§3.1 Reinforcing internal processes

18. To tailor mitigation measures to identified risks to electoral processes, providers of VLOPs and VLOSEs should consider reinforcing internal processes in line with Article 35(1)(f) of Regulation (EU) 2022/2065. Mitigation measures should, amongst others, be guided by information on elements such as the presence and activity of political actors on the service, relevant discussions on, and usage of, the platform in the context of elections, the number of users in a Member State when a particular election is called in that Member State, and indications of previous instances concerning tactics, techniques, and procedures for information manipulation. 19. Internal processes should identify and make available relevant information, analysis, and data to enable the design and calibration of measures to mitigate any actual or foreseeable risks that might stem from information on elections that is searched, shared, or accessed via the service provided by VLOPs and VLOSEs. This could include, but is not limited to, information on political parties or candidates, party programmes, manifestos or other political material, or related information, to organise events such as demonstrations or rallies, campaigning, fundraising, or other related political activities. Internal processes for collecting and sharing analysis and data informing the design and calibration of risk mitigation measures that providers of VLOPs and VLOSEs put in place shall ensure compliance with relevant data protection legislation (18). 20. Internal processes should be reinforced to ensure that the design and calibration of mitigation measures is appropriate for the specific regional, local, and linguistic context in which they will be employed. Therefore, providers of VLOPs and VLOSEs are encouraged, amongst others, to ensure information and analysis collected on local context-specific risks and Member State specific information at the national, regional and/or local level is seamlessly made available to the entities responsible for the design and calibration of risk mitigation measures. 21. It is also recommended that providers have adequate content moderation resources with local language capacity and knowledge of the national and/or regional contexts and specificities. The Commission also recommends that providers ensure they have adequate internal processes to take into account independent analyses of the state of media freedom and pluralism, such as the Media Pluralism Monitor (19), knowledge of media literacy initiatives and indicators, and information on the existence of an enabling space for civil society organisations to participate in policy-making and civic discourse. The capacity of all relevant mitigation measures to perform effectively in the local linguistic and electoral context should also be considered. 22. To reinforce internal processes and resources in a particular electoral context, providers of VLOPs and VLOSEs should consider setting up a dedicated, clearly identifiable internal team prior to each individual electoral period (see also section 3.5. ‘During an electoral period’). The resource allocation for that team should be proportionate to the risks identified for the election in question, including being staffed by persons with Member State specific expertise, such as local, contextual and language knowledge. The team should cover all relevant expertise including in areas such as content moderation, fact-checking, threat disruption, hybrid threats, cybersecurity, disinformation and FIMI, fundamental rights and public participation and cooperate with relevant external experts, for example with the European Digital Media Observatory (EDMO) hubs and independent fact-checking organisations (20). 23. The Commission recommends that providers of VLOPs and VLOSEs define in their terms and conditions the period during which measures and resources will be in place that are specific to the mitigation of risks for the electoral process. Certain risk mitigation measures such as additional internal processes or dedicated teams may only be needed around a specific electoral period, depending on the risk of a given provider and the specificities of the election at stake. 24. In addition, some Member States have a set period of time for election campaigning according to national laws, while others do not. This should be taken into account by providers of VLOPs and VLOSEs. In line with insights on expected threat progression during elections from the 2nd EEAS Report on Foreign Information Manipulation and Interference (FIMI) (21), the Commission recommends that, depending on the risk assessment for the particular election and taking into account the applicable electoral procedures, risk mitigation measures are in place and functioning at least one to six months before an electoral period, and continue at least one month after the elections. 25. Depending on the specific context, mitigation measures normally be intensified during the period prior to the date of elections, taking into account national rules on elections, a heightened risk for threats, and the need to provide accurate information on voting procedures.

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Source: EUR-Lex (Cellar) · retrieved 2026-09-07