§3.4 Cooperation with national authorities, independent experts and civil society organisations

43. Contributing to protecting the integrity of a specific election cannot be done without knowledge of the specific national, legal, societal, and political context as well as timely reactions to real-time developments affecting the risks generated by VLOPs or VLOSEs services. Procedures and organisational structures for elections differ from Member State to Member State and even from one election to another. Providers of VLOPs and VLOSEs should be aware of the applicable national election governance structure for the elections at hand and the role of various authorities. By gaining a good understanding of specific national procedures such as the delimitation of the electoral campaign periods, timing of the official designation of election candidates, and election silence periods, providers of VLOPs and VLOSEs may design risk mitigation measures taking into account the specific aspects of the relevant Member State. 44. To this end, the Commission recommends that providers of VLOPs and VLOSEs regularly and, where necessary, urgently, exchange information with and have contact points for competent national and European authorities, involving the Digital Services Coordinator of their Member State and, where appropriate, competent regional and local authorities, to facilitate the exchange of information, as well as the Commission, as appropriate. 45. The goal of such interactions between providers of VLOPs and VLOSEs and competent national authorities should be limited to share information that can inform risk assessments and mitigation measures on electoral processes or can inform national authorities’ actions that are within their competence to protect the integrity of electoral processes. For example, relevant national authorities can provide providers of VLOPs and VLOSEs with official information on the voting process that can be integrated in their services, and where possible and appropriate, provide them with information on possible risks for the electoral process, which can inform the mitigation measures providers of VLOPs and VLOSEs put in place. In return, information on the risks providers of VLOPs and VLOSEs mitigate on their service can be relevant for competent national authorities’ work in protecting the integrity of electoral processes. To the extent that such interactions do not fall within the scope of the transparency reporting obligations under Regulation (EU) 2022/2065, the Commission recommends that national authorities and providers of VLOPSs and VLOSEs transparently report about them, for example in public documents in which national authorities evaluate the electoral process, or in transparency reporting that follows from Regulation (EU) 2022/2065. 46. The Digital Services Coordinators designated under Regulation (EU) 2022/2065 in each Member State may serve as contact points for providers of VLOPs or VLOSEs, should it not be clear which national authority is competent for issues related to risk mitigation on electoral processes. As Digital Services Coordinators function as the single contact point with regard to all matters related to the application of Regulation (EU) 2022/2065 in a Member State, the Commission recommends that the Digital Services Coordinators are involved in the exchanges between providers of VLOPs and VLOSEs and competent national authorities on the electoral process. Additionally, the Commission recommended to Member States to strengthen their national election networks (32) and to facilitate their cooperation with relevant stakeholders (33). These national election networks can also be a relevant contact point for providers of VLOPs and VLOSEs. 47. Alongside cooperation with national authorities, providers of VLOPs and VLOSEs are also recommended to establish strong cooperation with relevant non-state actors as such actors play a key role in protecting electoral processes. Prior to the elections, providers of VLOPS and VLOSEs may organise meetings as well as establish channels of regular communication with non-state actors active in electoral processes such as academics, independent experts, civil society organisations and representatives of various communities, and invite them to share their independent expertise, insights and observations that can help identify risks that may require mitigation measures and contribute to the development of such mitigation measures. 48. Establishing channels for communication during the election campaign with non-state actors, including campaign organisations and election observers, will help providers of VLOPs and VLOSEs to better understand the context of the elections so as to react promptly in emergency situations, to design and calibrate risk mitigation measures and to understand better how their mitigation measures work in the local context. The Working Group on Elections of the Code of Practice – and its rapid response system – is a good example of such an existing and active multistakeholder forum, including NGOs and fact-checkers with important election specific experience. The EDMO Task-force on Elections – composed of independent fact-checkers, academics, and media literacy specialists – as well as the EDMO hubs across the EU can also provide important input in this respect. 49. The availability of trustworthy information from pluralistic sources is crucial for well-functioning democratic electoral processes. It warrants not only protection from external commercial and political interference, but also from potential misapplication of the internal processes of VLOPs and VLOSEs, as recognised by Article 17 of the proposed European Media Freedom Act (34). Journalists and media service providers fulfil a vital role in gathering, processing, and reporting information to the public, a role even more critical during election times. Independent news media service providers and organisations with well-established internal editorial standards and procedures are widely regarded as trusted sources of information. Providers of VLOPs and VLOSEs should, therefore, collaborate with independent media organisations, regulatory authorities, civil society and grassroots organisations, fact-checkers, academia, and other relevant stakeholders on initiatives to enhance the identification of trustworthy information and users’ accessibility to pluralistic news media content related to elections from trusted sources. 50. Considering the important role in judging the veracity of information that such organisations have, the Commission recommends that providers of VLOPs and VLOSEs collaborate with independent fact-checking organisations that adhere to high standards of methodology, ethics and transparency, for example by being a member of the European Fact-Checking Standards Network (EFCSN) and following its Code of Standards (35). The Commission recommends that such collaboration is transparent. For example, some signatories of the Code of Practice on Disinformation list the fact-checking organisations they have agreements with.

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