Annex IV). 

 
 
16 

34 The timeframe of the actions varies between short- and long-term, and some are 
concrete and time-bound (e.g. “by March 2019, the Commission and the High 
Representative, in cooperation with Member States, will establish a Rapid Alert 
System”), while others are vague (e.g. “Member States should significantly strengthen 
their own communication efforts on Union values and policies”). 

35 The EU action plan was not accompanied by a dedicated monitoring and 
evaluation framework (this applies also to the recently published European democracy 
action plan). There was no provision to evaluate the plan as a whole and there has 
been no overall evaluation to date. Feedback from its implementation in the Member 
States is not recorded centrally and not aggregated. Each representation carries out its 
own communication campaign and collects statistics, but we did not find any evidence 
of those statistics being used by the Commission for lessons learned, best practice, or 
as a baseline. There is no reporting beyond stating that some activities belong to the 
category of efforts against disinformation. For example, tools such as the 
Commission’s internal myth-busting wiki or the newsletter against disinformation are 
not monitored in terms of Member State engagement (e.g. using surveys, user 
statistics or indicators). 

36 The Commission and EEAS regularly update and report to various Council working 
parties and preparatory bodies on progress in implementing actions under specific 
pillars of the EU action plan. However, this reporting is not in the public domain and 
does not encompass the whole EU action plan. 

37 Although there have been separate reports on specific aspects of the EU action 
plan (an assessment of the code of practice and a Commission report on the EU 
elections), only one report on the implementation of the EU action plan as a whole has 
been published. This was on 14 June 2019, six months after the presentation of the EU 
action plan itself. 

38 Although this first implementation report covered all pillars of the EU action plan, 
it has a number of shortcomings: 

o 

o 

o 

o 

it does not provide any measure of performance; 

except for the code of practice, reporting for each pillar is mostly in a general 
narrative form and there is no detailed reporting for each action; 

there is no reporting annex on individual projects linked to the EU action plan; 

there is no indication of when to expect the next implementation report. 

 
 
17 

39 Fighting disinformation is a constantly evolving area, which would merit regular 
reporting. The Joint Communication on tackling COVID-19 disinformation recognised 
the need to develop regular reporting14. 

40 The EU action plan lacks a dedicated financial plan covering the costs of all 
activities assigned to different entities. Financing comes from different sources and 
there are no provisions to secure funding in the long term, even though some of the 
events mentioned in the EU action plan are recurring. Annex II presents the budget 
allocated to the different actions to combat disinformation. It shows that the main 
source of funding is different every year and exposes a lack of financial planning (see 
also paragraphs 50-51). The Commission and the EEAS do not always earmark 
expenditure linked to fighting disinformation (it has no specific intervention code) – 
such information has been compiled only for this audit. Figure 2 gives an overview of 
all EU funding against disinformation from 2015 to 2020 (it does not include activities 
that contribute indirectly to combatting disinformation, namely the pro-active 
communications activities in the EU’s neighbourhood). 

Figure 2 – All EU funding against disinformation 2015-2020 

Source: ECA, based on Commission and EEAS information. 

14  Tackling COVID-19 disinformation – Getting the facts right, p. 7, JOIN(2020) 8 final of 

10 June 2020. 

 
 
 
                                                      
18 

41 Furthermore, the EU action plan has not yet been updated since it was presented 
in 2018. For example, some actions are linked only to the 2019 European elections or 
the 2019 Media Literacy Week, both of which have passed. Disinformation is 
constantly evolving. The tactics used, the technology behind disinformation 
campaigns, and the actors involved are all constantly changing15. The Council also 
highlighted the need to regularly review and update the EU action plan (see 
paragraph 10). 

42 Although the COVID-19 disinformation communication (June 2020), the European 
democracy action plan and the proposal for a digital services act extend certain actions 
originally set out in the EU action plan, they cannot be considered a comprehensive 
update thereof. Moreover, having actions pursuing similar objectives in different 
action plans and initiatives makes coordination more complex, increasing the risk of 
inefficiencies. 

The implementation of the EU action plan is broadly on track, 
but has revealed a number of shortcomings  

43 This section assesses the implementation of the actions under each of the four 
pillars of the EU action plan and the extent to which they have improved the way the 
EU tackles disinformation. 

The strategic communications task forces play an important role but are 
not adequately staffed or funded to deal with emerging threats 

44 Under pillar I of the EU action plan, we examined the EEAS StratCom task forces. 
We looked at their mandate and determined whether they were adequately staffed 
and sufficiently funded. In this context, we also examined the role and position of 
EUvsDisinfo, an EU flagship project against disinformation. 

15  “Automated tackling of disinformation”, EPRS study, March 2019. 

 
 
                                                      
19 

The StratCom task forces’ mandates do not adequately cover the full range of 
disinformation actors 

45 Apart from improving the EU’s capacity to forecast and respond to external 
disinformation activities (the StratCom task forces’ mandates do not cover 
disinformation generated within the EU), the StratCom task forces have contributed 
greatly to effective communication and promoting EU policies in neighbouring regions. 

46 The mandates of the three StratCom task forces (East, Western Balkans and 
South) have grown out of a series of Council Conclusions, with differences in tasks and 
focus. For example, the mandate of the East StratCom task force specifically covers the 
task “challenge Russia’s ongoing disinformation campaigns”16. The East StratCom task 
force’s mandate was defined in terms of a single, external malign actor rather than 
protecting Europe from disinformation regardless of source. 

47 This was not the case for the other two StratCom task forces, whose original 
focus was stepping up communication activities in their respective regions. The South 
StratCom task force was established to cover the EU’s southern neighbourhood and 
the Gulf region, while the Western Balkans task force was established to enhance 
strategic communications in that region. Prior to the December 2019 Council 
Conclusions17, addressing disinformation was not the central priority of either task 
force. Only the East StratCom task force had the explicit objective of strengthening the 
capacity to forecast, address and respond to disinformation. Table 2 below sets out 
each StratCom task force’s objectives at the time of the audit. 

16  European Council Conclusions on external relations (19 March 2015), Council document 

EUCO 11/15. 

17  Council Conclusions on Complementary efforts to enhance resilience and counter hybrid 

threats (10 December 2019), Council document 14972/19. 

 
 
                                                      
Table 2 – Comparison of the StratCom task forces’ objectives 

20 

StratCom 
Task 
force 

s
e
v
i
t
c
e
b
O

j

Source: EEAS. 

East 

Western Balkans 

South 

o 

o 

Strengthen EU 
communications in 
the region to support 
EU enlargement 
policy and the 
stabilisation and 
association process 
Contribute to 
informed debate 
about the EU and 
region, including by 
addressing 
disinformation 

o 

o 

o 

o 

Effective and 
strategic 
communication and 
promotion of EU 
policies 
Bridge the policy-
communications gap 
Supporting and 
promoting media 
freedom in the 
region 
Address 
misperceptions 
about the EU and 
disinformation in the 
region 

o 

o 

o 

Effective 
communication and 
promotion of EU 
policies towards the 
eastern partnership 
countries (Armenia, 
Azerbaijan, Belarus, 
Georgia, Moldova 
and Ukraine); 
Strengthening the 
overall media 
environment in the 
EU’s eastern 
neighbourhood, 
including support for 
media freedom and 
strengthening 
independent media; 
Improving EU 
capacity to forecast, 
address and respond 
to disinformation 
activities by Russia 

48 The three StratCom task forces are distributed widely across different regions and 
cover different agents of disinformation. Nevertheless, the StratCom task forces’ 
media monitoring activities focus extensively on Russian international media, Russian 
official communication channels, proxy media, and/or media inspired/driven by the 
Russian narrative, operating in the EU and its neighbourhood. However, according to 
EEAS analysis, other actors such as China have emerged to varying degrees as 
prominent disinformation threats. In this respect, the new European Parliament 
committee on foreign interference (INGE) has also held hearings to discuss potential 
threats from third countries18. 

49 The StratCom task forces’ mandate is a political one, which does not specifically 
spell out their policy objectives and is not underpinned by a firm legal foundation. 
Under action 2 of the EU action plan, the High Representative was meant to review the 

18  European Parliament Hearing on foreign interference on 25 and 26 January 2021: China, 

Iran, India and Saudi Arabia and UAE; European Parliament Hearing on Foreign Interference 
on 1 February 2021: Turkey and Russia. 

 
 
 
                                                      
21 

mandates of the South and West Balkans StratCom task forces (but not the East task 
force). However, this review was never done. The EEAS considers that the Council 
Conclusions adopted in December 2019, by stating explicitly that “all three Task Forces 
should be able to continuously detect, analyse and challenge disinformation 
activities”19, provides sufficient basis for (re-)affirming their mandates. The Council 
also invited the EEAS to assess its needs and options for expanding to other 
geographical areas, which demonstrates that political support exists to broaden the 
scope of the StratCom task forces. 

The StratCom task forces do not have a dedicated and stable funding source 

50 When it was set up in 2015, the East StratCom task force was not provided with 
any resources of its own and was funded out of the administrative expenditure of the 
EEAS and the Commission’s Service for Foreign Policy Instruments. The EU action plan 
boosted the funding available for the EEAS StratCom task forces. In fact, strategic 
communications is the only part of the action plan whose specific budget has 
increased. As Figure 2 above shows, the budget for the StratCom task forces and 
strategic communications has increased nearly fourfold since the action plan was 
adopted. 

51 Even though disinformation is not just a short-term threat, the StratCom task 
forces do not have a stable funding source, which could threaten their sustainability. 
For example, a significant source of funding for the StratCom task forces has been a 
European Parliament preparatory action called ‘StratCom Plus’ (see Annex II). By their 
nature, preparatory actions are designed to prepare new actions like policies, 
legislation and programmes. Figure 3 illustrates how the added funding has been 
allocated to improving different capabilities. 

19  Complementary efforts to enhance resilience and counter hybrid threats – Council 

Conclusions (10 December 2019), Council document 14972/19. 

 
 
                                                      
Figure 3 – Funding by the 'StratCom Plus' preparatory action of different 
EEAS StratCom capacities (2018-2020) 

22 

Source: ECA, based on EEAS data. 

52 The importance of funding and adequate resourcing has been stressed on 
numerous occasions20, including by the European Parliament21, Member States22 and 
civil society23. However, stakeholders differ in their opinions about how to prioritise 
the available EU funding to fight disinformation. Based on our interviews, some 
Member States feel greater emphasis should be placed on analysing and monitoring 
those sources and actors to which disinformation can be more easily attributed. 
Others feel more funding should be allocated to positive communication. 

20  June 2018 European Council Conclusions and December 2019 Council Conclusions on 

complementary efforts to enhance resilience and counter hybrid threats. 

21  P8_TA(2019) 0187, P9_TA(2019) 0031. 

22  Information Manipulation: a Challenge for Our Democracies. A report by the Policy Planning 
Staff (CAPS, Ministry for Europe and Foreign Affairs) and the Institute for Strategic Research 
(IRSEM; Ministry of the Armed Forces) France, August 2018. 

23  For example, Democratic Defense against Disinformation, Atlantic Council, February 2018; 
GMF Policy Paper No.21, August 2019; Winning the Information War, CEPA, August 2016. 

 
 
 
                                                      
23 

Staffing needs not yet satisfied 

53 The EU action plan envisaged strengthening the StratCom division by adding
11 positions ahead of the European elections, recruiting permanent officials in the 
medium term and new staff in the EU delegations “to reach a total increase of 
50-55 staff members” by the end of 2020. The recruitment plan has been 
implemented in three phases: (1) redeployment of contract staff within the EEAS; (2) 
recruitment of staff to the StratCom team; and (3) addition of staff across 27 EU 
delegations in the EU neighbourhood. 

54 The StratCom division is still in the process of recruiting and deploying staff. As of
October 2020, it had 37 staff and had therefore not yet reached the total increase of 
50-55 staff, as stated in the EU action plan. One reason why it has been difficult to 
meet this target is that many StratCom staff are seconded from the Council, the 
Commission and the Member States and some have been withdrawn from their 
secondments.

55 Almost all staff reinforcements (including all the redeployments) have been
contract staff: the EEAS acknowledged that it is not easy to recruit permanent officials 
with the necessary expertise and skills needed to perform the duties required. 
However, despite their important contribution, contract staff have a maximum tenure 
of six years. 

56 The other group that makes up a significant portion of StratCom capacity is
seconded national experts. These have primarily supported the work of the East and 
recently also the Western Balkans StratCom task force. As well as benefitting the EEAS, 
their secondment benefits their home countries by allowing them to obtain more 
expertise and create deeper connections with the EEAS. However, overreliance on 
secondment can result in uncertainty in staffing and periodic loss of institutional 
memory and expertise due to frequent turnover. All of these factors potentially 
undermine the building of institutional memory and expertise. 

