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Identifying systemic risks for civic discourse and electoral processes and related mitigation measures under EU’s Digital Services Act



The Digital Services Act (DSA) mandates that Very Large Online Platforms (VLOPs), such as Facebook, and Very Large Online Search Engines (VLOSEs), such as Google, conduct thorough assessments and implement mitigation measures for systemic risks that the use of their services poses, among others, to civic discourse and electoral processes. As these rules are currently being implemented, EPD and our partners from Liberties have worked on a paper to feed into the discussion on how to ensure robust protection of civic discourse and electoral processes under the DSA.

Based on our definitions of civic discourse and electoral processes, this paper identifies a number of risks encompassing topics such as disinformation, political advertising and inclusivity online; and it recommends related mitigation measures such as changes in design features in particular for algorithmic systems, content moderation practices and enhanced data protection, along with many more recommendations specific to the different cases.

This paper is the first to offer a structured approach for VLOPs and VLOSEs as well as for the European Commission to identify risks to democratic “civic discourse” and “electoral processes”.

In the coming weeks, Liberties and EPD will actively engage with relevant stakeholders, including the European Commission, VLOPs, VLOSEs, researchers, and civil society organisations, to discuss the proposed risk assessments and mitigation measures. Through ongoing discussion, collaboration and advocacy efforts, Liberties and EPD aim to drive the practical implementation and enforcement of these recommendations (or upon need, a next version of them), ultimately contributing to a more responsible and accountable digital environment.

Image by Freepik

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