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The EDAP: a welcome step in the right direction

Following a public consultation and various exchanges with civil society and member states over the last year, European Vice President Vera Jourova has published the European Democracy Action Plan (EDAP). The EDAP restates the EU’s commitment to democracy, the rule of law and fundamental freedoms, and specifies various actions to strengthen election integrity, boost citizen participation, strengthen media pluralism and the safety of journalists, and counter online disinformation. In this article, we assess to what extent the EDAP lives up to civil society’s expectations and needs for strengthening European democracy.

A welcome step in the right direction

Having coordinated a joint input paper and joint statement with over 50 civil society organisations, the European Partnership for Democracy welcomes the European Democracy Action Plan as a positive and necessary step to tackling some key challenges to democracy. Our horizontal demands on the EDAP’s broadened scope, use of various tools, inclusive and clear implementation process and a positive narrative were largely met. With a focus on a multistakeholder approach throughout the Action Plan, a plurality of legislative and non-legislative proposals and a review in 2023, the Action Plan sets the right framework for action for the years to come. The EDAP’s ability to straddle both internal and external action is slightly awkward in presentation but a very necessary and welcome call for policy coherence.

We also made a number of specific recommendations specific to each of the themes of the EDAP, with a view to developing a comprehensive framework that allows for the Commission and EU Member States to strengthen democracy broadly, rather than focus on a narrow subset of challenges. While many of these specific recommendations were not taken up, the EDAP refers to several recommendations by lightly touching on them or related questions. We appreciate the acknowledgement of the broad range of actions needed to support democracy.

Elections and participation

In the section detailing commitments on strengthening election integrity and participation, we welcome the legislative proposal on online political ads to complement the transparency measures on all online advertisements that will be proposed in the Digital Services Act. The EDAP shares some insights of things that are likely to be included in the forthcoming legislation: restrictions on microtargeting for political ads, better enforcement of GDPR, and measures such as labelling, transparency of price-paid, targeting and amplification criteria, and disclosure requirements. As these measures require the Commission to define what constitutes a political ad, close coordination with civil society, researchers, private sector and Member States will be needed. We look forward to the transparency frameworks on online ads laid out in the DSA.

We also welcome the proactive new measures taken to strengthen cooperation on electoral matters between EU Member States, including a new mechanism for coordination and an increased role for the European Cooperation Network on Elections. While this is a start, we would have liked to see a commitment to electoral reform for European Parliament elections beyond the revision of European political parties financing legislation, to make the process more inclusive and representative. Likewise, the EDAP stays clear of addressing the fact that 800,000 persons with disabilities in the EU could not exercise their right to vote in the last European elections, and that many Member States don’t allow for citizen election observation.

A major unprecedented development is the clear commitment by the European Commission to deliberative democracy and participatory policy-making. While the document does not mention many new initiatives but rather refers to standing commitments such as Horizon Europe projects and the Conference on the Future of Europe, it is the first EU document to so clearly commit the Union to strengthening participatory and deliberative democracy.

On the downslide, the EDAP is completely void of any mention of civic space. In view of today’s challenges to civic space in Europe, it is unlikely that such an omission is accidental. Likewise, many of the commitments to participatory policy-making are directed at Member States, rather than the Commission’s everyday work. We thus await meaningful action by the Commission to live up to these expectations, for instance with an Inter-Institutional Agreement on Civil Dialogue or a revision of the European Citizens Initiative.

Media Pluralism & safety of journalists

A very necessary and welcome development is the proposal for a new anti-SLAPP initiative – although it remains to be seen what this will actually include – and recommendations on the safety of journalists in EU Member States. The new initiatives of the European News Media Forum and Media Ownership Monitor could likewise signify a positive step forward in media pluralism and safety of journalists. Significant support to media’s viability and funding for journalists is largely missing, however, the recently released Media and Audiovisual Action Plan sheds more light on the Commission’s work on that front.


Finally, we welcome the narrative around the Digital Services Act as a tool for strengthening democracy, as detailed in the section on countering disinformation. We see value in the DSA as a co-regulatory backstop for a reinforced Code of Practice, however, the Code of Practice will need significant work before it will lead to any meaningful change. Access to data for public interest research was, for instance, included in the previous Code of Practice and platforms have completely failed to deliver on that commitment citing the GDPR as an excuse, rather than a lack of will. For access to data to be organised in a transparent way, it will require official transparency and accountability frameworks that would better be suited to be created through the DSA. Another worrying element is the mention of “trustworthiness indicators” in algorithmic recommender systems – considering the ambiguity and subjectivity of trustworthy information – and therefore requires some clarification.

The work that has gone into looking at the different definitions of actions that typically fall under the umbrella of disinformation is important. Disinformation, misinformation, information influence operations and foreign interference in the information space are all different phenomena and democracies need to address each in a different manner.


In sum, the EDAP is a more consistent and wide-ranging document than could have been expected earlier in the year. Despite the limited openness of the Commission to engage with a broad range of civil society during the process of writing the EDAP, the Commission has succeeded in including many of the key demands from different European organisations. We commend Vice-President Jourová and her team. As a European democracy network, we stand ready to support the Commission with the implementation of the EDAP in the years to come.