57 In light of the COVID-19 pandemic and the additional workload it has created for
the task forces, there is a risk that the EEAS, with the current distribution and number 
of staff, will have insufficient capacity to keep pace with new trends and developments 
like emerging threat sources and disinformation strategies and tactics. Moreover, the 
Council’s request to reinforce strategic communications work in other regions (see 
paragraph 10) may further stretch its limited staffing capacity. 

24 

58 Effective data analysis is critical not only for monitoring, detecting and analysing 
disinformation, but also as a basis for sound, evidence-based strategic insights and 
policy-making. At the time of the audit, the StratCom division’s data analysis cell 
includes full-time in-house analysts, who are supported by external contractors. The 
cell, launched in mid-2019, supports the work of the StratCom task forces and the 
rapid alert system (RAS) under pillar II of the EU action plan. Its analyses are 
predominantly on demand and ad hoc. In addition, its work is not integrated in a 
structured manner into the work of all the StratCom task forces. Although relying on 
external contractors can provide flexibility, in-house capacity is critical to provide 
sensitive analysis at short notice and to build institutional memory and expertise. 

Measuring the impact of the StratCom task forces’ work remains a challenge 

59 The greatest challenges in strategic communications remain measuring 
vulnerability to and the impact of disinformation, as well as efforts to understand, 
analyse and respond to it. The Commission uses opinion polling as one way to assess 
the effectiveness of strategic communications to influence perceptions about the EU. 
However, it is difficult to attribute the results of this polling to EU actions. 

60 Beyond the communication campaigns, the StratCom task forces did not 
comprehensively measure the impact of their work. Furthermore, none of them had 
an evaluation function to assess their effectiveness and identify areas for 
improvement. 

The hosting of EUvsDisinfo by the EEAS creates uncertainty about the project’s 
ultimate purpose 

61 EUvsDisinfo is the public face and flagship of the EU’s efforts to combat 
disinformation, and the East task force’s main anti-disinformation product. It has a 
searchable, open-source database, with more than 9 700 disinformation cases as of 
1 October 2020. Key materials on the EUvsDisinfo website are published in five EU 
languages; the rest is in English and Russian only. According to the EEAS, the original 
focus on Russian disinformation provided the foundation for a unique and pioneering 
approach; there are no comparable initiatives by Member State governments.  

62 From its beginnings in 2015, EUvsDisinfo has steadily built up visibility online (see 
Figure 4 below) by cataloguing, analysing and publishing examples of Russian 
disinformation. Many stakeholders confirmed that EUvsDisinfo has been instrumental 
in raising awareness and influencing perceptions about the Russian disinformation 
threat to the EU and its Member States. 

 
 
Figure 4 – EUvsDisinfo: Number of visitors, unique page views and 
Twitter and Facebook followers 

25 

Source: ECA, based on EEAS information. 

63 However, EUvsDisinfo has also faced criticism in the past. For example, it was 
censured by the Dutch parliament24 in 2018 for erroneously attributing Russian 
disinformation to a Dutch domestic publication. Furthermore, some cases published on 
EUvsDisinfo do not represent a threat to EU democracies. 

64 Looking ahead, the future role and mission of EUvsDisinfo are unclear, beyond 
producing more examples of Russian disinformation – a threat that is now well 
established and acknowledged. Despite the EEAS’s claims that EUvsDisinfo is 
independent and does not represent the EU’s official position, its location within the 
EEAS makes this questionable. This raises the question of whether such an instrument 
should be hosted and run by a public authority (such as the EEAS) or whether it should 
be run under the responsibility of a civil society organisation. 

24  Officiele bekendmakingen. 

 
 
 
                                                      
26 

The RAS has brought Member States together but has not lived up to its 
full potential 

65 The establishment of the rapid alert system (RAS) is the key action under pillar II 
of the EU action plan (action 3). As the plan states, “The first hours after 
disinformation is released, are critical for detecting, analysing and responding to it”. 
The RAS was established in March 2019, by the deadline set in the plan. It has two key 
elements: a network of national contact points and a web-based platform whose aim is 
to “to provide alerts on disinformation campaigns in real-time through a dedicated 
technological infrastructure” in order to “facilitate sharing of data and assessment, to 
enable common situational awareness, coordinated attribution and response and 
ensure time and resource efficiency”25. The EEAS provides the secretariat for the RAS 
and hosts the website. 

Although a useful tool for sharing information, the RAS had not yet issued alerts at 
the time of the audit and has not been used to coordinate common action 

66 In order to work effectively, the RAS must be able to issue timely alerts, 
coordinate common attribution and response and facilitate exchange of information 
between Member States and EU institutions. We examined whether the RAS had been 
operational before the 2019 European elections, as stipulated in the EU action plan. 
We also assessed its activity and the level of engagement of its participants. 

67 We found that the RAS was set up quickly in March 2019 as envisaged in the EU 
action plan. It has brought together Member States and EU institutions, and has 
facilitated information sharing, but it had not issued alerts at the time of the audit and 
has not coordinated common attribution and response as initially envisaged. 

68 Most stakeholders consulted during our audit had a positive view of the RAS. For 
them, it fills an important gap in the counter-disinformation ecosystem by creating a 
community. This was also confirmed by our survey of Member States: the RAS allows 
them to share information, obtain new insights and mutually strengthen their 
capabilities. Figure 5 below presents the aspects most valued by the national RAS 
contact points. 

25  RAS terms of reference. 

 
 
                                                      
Figure 5 – Member States’ ratings of importance of elements of the RAS 

27 

Source: ECA. 

69 Despite this positive opinion of the RAS as an information exchange tool, we 
found no evidence that the information shared through the RAS had triggered any 
substantial policy developments at Member State level. Building common situational 
awareness remains a work in progress for the RAS, hampered by the absence of 
harmonised and consistent definitions (e.g. of the term disinformation itself, and 
differing views on its sources, responses, levels of preparedness, etc.) and lack of 
common risk assessment. 

70 When the RAS was launched, providing real-time alerts to react swiftly to 
disinformation campaigns was considered its primary purpose, driven by the urgency 
of the upcoming European elections. For the StratCom team, however, the key aim 
was to bring practitioners together and develop a community, as no such mechanism 
previously existed in the EU. These differing motives have obscured understanding 
among stakeholders and the wider public of what the RAS does. 

71 An alert mechanism has been developed, which can be used in extremely urgent 
cases, but it had not been activated at the time of the audit. A threshold for triggering 
the alert system has been defined in qualitative terms: a disinformation campaign that 
has ‘transnational significant impact’ (i.e. a targeted attack on several countries). 
However, a quantitative assessment of this threshold is not possible. 

 
 
 
28 

72 In addition to the alert function, the RAS was conceived to help attribute 
disinformation attacks to their source and promote a coordinated response. However, 
this coordination capacity of the RAS has not been tested. 

Activity and engagement in the RAS are driven by a limited number of Member 
States 

73 The RAS brings together the contact points of the Member States, the 
Intelligence and Situation Centre of the EEAS, the European Commission (especially 
DGs CNECT, JUST and COMM), the European Parliament and the General Secretariat of 
the Council. Representatives from NATO, the G7 Rapid Response Mechanism 
participate in the rapid alert system. Outside experts, including from civil society and 
online platforms, are also sometimes present during RAS meetings. Generally, 
meetings of the national contact points take place every quarter, but the level of 
engagement varies between different Member States. Most activity is driven by one 
third of the Member States, which participate more regularly and are more active in 
the meetings. 

Latest statistics point to a downward trend in activity levels 

74 The statistics generated by the platform point to a number of trends. Firstly, 
activity is driven by a small number of core users, with other users being much more 
passive. Secondly, since its launch, activity levels have peaked around two main 
events: the European elections and the early weeks following the general lockdown in 
mid-March 2020. However, in the case of the latter, these have since come down and 
stabilised at the end of August 2020 at around half the levels in May. 

75 The user statistics point to a downward trend in activity levels. For example, 
average daily views – even in the specific parts of the RAS that focus on COVID-19 
disinformation – have declined, as shown in Figure 6. In addition, the number of 
actively engaged users has been in steady decline since the European elections in late 
May 2019. While these metrics do not tell the full story, they indicate clearly that the 
platform is not living up to its full potential. 

 
 
Figure 6 – Average number of RAS users from March 2019 to March 2020 

29 

Source: EEAS StratCom. The two drops in the user number is a result of the policy introduced in August 
to deactivate user accounts that have not been active for more than three months. 

Cooperation with online platforms and existing networks is mostly informal 

76 According to the EU action plan, online platforms should cooperate with the RAS 
contact points, in particular during election periods, to provide relevant and timely 
information. However, there is no protocol establishing cooperation between the RAS 
and the online platforms and as the StratCom team does not monitor the number of 
cases flagged, it is not possible to assess the RAS’s performance in this area. 

The code of practice made online platforms adopt a stance against 
disinformation but stopped short of making them accountable 

77 One of the main reasons why disinformation is so acute is the widespread use of 
the internet, combined with the advent of new technologies and the ever-increasing 
use of online platforms to access information. This greatly facilitates the creation, 
amplification and dissemination of false information. According to the Digital Economy 
and Society Index, in 2020, 85 % of EU citizens were internet users. Most platforms 
monetise their services through their handling of personal data (mainly based on 
advertising models). This created a fertile ground also for disinformation actors, 
allowing them to better target their actions. 

78 In the case of online platforms, disinformation occurs mostly as a result of users 
sharing false information, which can then be promoted by the platforms’ algorithms to 
prioritise the display of content. These algorithms are driven by the online platforms’ 
business model, and they privilege personalised and popular content, as it is more 
likely to attract attention. Disinformation also affects web search results, which further 

 
 
 
30 

hinders users in finding and reading trustworthy online information26. Picture 1 below 
shows an example of the search predictions provided by an online platform for the 
term “The EU is”, which are almost all negative. 

Picture 1 – Example of predictions from an online platform when 
searching for “The EU is” 

Source: ECA actual internet search on 18 October 2019 at 11:55 (GMT +1).  
Google is a trademark of Google LLC. 

79 Fake accounts, internet trolls and malicious bots also contribute to the 
dissemination of false information. 

The CoP provides a framework for the Commission to interact with social media 
platforms 

80 Following the April 2018 Commission communication and the HLEG proposals, 
the Commission decided to engage with online platforms and other trade associations 
on the subject of disinformation. This led to the creation of the code of practice (CoP) 
(see Annex V), adopting a voluntary approach based on self-regulation by the 
signatories. The CoP was signed in October 2018, before being incorporated into the 
EU action plan under pillar III. Presently it has 16 signatories. 

26  Automated Tackling of Disinformation, EPRS study, March 2019. 

 
 
 
                                                      
31 

81 The CoP committed online platforms and trade associations representing the 
advertising sector to submit reports to the European Commission setting out the state 
of play regarding measures taken to comply with their commitments. These measures 
ranged from ensuring transparency in political advertising to closing fake accounts and 
preventing purveyors of disinformation from making money. The Commission closely 
monitored their compliance with these commitments. 

82 Most of the stakeholders interviewed during the audit stressed that the 
Commission’s engagement with online platforms was a unique and necessary 
initiative. Many of those from outside the EU whom we consulted are observing the 
Commission’s efforts closely. They see the EU as the first global player trying to 
achieve the delicate balance between protecting freedom of expression and limiting 
malign spread of harmful disinformation. 

83 The CoP provided a framework for the Commission to interact with social media 
platforms ahead of the EU elections in May 2019 and later during the COVID-19 
pandemic to mitigate the negative effects of the related “infodemic”. Box 1 presents 
EU efforts to limit COVID-19 related disinformation through the CoP (see also 
Annex VI). 

Box 1 

EU efforts to limit the COVID-19 “infodemic” through the CoP 

In March 2020, when the impact of the COVID-19 pandemic became more 
apparent, meetings took place between the Commission and the social media 
platforms. The Commission requested that the platforms give more prominence to 
information from authoritative sources and remove false advertising. 

In June 2020, the European institutions published a joint communication entitled 
“Tackling COVID-19 disinformation - Getting the facts right”. The communication 
highlights the role of the EU action plan. 

 
 
 
32 

The signatories to the CoP presented their efforts through dedicated reporting, 
which was published in September27 and October 202028. Below are some 
examples of these efforts, taken from the platforms’ reports: 

o 

o 

o 

Google blocked or removed over 82.5 million COVID-19-related 
advertisements in the first eight months of 2020, and in August 2020 alone 
Microsoft Advertising prevented 1 165 481 ad submissions related to 
COVID-19 from being displayed to users in European markets. 

In August 2020, over 4 million EU users visited authoritative sources on 
COVID-19 as identified by search queries on Microsoft’s Bing. Facebook and 
Instagram reported that more than 13 million EU users visited their COVID-19 
“information centre” in July and 14 million in August.  

Facebook displayed misinformation warning screens associated with 
COVID-19-related fact-checks on over 4.1 million items of content in the EU in 
July and 4.6 million in August. 

