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Civic Discourse and Electoral Processes in the Risk Assessment and Mitigation Measures Reports under the Digital Services Act: An Analysis


The EU’s Digital Services Act (DSA) mandates Very Large Online Platforms (VLOPs) and Very Large Online Search Engines (VLOSEs) to conduct thorough assessments and implement mitigation measures for systemic risks that the use of their services pose, among others, to civic discourse and electoral processes (Articles 34 and 35).

The first risk assessment and mitigation measures reports for 2023 and 2024 have been made public in November 2024. This provides an opportunity for civil society and other experts to obtain more information on the measures adopted by VLOPs and VLOSEs and to be involved in improving the effectiveness of such measures in future reports.

This paper aims to analyse the risk assessments to identify relevant gaps and suggest steps on how to ensure more robust protection of civic discourse and electoral processes under the DSA. We will provide first a general analysis of the risk assessments and then focus on individual reports, namely those of  Facebook, Instagram, Google Search, YouTube, TikTok, and X.

Cover photo: © Jacek Dylag on Unsplash.