Platforms have different moderation policies. Their reports have different formats 
and data are difficult to compare, as the terminology used by the companies 
differs. Facebook analyses “coordinated inauthentic behaviour” and “influence 
operations” while Twitter reports on “manipulative behaviour”. While Google and 
Microsoft reported removing millions of advertisements, Twitter stated that it did 
not find a single promoted tweet containing misinformation. Despite these 
discrepancies, the Commission considered that “In general, the reports provide a 
good overview of actions taken by the platforms to address disinformation around 
COVID-19”. 

The assessment of the CoP revealed limitations in the reporting requirements 

84 A number of reviews and evaluations have assessed the CoP. They revealed 
several shortcomings concerning the way the Commission established reporting 
requirements for the signatories to the CoP (see Box 2). These evaluations had not led 
to any changes in the CoP. 

27  First baseline reports – Fighting COVID-19 disinformation Monitoring Programme. 

28  Second set of reports – Fighting COVID-19 disinformation Monitoring Programme. 

 
 
                                                      
33 

Box 2 

Evaluations of the code of practice 

An initial assessment of the CoP, before it was signed, was made by the Sounding 
Board of the multi-stakeholder Forum on disinformation29 on 24 September 2018. 
It stated that: “…the “Code of practice”, as presented by the working group, 
contains no common approach, no clear and meaningful commitments, no 
measurable objectives or KPIs, hence no possibility to monitor progress, and no 
compliance or enforcement tool: it is by no means self-regulation, and therefore 
the Platforms, despite their efforts, have not delivered a Code of Practice.” Some 
elements of this opinion are still relevant today and were reflected in subsequent 
assessments and evaluation of the CoP. 

The European Regulators Group for Audiovisual Media Services (ERGA) presented 
an opinion on the CoP in April 202030. It identified three main weaknesses: 

o 

o 

o 

lack of transparency about how the signatories are implementing the CoP; 

CoP measures are too general in content and structure; 

limited number of signatories to the CoP. 

The Commission completed its own evaluation of the CoP in May 2020. Its overall 
conclusion was that the CoP had produced positive results31. The report stressed 
that the CoP had created a common framework and had improved cooperation 
between policymakers and the signatories. The main weaknesses it identified 
were: 

o 

o 

o 

its self-regulatory nature; 

lack of uniformity of implementation (uneven progress in monitoring); 

lack of clarity around its scope and some of the key concepts. 

The signatories themselves did not manage to prepare an annual review of the 
CoP as initially agreed. As the signatories do not have a common representative, 
coordination is time-consuming and informal, and reaching consensus on how this 
annual review will take place and who will conduct it has proven difficult. 

In September 2020, the Commission presented a staff working document32 taking 
stock of all evaluations of the CoP to date. It recognised that “it remains difficult to 
precisely assess the timeliness, comprehensiveness and impact of platforms’ 
actions”. The Commission has also identified the need for “commonly-shared 
definitions, clearer procedures, more precise and more comprehensive 
commitments, as well as transparent key performance indicators (KPIs) and 
appropriate monitoring”. 

 
 
34 

85 Our work confirms that signatories’ reporting varies, depending on their level of 
commitment and whether they are an online platform or a trade association. In 
addition, the online platforms’ reports are not always comparable and their length 
varies considerably. 

86 This variation among signatories to the CoP also proved to be a problem for 
setting overall KPIs. These KPIs made it possible to monitor the actions of some 
signatories, but not all. For example, under the heading “Integrity of services”, the 
Commission proposed the indicator “Number of posts, images, videos or comments 
acted against for violation of platform policies on the misuse of automated bots”. This 
output indicator is relevant for specific online platforms only. 

87 According to the Commission’s own analysis of the CoP signatories’ reports, the 
metrics provided so far satisfy only output indicators. For example, platforms report 
that they have rejected advertisements, or removed a number of accounts or 
messages that were vectors of disinformation in the context of COVID-19 (see also 
Box 1). If this reported information is not put into context (i.e. by comparing it, in time, 
against baseline data and other relevant information such as the overall creation of 
accounts), and the Commission cannot verify its accuracy, it is of limited use. 

88 The assessment of the CoP conducted on behalf of the Commission not only looks 
at the current state of the reporting but also recommends possible metrics for the 
future. The document proposes two levels of indicators: 

(i) 

‘structural’ indicators for the code as a whole, measuring overall outcomes, the 
prevalence of disinformation online and the code’s impact in general. These help 
to monitor, at a general level, whether disinformation is on the rise, stable or 
declining; 

(ii)  tailored ‘service-level’ indicators, broken down by pillar, to measure each 
individual signatory platform’s results in combatting disinformation. 

29  Multi-stakeholder forum on disinformation. 

30  ERGA Report on disinformation: Assessment of the implementation of the Code of Practice. 

31  Commission’s own evaluation of the code of practice. 

32  Assessment of the Code of Practice on Disinformation – Achievements and areas for further 

improvement. 

 
 
                                                      
35 

At the time of the audit, the Commission had not provided signatories with any new 
reporting template or more meaningful new indicators. 

89 The issues described above show that online platforms are not held accountable 
for their actions and their role in actively tackling disinformation. 

Lack of a coherent media literacy strategy and fragmentation of EU 
actions dilutes their impact 

90 Pillar IV of the EU action plan focuses on raising awareness and strengthening 
societal resilience to disinformation. It aims to improve media literacy actions, such as 
the 2019 Media Literacy Week, and to support independent media and investigative 
journalists. It also calls on Member States to rapidly implement the media literacy 
provisions of the Audio-Visual Media Services Directive and create teams of multi-
disciplinary independent fact-checkers in light of the 2019 European elections. 

91 Media literacy’ refers to skills, knowledge and understanding that allow citizens 
to use media effectively and safely and equip them with the critical thinking skills 
needed to exercise judgment, analyse complex realities and distinguish between 
opinion and fact33. Responsibility for media literacy, which lies at the cross-section of 
education policy and the EU’s digital agenda, lies with the Member States. The 
Commission’s role is to foster collaboration and facilitate progress in the area. 
Disinformation does not respect borders, however, and developing common tools and 
sharing best practices at EU level are important. 

92 In order to assess the actions under this pillar, we examined the 2019 EU Media 
Literacy Week event, and whether there was a well-defined strategy for the various 
initiatives in this area. We reviewed the Commission’s report on the 2019 European 
elections34 and assessed 20 projects directly related to media literacy and fighting 
disinformation. 

93 The Commission’s report on the 2019 European elections stated that “[while] 
manipulative efforts recurrently focused on politically sensitive topics and targeted EU 
audiences ahead of the elections, no large-scale covert interference operation in the 
2019 elections has been identified so far”. 

33  Audiovisual Media Services Directive (AVMSD) (EU) 2018/1808. 

34  COM(2020) 252 final of 19 June 2020. 

 
 
                                                      
36 

Member States do not participate evenly in the EU Media Literacy Week 

94 European Media Literacy Week is a series of actions to raise awareness about 
media literacy across the EU (see Box 3). It is unclear how it reflects a coherent EU 
media literacy strategy, however; although it includes some high-level discussions, it 
mainly serves to illustrate some specific EU and Member State initiatives. The 2020 
edition was to be jointly organised between the Commission and the Council, which 
could have further stimulated Member State action and participation. However, it was 
cancelled due to COVID-19. 

Box 3 

European Media Literacy Week 

The 2019 Media Literacy Week was one of two specific media literacy actions in 
the EU action plan. It took place in March 2019 in Brussels and in Member States, 
and included a high-level conference. Over 320 events were organised at the time, 
and in total 360 events had been organised up to the end of September 2020. 

Nearly half of all events took 
place in France, with Belgium 
(mostly Brussels) a distant 
second. A small number of 
Member States did not host 
any events at all – as the 
geographical distribution of 
the events shows (see picture 
opposite). As would be 
expected, most events took 
place around the time of the 
official launch. However, no 
further statistics are available 
on the number of people 
these events reached, their 
thematic distribution and the 
extent to which they dealt 
specifically with 
disinformation. 

Source: ECA, based on Commission data. 

 
 
37 

There is no overarching media literacy strategy that includes tackling disinformation 

95 We found there were a multitude of EU and Member State initiatives that 
addressed media literacy, and a plethora of policy documents. This is also clear from 
the Council Conclusions on media literacy35, which include an annex with the main 
policy documents. However, these actions are not coordinated under an overarching 
strategy for strengthening societal resilience, particularly in media literacy, which 
would include tackling disinformation. While actions to address Member States’ 
specific challenges on media literacy are also important in order to achieve local 
impact, EU support for media literacy lacks the following underlying elements, which 
would be conducive to its sound financial management: 

o 

o 

o 

a regular update , in cooperation with the Media Literacy Expert Group (MLEG), of 
the most important media literacy practices and actions in the EU and Member 
States (the Council of Europe produced such a mapping in 2016, the first of its 
kind; however, it has not been updated since then36); 

clear objective-setting based on systematic and regular research into media 
literacy and the impact of media and digital platforms, accompanied by a set of 
indicators to measure performance; 

the necessary coordination mechanisms to create synergies and avoid overlap 
between initiatives and actions under, for example, the Audio-Visual Media 
Services Directive, the digital education action plan, the Creative Europe 
Programme, the digital competence framework and skills agenda, the recently 
published European democracy action plan and the Digital Services Act, the media 
and audiovisual action plan, etc.; 

o 

unified monitoring of EU media literacy initiatives. 

96 For the next multi annual financial framework (2021-2027), according to the 
Commission, approximately €14 million in EU funding from the Creative Europe 
programme37 – €2 million per year – has been earmarked to support media literacy. 

35  See Annex to Council conclusions on media literacy in an ever-changing world 

(2020/C 193/06). 

36  Mapping of media literacy practices and actions in EU-28, European Audio-visual 

Observatory, Council of Europe, January 2016. 

37  Out of a total proposed budget of €61 million of the Cross-sectoral strand of the Creative 

Europe programme (budget line 07 05 03). 

 
 
                                                      
38 

However, as the Council Conclusions on media literacy also state, it will be necessary 
to develop additional funding sources. 

Most projects examined produced tangible results, but many did not demonstrate 
sufficient scale and reach 

97 Of the 20 projects we assessed, ten were funded under Horizon 2020, and the 
other ten were pilot projects and preparatory actions funded by the European 
Parliament (see table in Annex III). 

98 The ‘Media Literacy for all’ call for proposals, launched in 2016 by the European 
Parliament, includes pilot projects and preparatory actions for co-financing innovative 
start-up ideas from across the EU in the field of media literacy. A pilot project runs for 
two years, followed by a three-year preparatory action. The Horizon 2020 projects are 
research and innovation projects covering highly technical aspects of tackling 
disinformation, such as the use and detection of bots or developing a new generation 
of content verification tools. 

99 Our analysis (see Annex III) found tangible results in 12 out of 20 projects. Most 
positive results were achieved by projects that built on the results of previous projects 
to produce tools related to fact-checking, or by projects to create teaching and 
learning material against disinformation (see Box 4). 

Box 4 

Examples of EU-funded projects achieving positive results 

Based on the theoretical research of project 2, which investigated how the 
information generated by algorithms and other software applications is shared, 
project 1 produced, as a proof of concept, an interactive web tool designed to 
help increase transparency around the nature, volume, and engagement with false 
news on social media, and to serve as a media literacy tool available to the public.  

Project 11 set out to create an educational, multilingual (eight EU languages), 
crowdsourced online platform for teaching and learning about contemporary 
propaganda. This action was accompanied by sets of contextualised educational 
resources, and online and offline workshops and seminars for teachers, librarians 
and media leaders. The project was well set up and produced tangible results, 
with active participation from six EU countries. Even though the project ended on 
1 January 2019, its platform and resources remain active. 

 
 
39 

100 However, we identified shortcomings in 10 out of the 20 projects, which 
concerned mostly their small scale and limited reach. Seven projects did not or are 
unlikely to reach their intended audience, and the results achieved by three projects 
were difficult to replicate, which limited their impact. Box 5 presents a number of 
projects illustrating these issues: 

Box 5 

Examples of EU-funded projects with limited reach or scale of actions 

Project 10 set out to create a system for automatically detecting false information 
from the way it is spreading through social networks. The project was successful, 
and an online platform soon recruited the project manager and the people 
involved in the project, acquiring the technology. This is evidence of a well-
identified research project that produced good results. However, its subsequent 
acquisition by an American online platform has limited the targeted audience it 
would benefit and does not contribute to the development of an independent EU 
capability in this sector. 

One other project (14) focused on the representation of women in the media. It 
existed as an online portal presenting news that women journalists and editors 
found most relevant in their regions while at the same time trying to fact-check 
news on women’s and minority issues. Although the project reached a 
considerable audience via Facebook and Twitter with its gender theme, its main 
output was a website that is no longer available. 

Another project (16) was also supposed to develop social skills and critical 
thinking. It was composed of various heterogeneous parts that focused on 
creativity, with no clear connection between them and a loose conceptual link to 
media literacy. For example, children in schools created animation or simple 
games about cleaning a school gym or protecting a vending machine. The planned 
activities cannot be easily reproduced. 

101 Overall, there was little evidence of any comparative analysis of project results 
– especially in terms of what had worked and why. Nor was there much evidence of 
the Commission coordinating the exchange of best practice and media literacy 
material across the EU. An evaluation framework is also lacking. Such a framework is 
critical to the long-term development of societal resilience, as it ensures that lessons 
learned feed directly into future actions, policy and strategy. Obtaining evidence of the 
direct impact of media literacy measures is difficult, and efforts are still at an early 

 
 
40 

stage of development38. The Council Conclusions on media literacy also called for the 
development of systematic criteria and evaluation processes, and a uniform and 
comparative methodology for Member States’ reporting on the development of media 
literacy39. 

The SOMA and EDMO projects attracted limited interest from media literacy experts 
and fact-checkers 

102 As the EU action plan states under pillar IV, independent fact-checkers and 
researchers play a key role in furthering the understanding of the structures that 
sustain disinformation and the mechanisms that shape how it is disseminated online. 
The Commission financed the Social Observatory for Disinformation and Social Media 
Analysis (SOMA) project, a digital platform with the aim of forming the basis for a 
European network of fact-checkers. SOMA is funded under Horizon 2020, with an 
overall budget of nearly €990 000. The project started in November 2018 and is 
scheduled to end on 30 April 2021. 

103 Our analysis revealed that SOMA managed to attract only two fact-checkers 
recognised by the International Fact Checking Network40. At the time of the audit 
(October 2020), SOMA had 48 registered members. Several of those we contacted 
admitted to never using the SOMA platform. While the technology behind SOMA has 
been evaluated positively, the project is still not widely used by the fact-checking 
community. 

104 Well before the end of the SOMA project, and without waiting for an 
evaluation to collect and apply lessons learned, the Commission in June 2020 launched 
the first phase (worth €2.5 million, running until the end of 2022) of the European 
Digital Media Observatory (EDMO). It aims to strengthen societal resilience by bringing 
together fact-checkers, media literacy experts, and academic researchers to 
understand and analyse disinformation, in collaboration with media organisations, 
online platforms and media literacy practitioners. 

105 SOMA and EDMO therefore have partially overlapping objectives, and most 
contractors are involved in both projects at the same time. The evaluators of SOMA 
suggested merging the two projects but no formal links between them have yet been 

38  Exploring Media Literacy Education as a Tool for Mitigating Truth Decay, RAND Corporation, 

January 2019. 

39  Council conclusions on media literacy in an ever-changing world (2020/C 193/06). 

40  Created by the Poynter Institute. Presently, it has 82 active members. 

 
 
                                                      
41 

established. There is also a risk of overlap in their financing, as both projects are based 
on and use the same technology and commercial products. 

106 EDMO has been presented as a holistic solution to tackling many of the societal 
challenges around disinformation. However, being in its infancy, its visibility among 
stakeholders is still limited, according to its management. It is too early to judge the 
effectiveness of EDMO. Nevertheless, given the limited awareness of EDMO among 
stakeholders, its achievements may not match its overly ambitious goals. Its current 
focus is on building up the necessary infrastructure, and it will need more resources to 
succeed in its aims. 

107 The media literacy experts we interviewed commented that the media literacy 
community was not feeling sufficiently engaged with EDMO. EDMO’s advisory board 
features a broad array of expertise from across academia and journalism, reflecting the 
EU action plan’s key emphasis on strengthening fact-checking and supporting 
journalism. However, the media literacy community or civil society, who could provide 
useful links between academia and policy-making are under represented (two out of 
19 experts). 

 
 
 
 
42 

Conclusions and recommendations 

108 We examined whether the EU action plan against disinformation was relevant 
when drawn up and delivering its intended results. We conclude that the EU action 
plan was relevant but incomplete, and even though its implementation is broadly on 
track and there is evidence of positive developments, some results have not been 
delivered as intended. 

109 We found that the EU action plan was consistent with experts’ and 
stakeholders’ views and priorities. It contains relevant, proactive and reactive 
measures to fight disinformation. However, even though disinformation tactics, actors 
and technology are constantly evolving, the EU action plan has not been updated since 
it was presented in 2018. In December 2020, the Commission published the European 
democracy action plan, which includes actions against disinformation, without 
clarifying exactly how it relates to the EU action plan against disinformation (see 
paragraphs 20-24 and 41-42). 

110 The EU action plan does not include coordination arrangements to ensure that 
EU responses to disinformation are coherent and proportionate to the type and scale 
of the threat. Each of the EU action plan’s pillars is under the responsibility of a 
different Commission Directorate-General or the European External Action Service, 
without any single body being in charge or having complete oversight of 
communication activities (see paragraphs 25-31). 

111 There is no monitoring, evaluation and reporting framework accompanying the 
EU action plan and the European democracy action plan, which undermines 
accountability. In particular, the plans include generic objectives that cannot be 
measured, several actions that are not time-bound and no provisions for evaluation. 
Only one report on the implementation of the EU action plan has been published, with 
limited information on performance. Without a comprehensive, regular review and 
update, it is difficult to ensure that EU efforts in this area are effective and remain 
relevant. Furthermore, there was no comprehensive information on the funding 
sources and the estimated costs of the planned actions (see paragraphs 32-40). 

 
 
43 

Recommendation 1 – Improve the coordination and 
accountability of EU actions against disinformation 

The European Commission should improve the coordination and accountability 
framework for its actions against disinformation by incorporating:  

  clear coordination and communication arrangements between the relevant 

services implementing the EU actions against disinformation; 

  a dedicated monitoring and evaluation framework containing clear, measurable 

and time-bound actions, as well as indicators to measure performance and 
evaluation provisions; 

regular reporting on the implementation of the actions, including any necessary 
updates; 

  a summary of the main funding sources and expenditure made in implementing 

the actions. 

Timeframe: end of 2021 for recommendations a) and b) and mid 2023 for 
recommendations c) and d) 

112 Under pillar I of the EU action plan the three EEAS strategic communication 
task forces have improved the EU’s capacity to forecast and respond to disinformation 
activities and have contributed substantially to effective communication and 
promoting EU policies in neighbouring countries. The task forces’ mandates do not 
adequately cover the full range of disinformation actors, including new emerging 
threats (see paragraphs 45-49). 

113 Staffing of the task forces largely depends on the secondment of national 
experts, making it more difficult for the EEAS to manage and retain staff. The StratCom 
team has not yet met its recruitment targets, and the COVID-19 crisis has created 
additional workload. Furthermore, the task forces have no evaluation function to 
assess their effectiveness and identify areas for improvement (see paragraphs 53-58 
and 60). 

 
 
 
44 

Recommendation 2 – Improve the operational arrangements of 
the StratCom division and its task forces 

The EEAS should: 

  bring emerging disinformation threats to the Council’s attention. It should then 

review and clarify the policy objectives to be achieved by strategic 
communications division and its task forces. 

  reach the recruitment targets set in the EU action plan; 

focus its human resources on the most sensitive tasks, such as threat analysis and 
threat evolution, and outsource less sensitive communication activities where 
these cannot be done in-house due to staff shortages; 

  undertake regular evaluations of the task forces’ operational activities, beyond 

their communication campaigns. 

Timeframe: mid 2022 

114 EUvsDisinfo has been instrumental in raising awareness about Russian 
disinformation. However, its placement inside the EEAS raises some questions about 
its independence and ultimate purpose, as it could be perceived as representing the 
EU’s official position (see paragraphs 61-64). 

115 Under pillar II, the EEAS quickly set up the rapid alert system (RAS). We found 
that the RAS had facilitated information sharing among Member States and EU 
institutions. However, the RAS has never issued alerts and, consequently, has not been 
used to coordinate joint attribution and response as initially envisaged. Furthermore, 
the latest statistics show that activity and engagement in the RAS are driven by a 
limited number of Member States. There is a downward trend in activity levels and 
cooperation with online platforms and existing networks is mostly informal. 
Additionally, there is no protocol establishing cooperation between the RAS and the 
online platforms (see paragraphs 65-76). 

 
 
 
45 

Recommendation 3 – Increase participation in the RAS by 
Member States and online platforms 

The EEAS should: 

  request detailed feedback from Member States on the reasons for their low level 

of engagement and take the necessary operational steps to address them; 

  use the RAS as a system for joint responses to disinformation and for coordinated 

action, as initially intended; 

  propose to the online platforms and the Member States a framework for 

cooperation between the RAS and the online platforms. 

Timeframe: mid 2022 

116 The one action under pillar III is about ensuring continuous monitoring of the 
code of practice (CoP). It sets out a number of voluntary measures to be taken by 
online platforms and trade associations representing the advertising sector. With the 
CoP, the Commission has created a pioneering framework for engagement with online 
platforms. During the initial stages of the COVID-19 pandemic, the CoP led the 
platforms to give greater prominence to information from authoritative sources. 

117 Our assessment of the CoP and the Commission’s evaluations revealed 
different reporting from the platforms, depending on their level of commitment. 
Moreover, the metrics that the platforms are required to report satisfy only output 
indicators. Platforms do not provide access to data sets, so that the Commission 
cannot verify the reported information. Consequently, the CoP falls short of its goal to 
hold online platforms accountable for their actions and their role in actively tackling 
disinformation (see paragraphs 77-89). 

 
 
46 

Recommendation 4 – Improve the monitoring and 
accountability of online platforms 

Building on recent initiatives such as the new European democracy action plan, the 
Commission should: 

  propose additional commitments to the signatories to address weaknesses 

identified in the evaluations of the code of practice; 

improve the monitoring of the online platforms’ activities to tackle disinformation 
by setting meaningful KPIs; 

  establish a procedure for validating the information provided by online platforms. 

Timeframe: end of 2021 

118 Under pillar IV of the EU action plan, we found there were a multitude of EU 
and Member State media literacy initiatives, and a plethora of policy documents, 
which are not organised under an overall media literacy strategy that includes tackling 
disinformation (see paragraph 95). 

119 Most activities during the 2019 EU Media Literacy Week took place in just two 
Member States, which substantially limited the initiative’s awareness-raising potential. 
Our analysis of a sample of 20 projects addressing disinformation found tangible 
results in 12 projects. Most positive results were achieved by projects that built on the 
results of previous projects to produce fact-checking tools or teaching material. The 
key shortcomings identified in 10 projects relate to the small scale and reach of their 
activities (see Box 3, paragraphs 94 and 97-101). 

 
 
 
47 

Recommendation 5 – Adopt an EU media literacy strategy that 
includes tackling disinformation 

The Commission should adopt a media literacy strategy that includes combatting 
disinformation as an integral part. In order to better target disinformation through 
media literacy actions and reduce their fragmentation, this strategy should include: 

  a regular update, in cooperation with the Media Literacy Expert Group (MLEG), of 
the most important media literacy practices and actions in the EU and Member 
States; 

  clear objective setting based on systematic and regular research into media 

literacy and the impact of media and digital platforms, accompanied by a set of 
indicators to measure performance; 

the necessary coordination mechanisms to create synergies among projects. 

Timeframe: end of 2022 

120 Independent fact-checkers and researchers play a key role in furthering the 
understanding of disinformation. So far, the Commission’s efforts to develop a 
European network of fact-checkers (the Social Observatory for disinformation and 
Social Media Analysis (SOMA)) have not managed to attract much awareness from this 
community. The European Digital Media Observatory (EDMO) is supposed to replace 
SOMA, but both projects were running in parallel at the time of the audit. EDMO’s 
visibility among stakeholders is still limited, which contrasts with its ambition of 
providing a holistic solution to the societal challenges around disinformation. 
Furthermore, the media literacy community and civil society, who could provide 
important links between academia and policy-making, are not well represented on 
EDMO’s advisory board (see paragraphs 102-107). 

 
 
 
48 

Recommendation 6 – Take steps to enable EDMO to fulfil its 
ambitious objectives 

To ensure that EDMO meets its ambitious objectives, the Commission should: 

collect lessons learned from the SOMA project once it has ended and apply them 
in EDMO; 

increase the representation of media literacy and civil society experts in EDMO’s 
advisory board; 

increase awareness of EDMO among stakeholders, in particular fact-checkers 
and media literacy experts. 

Timeframe: end of 2021 

This Report was adopted by Chamber III, headed by Mrs Bettina Jakobsen, Member of 
the Court of Auditors, in Luxembourg on 27 April 2021. 

For the Court of Auditors 

Klaus-Heiner Lehne 
President 

49 

Annexes 

Annex I — Main EU institution departments and offices fighting 
disinformation 

European External Action 
Service (EEAS) 

Responsibilities 

Responsible for the StratCom Task Forces (East StratCom Task 
Force since 2015 and since mid-2017 the South Task Force covering 
the Middle East and North Africa region (May 2017), and the 
Western Balkans Task Force covering the Western Balkans 
(July 2017). The EEAS is also responsible for maintaining and 
moderating the digital platform of the Rapid Alert System, and 
strengthening detection and analytical capabilities. In 2020, it 
created a new Strategic Communications Division, comprising the 
Task Forces and other relevant capabilities. 

The Directorate-General for 
Communications Networks, 
Content and Technology 
(DG CNECT) 

Leads the activities relating to the Code of Practice, the creation of 
an independent network of fact-checkers and researchers, and 
actions in support of media literacy and cybersecurity. DG CNECT 
also implements projects financed by the European Parliament and 
R&I projects financed under the H2020 program. 

Directorate-General for 
Communication (DG COMM) 

Responsible for the Network against Disinformation (an internal 
forum of close collaboration across all Directorate Generals, the 
EEAS, European Parliament and EU Representations in Member 
States). Also responsible for proactive and objective 
communication on EU values and policies and raising public 
awareness activities. 

Directorate-General for 
Justice and Consumers 
(DG JUST) 

Contributed on fundamental rights and democracy aspects to the 
main outputs relating to disinformation. Led on the preparation of 
the Commission’s electoral package which was issued in 
September 2018 (the “Election package”) 

Secretariat General of the 
European Commission 

Tasked with coordinating the implementation of the actions from 
the EU action plan. 

European Parliament 
(DG Communications) 

Part of the internal coordination network, drafts counter narratives 
and funds preparatory actions to be implemented by the EEAS and 
MS via direct management. 

Commission Representations 

European Parliament liaison 
offices 

Source: European Commission. 

Provide locally-tailored messaging, including specific tools to 
counter myths and disseminate facts 

 
 
 
 
Annex II — EU spending on actions against disinformation (in euros) 

Entity

Budget line

Financed under

Title

19 06 01

Commission prerogative (FPI)

Information Outreach on EU External Relations

EEAS

DG CNECT

ERC

FPI

DG JUST

19 06 77 01

Preparatory Action (FPI)

1200

2214

EEAS

EEAS

09 04 02 01

Horizon 2020

09 03 03

CEF - Telecom

09 05 77 04

Pilot Project

09 05 77 06

Prepratory Action

08 02 01 01

Horizon 2020

19 02 01 00

IcSP

33 02 01

33 02 01

REC programme

REC programme

Preparatory Action "StratCom Plus"

Contract staff
Strategic Communication Capacity

Leadership in information and communications technology

3 115 736

2 879 250

10 885 524

European Digital Media Observatory

Pilot Project "Media literacy for all"

Preparatory Action "Media literacy for all"

Strengthening frontier research in the European Research Council

Countering disinformation in southern and eastern Ukraine

Study on the impact of new technologies on free and fair elections
Promotion activities for EU citizenship rights (e.g. an event for the cooperation network on elections or 
related to the citizenship report) 

245 106

500 000

1 980 112

1 931 730

149 921

499 290

150 000

2015

2016

2017

2018

2019

2020

Budget Allocation

1 187 000

1 100 000
1 128 942

298 200

3 000 000
2 098 697

4 000 000
2 159 748

50 

Total

298 200

8 100 000

6 574 387

800 000

2 000 000

2 000 000

4 800 000

34 02 01

REC programme

Studies and research into specific areas concerning Union Citizenship (Network of Academics and others)

16 03 02 03

Operational budget

DG COMM

16 03 01 04

Operational budget

Online and written information and communication tools
Communication of the Commission Representations, Citizens’ Dialogues and ‘Partnership’ actions

08 02 05 00

Corporate budget

Horizontal activities of Horizon 2020

DIGIT for EEAS

26 03 77 09 

Preparatory action "Data Analytics 
Solutions for policy-making"

TOTAL

Source: ECA on information provided by the Commission and the EEAS. 

5 095 848

2 176 836

4 716 171

14 563 756

10 634 134

12 163 997 49 350 742

16 880 510

2 500 000

2 500 000

745 106

500 000

500 000

1 499 290

1 934 213

350 000

91 603

110 000

251 421

4 211 763

1 934 213

350 000

376 000

376 000

434 000

62 249
132 000

434 000

153 852
132 000

110 000

251 421

Annex III — Assessment of projects against disinformation (Pilot Projects, Preparatory Actions, H2020) 

Project 
number 

Type of 
Project 

Countries 

Project Duration 
(Actual) 

Status 

Direct link 
with other 
projects 

Grant Amount 
(in euro) 

Was the Commission's monitoring adequate? 

Criterion 1  
Relevance to disinformation 

Criterion 2  
Tangible and sustainable results 

Criterion 3 
Sufficient scale and reach 

51 

H2020 

United Kingdom (targets: 
Germany, France, Poland, 
Sweden, United Kingdom / 
Brazil, Canada, China, Mexico, 
Russia, Ukraine, United States, 
Taiwan) 

Jan. 2016 - Dec. 2020 

Ongoing 

Yes 

1 980 112 

There is both a continuous reporting and independent 
reporting in the form of an audit and a scientific report.  

H2020 

United Kingdom  

July 2017 - Jan. 2019 

Ended 

Yes 

149 921 

There is both a continuous reporting and an 
independent reporting in the form of an audit.  

H2020 

Greece  

Jan. 2016 - Dec. 2018 

Ended 

Yes 

3 115 737 

There is an independent expert opinion and review 
reports. 

H2020 

Italy 

Jan. 2018 - Dec. 2020 

Ongoing 

No 

2 879 250 

The project is still on-going. There is continuous 
reporting with a first assessment.  

H2020 

Ireland, Greece, Italy, Cyprus, 
Austria, Portugal, Romania, 
United Kingdom  

Jan. 2018 - Nov. 2021 

Ongoing 

Yes 

2 454 800 

An independent, remote review was carried out in July 
2020 which was facilitated by DG CNECT. 

H2020 

Czechia, Ireland, Spain, Austria 

Dec. 2018 - Nov. 2021 

Ongoing 

Yes 

2 753 059 

H2020 

France, Italy, Poland, Romania, 
United Kingdom  

Dec. 2018 - Nov. 2021 

Ongoing 

Yes 

2 505 027 

H2020 

Denmark, Greece, Italy 

Nov. 2018 - April  
2021 

Ongoing 

Yes 

987 438 

An independent, remote review are being carried out 
(started in August 2020). 
Three individual evaluations were conducted in 
December 2019 and an overall assesment was 
conducted in February 2020. Additionally, between 
January and April 2020, a project review was carried 
out. 
The Project was reviewed by 3 independent monitors, 
and evaluated by the Project Officer. 

H2020 

Belgium, Bulgaria(C), Germany, 
Greece, France, United 
Kingdom  

Dec. 2018 - Nov. 2021 

Ongoing 

Yes 

2 499 450 

No input and no coordinating effort from the 
Commission in the beginning. 

The project produced mainly research papers. Most of 
the presentations of these papers have taken place 
outside of the EU. With the UK having left the EU, it is 
unclear how this research will still benefit the EU.   

There is no indication that the project will go beyond 
a proof of concept and if it does, it is not clear 
whether the public will benefit from it as much as the 
private sector if the end product is commercialized.  
The tool produced by the project catered mostly to 
experts and was not user friendly enough for the 
general public (two subsequent projects were needed 
to refine results and to enhance the scale and reach 
of the project). 

Weaknesses in the implementation of the 
dissemination and business exploitation strategies. 

There is uncertainty on how the centralised, online 
platforms will engage with the tool. 

There is a weakness as one of the 
software components is dated and the 
project is not using state of the art 
methods in this area. 
A well-managed project but some 
corrective action is needed to focus on 
key components, and a more detailed 
elaboration of dissemination and 
exploitation. 

The project is still ongoing in parallel with 
a similar project in the field. 
Results are being tested at the prototype 
stage. This can entail risks. No guidance 
from the Commission and ideas on how 
results will be sustainable are limited to 
partner initiatives linked with their own 
individual contacts/ partners/ clientiele.  

H2020 

Switzerland/United Kingdom  

Sep. 2018 - Nov. 2019 
(initially Feb. 2020) 

Ended 

Pilot Project 

Pilot Project 

Pilot Project 

Belgium, Romania,  France, 
Croatia, Poland, Finland, United 
States 
Spain, Italy, Malta, Portugal, 
United Kingdom 
Belgium, Greece, Spain, Italy, 
Latvia, Lithuania, Hungary, 
Malta, Austria, Poland, 
Portugal, Romania, Slovakia  

Jan. 2018 – Jan. 2019  

Ended 

2016 

2017 

Ended 

Ended 

Pilot Project 

Poland 

July 2018 – June 2019 

Ended 

Pilot Project 

Belgium, Austria, Portugal 

2017 

Ended 

Pilot Project 

Preparatory 
Action 

Preparatory 
Action 

Denmark, Ireland, Greece, 
Cyprus, Portugal 

Belgium, Bulgaria, Germany, 
Spain, Croatia, Romania, Italy, 
Latvia  
Denmark, Germany, Spain, 
France, Italy, Netherlands, 
Poland, Finland 

Preparatory 
Action 

Spain, France, Romania, 
Sweden   

July 2018 – June 2019 

Ended 

July 2019 - Aug. 2020  
Extension discussed 

Ongoing 

2018 

2018 

Ongoing 

Ongoing 

Yes 

No 

Yes 

No 

No 

No 

No 

No 

Yes 

Yes 

Preparatory 
Action 

Greece, Spain, Lithuania, 
Finland 

Aug. 2019 - Aug. 2020 
(extension discussed) 

Ongoing 

No 

86 630 

150 000 

125 000 

171 057 

118 445 

127 590 

122 815 

131 150 

At the request of the Court the project officer worked 
well to collect the information needed on establishing 
how the results were exploited.  

The project was monitored with various qualitative and 
quantitative indicators. 

Commission monitoring was not evident. 

Continuous reporting and a technical report and 
independent Final evaluation were produced. 

Results exploited mainly by an American company. 

Sustainable training courses were only 
developed in one country out of five. 

Limited reach of the projects's results. 

Sustainability concerns. In its final self assessment the 
project highlighted the absence of an overall media 
literacy strategy.  

There is only one page assessment that does not 
analyse the outcomes. 

The project mixes fact checking with 
women's rights and sexism and the 
relevance to disinformation is weak. 

The website created by the project is no 
longer operational. 

There is no proof of on ongoing monitoring. The final 
assesment is 133 words long and does not include any 
recommendations. 

The project deals with creative thinking in 
general. 

The outputs/outcomes are not 
measurable. 

The project was a stand-alone exercise and cannot be 
easily reproduced or continued 

The brainstorming and white papers were 
done but there is no toolkit. 

The project was aborted due to insolvency of the 
coordinator. 

124 546,72 

An interim technical implementation report was 
produced. 

214 556 

159 380 

The project monitored actions closely with clearly 
defined indicators. 

The project is still on-going and the technical report is 
of good quality. There will be also an independent 
report.  

The reporting required only one mid-evaluation report 
after seven months. Some documentation was not 
immediately available and had to be sent by post.  

The project is finding it difficult to bridge a financing 
gap. 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

Not fulfilled 
Partly fulfilled 
Fulfilled 
N/A 

Source: ECA. 

 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
 
Annex IV — Assessment of the actions included in the EU action plan on Disinformation 

EU Action Plan 

Is the Action clearly defined? 

Is the Action time bound? 

Responsibility 

52 

Action 5: The Commission and the High Representative, in cooperation with Member States, 
will strengthen strategic communications in the Union’s neighbourhood. 

No – it is not clear how the strategic communications can be 
strenghtened 

No deadline 

Action 1: With a view to the 2019 European Parliament elections in particular, but also with a 
longer-term perspective, the High Representative, in cooperation with the Member States, will 
strengthen the Strategic Communication Task Forces and Union Delegations through additional 
staff and new tools which are necessary to detect, analyse and expose disinformation activities. 
Member States should, where appropriate, also upgrade their national capacity in this area, and 
support the necessary increase in resources for the Strategic Communication Task Forces and 
Union delegations. 
Action 2: The High Representative will review the mandates of the Strategic Communications 
Task Forces for Western Balkans and South to enable them to address disinformation effectively 
in these regions. 
Action 3: By March 2019, the Commission and the High Representative, in cooperation with 
Member States, will establish a Rapid Alert System for addressing disinformation campaigns, 
working closely with existing networks, the European Parliament as well as the North Atlantic 
Treaty Organisation and G7’s Rapid Response Mechanism. 
Action 4: With a view to the upcoming European elections, the Commission, in cooperation with 
the European Parliament, will step up its communication efforts on Union values and policies. 
Member States should significantly strengthen their own communication efforts on Union 
values and policies. 

Action 6: The Commission will ensure a close and continuous monitoring of the implementation 
of the Code of Practice. Where needed and in particular in view of the European elections, the 
Commission will push for rapid and effective compliance. The Commission will carry out a 
comprehensive assessment at the conclusion of the Code’s initial 12-month period of 
application. Should the implementation and the impact of the Code of Practice prove 
unsatisfactory, the Commission may propose further actions, including actions of a regulatory 
nature. 
Action 7: With a view especially to the 2019 European elections, but also to the longer term, the 
Commission and the High Representative, in cooperation with the Member States, will organise 
targeted campaigns for the public and trainings for media and public opinion shapers in the 
Union and its neighbourhood to raise awareness of the negative effects of disinformation. 
Efforts to support the work of independent media and quality journalism as well as the research 
into disinformation will be continued in order to provide a comprehensive response to this 
phenomenon. 
Action 8: Member States, in cooperation with the Commission, should support the creation of 
teams of multi-disciplinary independent fact-checkers and researchers with specific knowledge 
of local information environments to detect and expose disinformation campaigns across 
different social networks and digital media. 

Action 9: As part of the Media Literacy Week in March 2019, in cooperation with the Member 
States, the Commission will support cross-border cooperation amongst media literacy 
practitioners as well as the launch of practical tools for the promotion of media literacy for the 
public. Member States should also rapidly implement the provisions of the Audio-visual Media 
Services Directive, which deal with media literacy. 

Action 10: In view of the upcoming 2019 European elections, Member States should ensure 
effective follow-up of the Elections Package, notably the Recommendation. The Commission will 
closely monitor how the Package is implemented and where appropriate, provide relevant 
support and advice. 

Yes 
No 
Partially 

Source: ECA. 

Yes – to hire more people and acquire tools 

With a view to the 2019 European 
elections but also in a longer-term 
perspective 

The High Representative and 
Member States 

Yes – to review the mandate 

No deadline 

The High Representative 

Yes – to establish the Rapid Alert System 

March 2019 

No – it is not clear what “step up communication efforts” means – 
more articles, more press releases? 

With a view to the 2019 European 
elections 

Yes – the Commission needs to monitor and conduct a 
comprehensive assessment 

Where needed and in particular in view 
of the 2019 European elections. The 
Commission will carry out a 
comprehensive assessment at the 
conclusion of the Code’s initial 12-month 
period of application 

The Commission and the High 
Representative 

The Commission in cooperation 
with the European Parliament and 
Member States 

The Commission and the High 
Representative, in cooperation 
with Member States 

The Commission 

Partially – the Commission needs to launch campaigns and 
trainings, however it is not clear what efforts it should make to 
support media and research 

With a view especially to the 2019 
European elections, but also to the longer 
term 

The Commission and the High 
Representative, in cooperation 
with Member States 

No – it is not clear how the MS should support the creation of fact-
checker and researcher teams 

No deadline 

The Commission and Member 
States 

No – it is not clear how the Commission is to support cross border 
cooperation amongst media literacy practitioners during one 
week. The Action Plan encouragement to implement the 
AudioVisual Medial Service Directive is just that. It has no legal 
power over the deadlines imposed in the directive (end of 2022). 

March 2019 

The Commission and Member 
States 

No – it is not clear how the election package should be followed up 
– evaluation, legal changes? 

With a view to the 2019 European 
elections 

The Commission and Member 
States 

 
 
 
 
 
 
 
53 

Annex V — The code of practice on disinformation 
The code of practice on disinformation (CoP) is a set of commitments to fight 
disinformation, agreed on a voluntary basis by representatives of online platforms, 
leading social networks, advertisers and the advertising industry. The CoP was 
encouraged and facilitated by the European Commission. This was the first time major 
industry players had decided to act together to address the spread of online 
disinformation. 

The initial signatories in October 2018 included Facebook, Google, Twitter and Mozilla, 
as well as a number of advertisers and advertising industry bodies. Microsoft signed 
the CoP in May 2019, followed by TikTok in June 2020. Presently there are 
16 signatories. 

The CoP consists of a series of commitments under five pillars: 

o 

o 

o 

o 

o 

scrutiny of ad placements; 

political advertising and issue-based advertising; 

integrity of services;  

empowering consumers; 

empowering the research community. 

It also includes an annex identifying best practices that signatories will apply to 
implement the CoP’s commitments. The signatories prepared individual roadmaps to 
implement the CoP. 

As the CoP is voluntary, there are no penalties for failure to honour these 
commitments. Therefore, it is important to monitor the signatories’ progress in 
implementing their commitments. Between January and May 2019, the European 
Commission verified the implementation of these commitments by Facebook, Google 
and Twitter, particularly in relation to the integrity of the European elections. The 
three platforms reported on a monthly basis on action they had taken in relation to the 
scrutiny of ad placements, transparency of political and issue-based advertising, and 
fake accounts and malicious use of bots. The Commission also invoked the CoP to 
request five sets of reports from the signatories on action they had taken to counter 
disinformation during the COVID-19 pandemic. 

These reports are available on the Commission’s website, together with the 
Commission’s assessment. 

 
 
Annex VI — Chronology of the main EU actions as a response to the 2020 COVID-19 pandemic and “infodemic” 

54 

Source: ECA. 

 
 
 
55 

Acronyms and abbreviations 

CoP: Code of Practice 

EDMO: European Digital Media Observatory 

EEAS: European External Action Service 

EMLW: European Media Literacy Week 

ERGA: European Regulators Group for Audio-visual Media Services 

EU action plan: EU action plan against disinformation 

EUD: EU Delegations 

EUvsDisinfo: The flagship project of the European External Action Service’s East 
StratCom Task Force. It was established in 2015 to better forecast, address, and 
respond to the Russian Federation’s ongoing disinformation campaigns affecting the 
EU, its Member States, and countries in the shared neighbourhood. 

HLEG: Independent High Level Expert Group on Fake News and Online Disinformation 

HWP: Horizontal Working Party on Enhancing Resilience and Countering Hybrid 
Threats 

IE: Information Environment 

IND: Internal Network on Disinformation 

RAS: Rapid Alert System 

SOMA: Social Observatory for Disinformation and Social Media Analysis 

StratCom: Strategic Communication 

 
 
 
 
56 

Glossary 

Algorithms: A process or set of rules applied by a computer in calculations or other 
problem-solving operations. 

Bot: An automated software application that is programmed to do certain tasks. 

Disinformation: The communication of false or misleading information for the purpose 
of deceit. 

Infodemic: An excessive amount of information – some accurate and some not – that 
can be used to obscure or distort the facts. 

Internet troll: Person who posts insults, often laced with profanity or other offensive 
language on social networking sites. 

Media literacy: Capacity to access, understand and interact with media and 
communications. 

Misinformation: The communication of false or misleading information, whether in 
good faith or for the purpose of deceit. 

Strategic Communications: Coordinated and coherent communication by an 
organisation in pursuit of specific goals. 

Wiki: A collaborative website on which any user can add and edit content. 

 
 
REPLIES OF THE EUROPEAN COMMISSION AND THE EUROPEAN EXTERNAL 
ACTION SERVICE TO THE EUROPEAN COURT OF AUDITORS SPECIAL REPORT: 
“DISINFORMATION AFFECTING THE EU: TACKLED BUT NOT TAMED” 

EXECUTIVE SUMMARY 

I. The European Union (EU) has recognised disinformation and foreign interference as an important 
challenge to democracy and society, at EU level as well as globally. Since 2015, it has increased its 
efforts  to  tackle  these  phenomena  –  to  that  end,  different  policy  documents  have  been  issued, 
including  the  2018  Action  Plan  against  Disinformation  (2018  Action  Plan).  The  EU  continues  to 
assess the ever-changing threats in this field and aims to support partner countries around the globe to 
address them.  

The EU aims to adapt its approach to these developments to ensure a coherent, comprehensive and 
effective framework to tackle disinformation and foreign interference, in full respect of fundamental 
rights and freedoms. 

III. The 2018 Action Plan remains, together with other policy documents, one of the core EU policy 
pillars on tackling disinformation. At the time of its adoption and still today, the Action Plan is one of 
its kind, looking at disinformation from different angles and identifying core areas for action. It allows 
for  immediate  short-term  response  to  disinformation  campaigns  and  long-term  investment  in 
strengthening societal resilience.  

It  is  a  comprehensive  document  that  focusses exclusively  on  disinformation and  thus  highlights the 
importance  that  the  EU  attaches to  this  challenge.  It  also  underlines  the  EU’s  aim  to  work  with  all 
stakeholders,  including  from  civil  society  and  private  industry,  to  develop  a  whole-of-society 
approach.  The  value  of  international  cooperation  is  highlighted,  forming  the  basis  for  increased 
cooperation with key partners like NATO and the G7. 

IV. Building on the 2018 Action Plan and the steps taken to implement it, the Commission and the 
European  External  Action  Service  (EEAS)  has  issued  policy  documents  like  the  2020  Joint 
Communication  on  COVID-19  Disinformation  (JOIN(2020)  8  final)  and  the  European  Democracy 
Action  Plan  (EDAP).  These  documents  built  on  the  achievements  stemming  from  the  2018  Action 
Plan and reiterate many of its points. Therefore, while not a formal update to the 2018 Action Plan, 
these documents are being regarded as the further developments of the 2018 Action Plan. The EDAP 
sets  out  measures  to  promote  free  and  fair  elections,  strengthen  media  freedom  and  counter 
disinformation.  In  doing  so,  it  takes  into  account  the  2018  Action  Plan  as  well  as  the  2020  Joint 
Communication  on  COVID-19  Disinformation. The EDAP  reiterates  many  of  the  calls  of the  2018 
Action  Plan,  including  the  cooperation  with  international  partners  and  the  need  to  further  enhance 
analytical capabilities at the European and national level. It also takes into account the progress made 
on the basis of the 2018 Action Plan to date and should therefore, be considered as an extension of the 
policy  framework  foreseen  in  2018  Action  Plan. The  EDAP  and  the  2020 Joint  Communication  on 
COVID-19 Disinformation were adopted after the conclusion of the audit and were therefore, outside 
of its scope.  

V. The EEAS considers that the absence of an overarching, single mandate from the Council has not 
impeded  the  development  or  the  operation  of  the  strategic  communications  division  and  its  Task 
Forces, including the adaptation to new and emerging issues. Any new consolidated mandate would 
need  to  reflect  the  same  level  of  political  support  as  originally  reflected  in  the  European  Council 
mandate of 2015. 

VI.  The  EEAS  underlines  the  uniqueness  of  the  EUvsDisinfo  project,  which  has  been  set  up  as  a 
direct implementation of the 2015 mandate given by the European Council. The EUvsDisinfo project 
is  of  great  value  for  the  EEAS  and  the  EU  institutions  as  a  whole  to  raise  awareness  for  the  ever-

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evolving threat of disinformation campaigns. As the disinformation challenge and related threats are 
evolving, it is only natural to revisit the approach taken on a regular basis. 

The  EEAS  considers  that  the  establishment  of  the  Rapid  Alert  System  (RAS)  was  an  important 
element in developing its counter-disinformation strategy. In fact, the RAS represents the only forum 
in the EU institutional set up where disinformation experts from EU institutions and Member States  
are  working  together  to  address  disinformation  related  issues.  The  EEAS  welcomes  the  active 
participation of a large number of Member States and invites others to intensify their activity. 

VII.  The  assessment  of  the  Code  of  Practice  on  Disinformation  published  in  September  2020  (the 
Code of Practice) acknowledged that it should be further improved in several areas. The findings of 
the assessment supported two Commission’s policy initiatives adopted at the end of 2020 – the EDAP 
and  the  Digital  Services  Act  (DSA)  –  that  aim  inter  alia  to  strengthening  the  fight  against 
disinformation  by  establishing  a  transparency  and  accountability  co-regulatory  framework,  thus 
addressing the indicated shortcomings. 

VIII. The first phase of supporting and observing grass root media literacy projects through the Media 
Literacy  for  All  Pilot  project  and  preparatory  action  showed  a  fragmented  landscape,  however 
mirroring the needs of Member States. Since then, the Commission has further developed its media 
literacy  work  programme  in  the  framework  of  the  Creative  Europe  Programme,  to  scale  up  the 
relevant  actions  in  this  area  and  share  the  results  across  Member  States,  cultural  and  linguistic 
borders.  The  targeted,  smaller  scale  initiatives  and  a  more  harmonised  pan-European  approach  are 
necessary  and  can  complement  each  other.  However,  the  Commission  does  not  see  that  a  certain 
degree of fragmentation, which mirrors the Member States’ heterogeneous approaches, would present 
a risk per se, while it acknowledges the need for coordination, and is addressing this. 

The  European  Digital  Media  Observatory  (EDMO)  was  launched  only  in  June  2020  and  has  been 
developing fast into its current advanced phase. 

IX. First bullet point – The Commission and the EEAS accept recommendations 1 (a) and 1 (d), and 
partially accept recommendations 1 (b) and 1 (c). 

Second bullet point – The EEAS accepts recommendations 2 (a), (b), (c) and (d). 

Third bullet point – The EEAS accepts recommendations 3 (a), (b) and (c). 

Fourth bullet point – The Commission accepts recommendations 4 (a) and (b), and partially accepts 
recommendation 4 (c). 

Fifth bullet point – The Commission accepts recommendations 5 (a), (b) and (c). 

Sixth bullet point – The Commission accepts recommendations 6 (a), (b) and (c). 

INTRODUCTION 

01.  The  Commission  and  the  EEAS  point  out  that  the  challenge  of  disinformation  and  information 
manipulations  continues  to  change  and  evolve  rapidly.  Definitions  and  precise characterisations  are 
therefore being reviewed, also in recent policy documents such as the 2020 Joint Communication on 
COVID-19 Disinformation and the EDAP. 

OBSERVATIONS 

22. The Commission also adopted a package of measures to support free and fair elections in light of 
the  2019  elections,  with  recommendations  addressed  to  Member  States  and  national  and  European 
political parties, which included measures to address disinformation1. As part of the implementation 

1  https://ec.europa.eu/info/sites/info/files/soteu2018-cybersecurity-elections-recommendation-5949_en.pdf; 

Reported in https://ec.europa.eu/info/files/com_2020_252_en.pdf_en 

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of these recommendations, the Commission organised three meetings of a specially created European 
Cooperation Network on Elections to exchange good practice and information among Member State 
competent authorities. 

25. Although a formal framework was not set up, the Commission hold regular coordination meetings 
at services and political level to ensure that information was shared about the implementation of the 
2018 Action Plan. 

28. The Network against Disinformation has helped build the capacity of the services to respond to 
disinformation, providing the tools, competences and support to all the Directorates-General and the 
Representations  of  the  EU  that  are  part  of  it.  It  brought  together  previously  disjointed  actions, 
encouraged collaboration and provided a repository of common myths and the facts needed to rebut 
them.  It  fostered  a  culture  of  fact-checking  and  responding  to  myths  and  disinformation  and  in  so 
doing  provided  a  more  unified  approach  to  the  EU’s  efforts  to  counter  disinformation.  Finally,  the 
many awareness raising activities, raised the profile of the EU’s policy work against disinformation. 

29. Directorate-General for Communication (DG COMM) points out that its 2020 management plan 
includes  three  measurable  indicators  related  to  disinformation:  reach  of  awareness-raising  activities 
fighting disinformation and number of visit of anti-disinformation web pages (besides the number of 
meetings of the internal network against disinformation). 

30. An overall modernisation of the relevant websites is ongoing with a view of launching the new 
versions by the end of 2021, including measuring their performance.  

31. DG COMM’s external communication efforts were focused on COVID-19 and vaccines mis- and 
disinformation,  through  dedicated  web  pages.  It  was  decided  that  the  planned  central  web-based 
disinformation hub would be transformed into an internal tool, revamping the existing WIKI. 

40.  The  2018  Action  Plan  is  not  a  funding  programme.  As  a  result,  the  funds  allocated  to  its 
implementation  depend  on  the  decisions  taken  in  another  framework  (e.g.  work  programme  of 
funding programmes like Horizon 2020). The total budget cannot be earmarked ex-ante. 

41. The 2018 Action Plan remains one of the core guiding documents that steer the EU’s response to 
disinformation and it has not lost its relevance since its adoption. However, the threat has evolved and 
so  has  the  EU’s  approach  to  tackling  disinformation  –  this,  however,  does  not  mean  that  the  four 
pillars identified in the 2018 Action Plan have lost any of their relevance. On the contrary – building 
on the 2018 Action Plan and the steps taken to implement it, the EU has issued policy documents like 
the 2020 Joint Communication on COVID-19 Disinformation and the EDAP. These documents built 
on the achievements stemming from the 2018 Action Plan and reiterate many of its points. Therefore, 
while not a formal update to the 2018 Action Plan, these documents are being regarded as the further 
developments of the 2018 Action Plan. In particular, this refers to its rationale to strengthen societal 
resilience in the long term and protect democracies by better understanding and defining the threat, 
and taking actions to strengthen capabilities to monitor, analyse and expose disinformation. 

42. The Commission notes that the EDAP, the DSA and the Media and Audiovisual Action Plan are 
effectively proposing to take over several actions and following up on various points from the 2018 
Action Plan. These initiatives are complementary, and will be well coordinated, mitigating the risk of 
inefficiencies in addressing certain weaknesses of the 2018 Action Plan identified in this audit. 

48.  The  EEAS  considers  that  the  Strategic  Communications  Division  and  its  Task  Forces  pursue  a 
risk-based  approach  in  its  monitoring  activities  and  focus  on  those  actors  and  issues  that  are  most 
prevalent. The EEAS also takes into account the rapidly changing and evolving threat landscape and 
on a regular basis aims to review and adapt its processes and the work of the entire team accordingly. 
It also points out that threat actors can be state or non-state actors. The EEAS continuously strives to 
adapt team and focus to changing threat landscape. 

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49.  While  the  EEAS  considers  that  the  current  mandates  given  by  the  European  Council  and  other 
Council formations have provided a good basis for the ongoing operations of the StratCom Division 
and its Task Forces so far, an updated consolidated mandate taking into account the changed threat 
landscape could be useful. Any such new consolidated mandate would need to be given at the level of 
the European Council, in line with the 2015 mandate. 

51. The EEAS points out that, under the 2021 budget, the EEAS Strategic Communications Divisions 
has received a clear allocation of funds on different budget lines, which nearly doubled its operating 
budget. 

54.  The  EEAS  points  out  that,  in  the  past  allocation  2019,  2020  and  2021,  the  Strategic 
Communications  Division  has  received  a  total  of  52  new  posts,  including  27  Local  Agents  in 
Delegations, which will enable the EEAS to fulfil the Action Plan’s target. 

55. EEAS common reply to paragraphs 55 and 56. 

The  EEAS  would  like  to  underline  the  crucial  importance  of  recruiting  expert  and  specialist 
knowledge for its work related to disinformation. Contractual agents and seconded national experts, 
even  if  they  have  an  overall  limited  tenure,  play  an  important  role  in  the  current  operations,  for 
example in the field of data analysis, as well as regional or linguistic knowledge. 

58. The activities of the data team continue to be built. These are meant to serve the entire Division 
and  all  work  strands,  as  well  as  to  adjust  to  any  changes  in  the  disinformation  landscape.  The 
approach of the data team is comprehensive to support the entire Division, but also contribute to the 
cooperation with international partners like the G7 and NATO. The work of the data team additionally 
includes  the  constant  further  development  of  the  methodological  and  conceptual  framework  of  the 
Division’s data work. 

60. The EEAS strives to further improve evaluation of all aspects of its operations. However, when it 
comes  to  the  impact  of  counter-disinformation  activities,  there  is  no  established  methodology  to 
measuring  the  impact  of  disinformation,  as  well  as  of  actions  taken  to  tackle  it.  This  reflects  the 
challenges that the entire community who works to counter disinformation and foreign interference is 
facing. 

64. The EEAS considers the EUvsDisinfo as a well-established brand, which is clearly anchored in 
the  EEAS  role  and  activities.  The  focus  on  Russian  disinformation  stems  from  the  very  specific 
mandate from the European Council in 2015. The EEAS is continuously adapting and expanding the 
scope and approach of these tools. 

67.  The  EEAS  considers  that  the  establishment  of  the  RAS  was  a  major  positive  development  to 
contribute to the EU’s capability to address disinformation and information manipulations.  

69.  The  EEAS  considers  that  the  RAS  has  greatly  contributed  to  a  better  coordination  between 
Member  States  and  European  institutions  by  facilitating  information  exchange,  better  situational 
awareness and practical cooperation on communication activities. 

70. The EEAS considers that the RAS has been built as a facilitating structure for the EU Member 
States  and  the  European  institutions.  It  has  proven  to  be  very  useful  in  this  context.  The  operating 
principles and workflows have been jointly agreed and the regular meetings held with the Points of 
Contact  as  well  as  bilateral  exchanges  with  the  RAS  Members  and  EEAS  ensure  a  common 
understanding of the rationale behind the RAS. Members are also regularly consulted on their views 
of how the RAS can be further built and improved. 

74. EEAS common reply to paragraphs 74 and 75. 

The EEAS agrees that the level of activity on the RAS platform could be increased, especially by the 
Member States who have been less active in the past, and that there is much untapped potential. The 
fluctuations in activity can be explained by the importance of specific events, such as elections. 

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76. The EEAS underlines that there was no intention to formalise the cooperation between the RAS 
and  the  social  media  platforms.  Notwithstanding  the  provisions  of  the  Code  of  Practice,  informal 
cooperation between the RAS and the platforms has been taken forward as appropriate. 

84. Further to the assessment of the Code of Practice, the EDAP has set up a process to revise and 
strengthen the Code. The Commission will issue guidance and convene the signatories to strengthen it 
according  to  the  guidance.  Setting  up  a  robust  and  permanent  framework  for  the  monitoring  of  the 
Code  is  also  specifically  announced  in  EDAP.  Furthermore,  the  DSA  proposes  a  horizontal 
framework  for  regulatory  oversight,  accountability  and  transparency  for  online  platforms.  When 
adopted, the DSA will establish a co-regulatory backstop for the measures, which would be included 
in  a  revised  and  strengthened  Code  of  Practice  on  disinformation.  Thus,  better  monitoring  and 
accountability will be possible if and when the proposal for the DSA is adopted. 

86. With regard to the absence of overall Key Performance Indicators (KPIs) for all signatories, the 
Commission notes the difficulty to identify KPIs capable of monitoring the actions of all signatories 
of  the  Code  of  Practice,  given  the  very  different  nature  and  activities  of  the  signatories  and  the 
different  levels  of  commitments  e.g.,  the  services  provided  by  social  media  platforms  vary 
significantly from the services provided by search engines. 

88.  The  2020  Joint  Communication  on  tackling  COVID-19  disinformation  listed  the  features  that 
platforms had to report about in their monthly reports. The Commission asked platforms to take action 
to harmonise reporting and proposed a detailed list of data points relevant to these features from the 
platform signatories. 

94.  The  2019  edition  of  European  Media  Literacy  Week  was  a  comprehensive  and  coordinated 
initiative, featuring events at EU and national levels, showcasing of projects, regulatory and forward-
looking policy exchanges. The initiative was highly appreciated by the media literacy community. 

96. In addition to the Creative Europe Programme, where the funding of approximately €14 million, 
compared  to  the  pilot  project  and  preparatory  action  funding,  will  be  multiplied,  also  other 
programmes,  such  as  Erasmus+  and  the  European  Solidarity  Corps  actively  support  media  literacy 
initiatives. Support will continue through the 2021-2027 period. 

99.  The  Commission  points  out  that  projects  may  not  provide  “tangible  results”  but  they  may 
nevertheless be highly successful. The projects are aimed to reach to new areas, initiate new research 
avenues,  pilot  and  test  concepts,  create  new  communities  and  are  by  nature  and  design  of 
experimental nature. 

100. Horizon 2020 projects are chosen through an objective external evaluation following set criteria, 
and  they  are  supervised  through  regular  reviews  by  objective  reviewers.  The  evaluation  and  the 
reviews are carried out by selected highly competent experts, whose opinion the Commission trusts 
with  regard  to  best  value  for  money.  The  Commission  notes  that,  in  view  of  reach,  the  limited 
available funding plays a key role. 

Box 5 – Examples of EU-funded projects with limited reach or scale of actions 

One of the key objectives of Media Literacy for All was, in addition to tackle disinformation related 
media literacy challenges, to reach the hard to reach sectors of European societies with an emphasis 
on  the  socially  disadvantaged,  minorities  and  those  on  the  margins  of  society,  for  whom  media 
literacy  skills  are  especially  important.  The  projects  funded  under  Media  Literacy  for  All  provide 
valuable insights on how to engage productively with the above mentioned groups. 

Project  14  had  a  limited  time  span,  hence  the  web  site  has  since  been  removed.  Project  16  used 
established media literacy techniques, such as development of videogames, podcasts and video clips, 
with an overarching theme of empowerment through the development of critical evaluation skills and 
creation of media content. The project also covered media literacy activities designed specifically for 
children with a migration background. 

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101. The Commission notes that media literacy is a difficult area for measuring impact. A task force 
in  collaboration  with  the  European  Regulators  Group  for  Audiovisual  Media  Services  (ERGA)  and 
Media Literacy Expert Group (MLEG) has been initiated to review possibilities for useful KPIs on 26 
March 2021 with an aim for first results by end of 2021. 

Notably, a comprehensive evaluation of the implementation of Media Literacy for All (2016-2020), is 
not possible before all projects are completed in spring 2022. Nevertheless, the success and impact of 
the  projects  are  assessed  systematically  at  individual  project  level  exit  meetings  as  well  as  through 
annual coordination meetings of all ongoing projects and via presentations to the Member States at the 
MLEG meetings. This is part of the verification process of the projects’ impacts. 

103. The Commission acknowledges that the Social Observatory for Disinformation and Social Media 
Analysis (SOMA) did not attract many fact-checkers recognised by the International Fact Checking 
Network. However, the Commission would like to note that the number of disclosed members now 
stands at 55 and so far 25 investigations on disinformation campaigns across Europe were produced 
by members of the SOMA network. 

105. The Commission acknowledges a partial overlap of SOMA and EDMO. This overlap between 
the two  projects  and the  fact that  the  two projects rely  on  the  same  technological  solution  ensure  a 
smooth migration of the fact-checking community from SOMA to EDMO. Moreover, before ending, 
the SOMA project will pass the lessons learned to EDMO.  The Commission notes that technological 
platform  provided  by  EDMO,  while  based  on  the  same  technology,  will  provide  extended 
functionalities to a much wider network of fact-checking and research organisations when compared 
to SOMA. The Commission will carefully monitor the projects to avoid double funding. 

107.  The  Commission  notes  that  the  media  literacy  community  will  be  further  involved  in  EDMO 
through the national hubs, operational from summer 2021, which will have to carry out specific media 
literacy tasks. 

CONCLUSIONS AND RECOMMENDATIONS 

109. The EDAP includes a dedicated section on countering disinformation and foreign interference. 
The Commission and the EEAS considers this the evolution of policy framework as proposed in the 
2018  Action  Plan.  The  EDAP  reiterates  many  of  the  calls  of  the  2018  Action  Plan,  such  as  strong 
international cooperation, and references inter alia the RAS, which the 2018 Action Plan introduced 
for the first time. It also includes a call for more obligations and accountability for online platforms, 
setting out next steps, including the co-regulatory framework set up by the DSA, which is the follow 
up  of  pillar  3  of  the  2018  Action  Plan.  It  acknowledges  the  progress  made  in  monitoring  and 
analysing  disinformation  and  calls for a  more  detailed  framework  and  methodology  to  build  on  the 
achievements  following  the  2018  Action  Plan.  In  the  view  of  the  Commission  and  the  EEAS,  it  is 
therefore inherent to the text of the EDAP that it takes the 2018 Action Plan fully into account and is 
considered its natural follow-up. 

110. Coordination among all services for the implementation of the 2018 Action Plan was carried out 
by the secretariat of the Security Union Task Force and regular reporting on the progress made was 
included  in  the  Security  Union  Progress  Reports.  In  the  context  of  the  pandemic,  coordination  of 
policies  in  the  field  of  disinformation  was  ensured  by  the  Secretariat  General  in  a  dedicated  Inter-
Service  Group,  which  also  helped  prepare  the  2020  Joint  Communication  on  COVID-19 
disinformation and its follow up. In the context of EDAP, a new Inter-Service Group has been created 
under  the  leadership  of  the  Secretariat  General  to  coordinated  services’  work,  including  on 
disinformation.  Besides,  the  EDAP  foresees  the  establishment  of  a  clear  protocol  to  pull  together 
knowledge and resources quickly in response to specific situations. 

Recommendation 1 – Improve  the  coordination  and  accountability  of  EU  actions  against 
disinformation 

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The Commission and the EEAS accept recommendation 1 (a). 

As also announced in EDAP, the EU institutions will further ensure that their internal coordination on 
disinformation is strengthened with a clear protocol to pull together knowledge and resources quickly 
in response to specific situations. 

The Commission and the EEAS partially accept recommendation 1 (b). 

Following the adoption of EDAP, the Commission and the EEAS are monitoring the implementation 
of actions against disinformation in the context of that action plan. As pointed out, the EDAP builds 
on the 2018 Action Plan and further develops many aspects of it.  In addition, the Commission and the 
EEAS would like to stress that, given the policy nature of some actions, it is difficult to set a single set 
of  performance 
legislative  proposals  will  provide  separate  evaluation 
frameworks. 

indicators.  Relevant 

The Commission and the EEAS partially accept recommendation 1 (c). 

The Commission and the EEAS will review the implementation of the EDAP in 2023, a year ahead of 
the European Parliament elections, including the reporting arrangements to follow. 

The Commission and the EEAS accept recommendation 1(d). 

Recommendation 2 – Improve  the  operational  arrangements  of  the  StratCom  division  and  its 
task forces 

The  EEAS  accepts  recommendation  2  (a)  and  will  continue  to  brief  and  update  different  Council 
formations, taking into account their views in further refining policy objectives and approaches. 

The EEAS accepts recommendation 2 (b) and points out that recruitment targets as spelled out in the 
2018 Action Plan are expected to be reached in 2021. 

The EEAS accepts recommendation 2 (c). 

The EEAS accepts recommendation 2 (d). 

114.  The  EEAS  underlines  the  uniqueness  of  the  EUvsDisinfo  project,  which  has  been  set  up  as  a 
direct implementation of the 2015 mandate given by the European Council. The EUvsDisinfo project 
is  of  great  value  for  the  EEAS  and  the  EU  institutions  as  a  whole  to  raise  awareness  for  the  ever-
evolving threat of disinformation campaigns. As the disinformation challenge and related threats are 
evolving, it is only natural to revisit the approach taken on a regular basis. 

Recommendation 3 – Increase participation in the RAS by Member States and online platforms 

The EEAS accepts recommendation 3 (a) and would like to underline that many operational aspects 
are in the competence of Member States.  

The EEAS accepts recommendation 3 (b) and underlines that the changes already implemented will 
further facilitate joint responses. 

The EEAS accepts recommendation 3 (c). 

117.  Regarding  the  provision  of  data  to  the  Commission,  the  Commission  notes  that  the  Code  of 
Practice  is  a  self-regulatory  tool  voluntarily  adopted  by  its  signatories  to  address  disinformation 
activities running on their services. For the time being, there is no legal framework that obliges the 
Code’s signatories to give the Commission access to the data sets. This is an example of the limited 
powers of the Commission in this field.   

However, as indicated, the EDAP sets out the next steps to strengthen the Code of Practice, including 
by issuing guidance in anticipation of the co-regulatory backstop, which will be put in place with the 
DSA.  The  DSA  is  proposing  a  horizontal  framework  for  regulatory  oversight,  accountability  and 

EN 

7 

  EN 

 
 
 
transparency of the online space in response to the emerging risks. The EDAP also sets out how to 
establish a robust and permanent framework for the monitoring of the Code of Practice.  

An even better monitoring will be possible when the proposal for the DSA is adopted. DSA notably 
includes provisions for very large platforms to establish regular monitoring frameworks related to the 
relevant risks and to submit their risk assessments and risk mitigation measures to independent audits.  

Recommendation 4 – Improve the monitoring and accountability of online platforms 

The Commission accepts recommendation 4 (a) and notes that it has already started implementing it 
in in the framework of the EDAP. The Commission has also addressed the disinformation problem in 
the  proposed  DSA,  which  should  strengthen  the  obligations  of  transparency,  accountability  and 
monitoring. 

The  Commission  will  shortly  issue  guidance  to  address  the  shortcomings  of  the  Code  of  Practice, 
including KPIs and benchmarks to better monitor its effectiveness. The Commission also stresses its 
current  limited  competences  in  this  field,  which  preclude  it  from  addressing  on  its  own  all  the 
complex societal challenge posed by disinformation.  

The Commission accepts recommendation 4 (b) and will implement it in the framework of the EDAP.  

This will include setting up a robust framework for recurrent monitoring of the Code of Practice. As 
also set out in EDAP, the strengthened Code of Practice shall monitor the effectiveness of platforms 
policies on the basis of a new methodological framework which includes principles for defining KPIs. 

The  Commission  partially  accepts  recommendation  4  (c).  It  will  assess  the  possibilities  for 
establishing a procedure for validating the information provided by online platforms in full respect of 
the currently purely self-regulatory character of the Code of Practice. At the same time, it notes that 
the  Commission’s  proposal  for  the  DSA  proposes  a  horizontal  framework  for  regulatory  oversight, 
accountability and transparency of the online space in response to the emerging risks, which includes 
provisions for very large platforms to establish regular monitoring frameworks related to the relevant 
risks and to submit their risk assessments and risk mitigation measures to independent audits. 

Recommendation 5 – Adopt an EU media literacy strategy that includes tackling disinformation 

The Commission accepts recommendation 5 (a) and notes that it started being implemented. 

The Commission accepts recommendation 5 (b) and notes that it started being implemented. 

The Commission accepts recommendation 5 (c) and notes that it started being implemented. 

120. The Commission acknowledges that SOMA did not attract many fact-checkers recognised by the 
International Fact Checking Network.  

The Commission would like to note that the number of disclosed members of SOMA now stands at 55 
including members active in fact-checking and so far 25 investigations on disinformation campaigns 
across Europe were produced by  members of the SOMA network. 

The Commission notes that EDMO started its operations only 4-5 months before the auditors reached 
EDMO’s  management.  At  that  time,  EDMO  had  still  a  limited  operational  capacity  to  reach 
stakeholders.  The  EDMO’s  capacity  to  operate  is  greatly  increasing.    Several  meetings  and  survey 
with stakeholders already took place and the EDMO national hubs, operational from summer 2021, 
will further extend its reach. Further resources earmarked under the Digital Europe Programme will 
ensure sufficient resources to achieve EDMO’s objectives. 

The Commission notes that the media literacy community will be further involved in EDMO through 
the national hubs, operational from summer 2021, which will have to carry out specific media literacy 
tasks. 

Recommendation 6 – Take steps to enable EDMO to fulfil its ambitious objectives 

EN 

8 

  EN 

 
 
 
The  Commission  accepts  recommendation  6  (a).  The  SOMA  project  will  provide  EDMO  with  a 
handover package with the lessons learned during its activity. 

The  Commission  accepts  recommendation  6  (b)  and  will  suggest  EDMO,  while  respecting  its 
independence, to  increase  the  representation  of  media  literacy  and  civil  society  experts in  EDMO’s 
advisory board. 

The Commission accepts recommendation 6 (c) and notes that EDMO has already organised, on the 9 
October 2020, a workshop with the fact-checking community and will continue the outreach activities 
towards  the  fact-checking  community.  Moreover,  the  media  literacy  community  will  be  further 
involved in EDMO through the national hubs – to be established in the second half of 2021 – which 
will carry out also specific media literacy tasks. 

EN 

9 

  EN 

 
 
 
Audit team 

The ECA’s special reports set out the results of its audits of EU policies and 
programmes, or of management-related topics from specific budgetary areas. The ECA 
selects and designs these audit tasks to be of maximum impact by considering the risks 
to performance or compliance, the level of income or spending involved, forthcoming 
developments and political and public interest. 

This performance audit was carried out by Audit Chamber III External action, security 
and justice, headed by ECA Member Bettina Jakobsen. The audit was led by ECA 
Member Baudilio Tomé Muguruza, supported by Daniel Costa de Magalhaes, Head of 
Private Office and Ignacio Garcia de Parada, Private Office Attaché; Alejandro Ballester 
Gallardo, Principal Manager; Emmanuel-Douglas Hellinakis, Head of Task; Piotr Senator 
and Alexandre Tan, Auditors. Michael Pyper provided linguistic support. 

 
 
 
 
 
 
Timeline 

Event 

Adoption of Audit Planning Memorandum (APM) / Start of Audit 

Official sending of draft report to Commission (or other auditee) 

Date 

4.2.2020 

4.3.2021 

Adoption of the final report after the adversarial procedure 

27.4.2021 

Commission’s (or other auditee’s) official replies received in all 
languages 

25.5.2021 

 
 
 
 
 
 
 
 
 
 
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PDF
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ISBN 978-92-847-5963-7
ISBN 978-92-847-5945-3

ISSN 1977-5679
ISSN 1977-5679

doi:10.2865/337863
doi:10.2865/772885

QJ-AB-21-008-EN-N
QJ-AB-21-008-EN-Q

 
 
 
 
 
 
 
 
Disinformation is a serious concern in organised societies. Social 
media and new technologies have increased the scale and speed 
with which false or misleading information can reach its 
audiences, whether intended and unintended. The EU action plan 
against disinformation was relevant at the time it was drawn up 
but incomplete. Even though its implementation is broadly on 
track and there is evidence of positive developments, it has not 
delivered all its intended results. We make recommendations to 
improve the coordination and accountability of EU actions against 
disinformation. We focus on the operational arrangements of the 
European External Action Service’s strategic communications 
division and its task forces. We recommend increasing Member 
States’ involvement in the rapid alert system and improving the 
monitoring and accountability of online platforms. We also point 
to the need for an EU media literacy strategy that includes 
combatting disinformation and taking steps to enable the 
European Digital Media Monitoring Observatory achieve its 
ambitious objectives. 

ECA special report pursuant to Article 287(4), second 
subparagraph, TFEU.