§3.5 During an electoral period

51. During the electoral period, in which measures and resources will be in place that are specific to the mitigation of risks for the electoral process, the Commission recommends that providers of VLOPs and VLOSEs pay specific attention to risk mitigation measures that reduce the impact of incidents that can have a significant impact on the election outcome or turnout. 52. This includes providing users with access to reliable, timely and intelligible information from official sources on how to vote as well as on the voting process or measures like those mentioned in section 3.3 to reduce the potential harm of high impact issues such as manipulated images, voice recordings or deepfakes, for example of political actors contending in elections. Providers of VLOPs and VLOSEs should also ensure that are able to react rapidly to manipulation of their service aimed at undermining the electoral process and attempts to use disinformation and information manipulation to suppress voters. 53. Incidents occurring on- or off- platform during an electoral period can have rapid and high-impact consequences for the integrity of elections or public security. The Commission recommends, as a result, that providers of VLOPs and VLOSEs put in place an internal incident response mechanism, involving also the senior leadership, as well as a mapping of the stakeholders involved within the organisation in responding to the incident. This procedure should be set-up, agreed-upon and tested, including through red teaming exercises, beforehand so it can be applied quickly. This procedure also needs to be consistent, repeatable and auditable, and produce well-documented decisions and outcomes, so that providers of VLOPs and VLOSEs can review their responses after high impact events. 54. Considering the need for the rapid application of mitigation measures, the Commission also recommends that providers of VLOPs and VLOSEs establish cooperation and swift and efficient exchange of information cross-platform and with relevant non-state actors that have knowledge and expertise relevant for elections; these actors could include stakeholders from civil society organisations, academia and researchers, independent media and others. Considering the cross-platform nature of illegal and/or harmful content, as well as of disinformation and FIMI activity, cooperation amongst VLOPs and VLOSEs themselves to share relevant information, as well as their cooperation with smaller platforms and services is crucial to mitigate these risks effectively. This will help providers of VLOPs and VLOSEs to react more swiftly to emerging issues and incidents, better understand the context, adapt their mitigation measures, and help them assess the effectiveness of their actions taken. The efficiency of this cooperation and this exchange of information is particularly essential due to the time-sensitive nature of such events. It therefore should include reactions from providers of VLOPs and VLOSEs and meaningful feedback to relevant non-state actors involved – within a reasonable timeframe – allowing assessment of the efficiency and impact of this cooperation and exchange. 55. The rapid response system to be established by the signatories of the Code of Practice on Disinformation is a good example of such a forum for cooperation during elections, feeding into the platforms incident response mechanisms. Providers of VLOPs and VLOSEs should set out, together with the other signatories, the procedural framework for cooperation and coordination between them during elections, including a rapid feedback mechanism with the need of swift, efficient, and appropriate follow-up by platforms. 56. Another example on how to organise the work on responses to FIMI and disinformation can be found in the second EEAS Report on FIMI Threats (36) which puts forward a “Response Framework” effectively linking analysis to evidence-based responses while highlighting the importance of cooperation between various stakeholders. Inspiration could also be drawn from initiatives like the Information Sharing and Analysis Center on Foreign Information Manipulation and Interference (FIMI-ISAC) (37). Such a FIMI-ISAC aims to promote the sharing of information between all stakeholders about root causes, incidents and threats, and the sharing of experience, knowledge and analysis. 57. A timely response to incidents is often key. The Commission recommends that providers of VLOPs and VLOSEs consider a ‘follow the sun’ model in which offices around the world would be able to cover all time zones. 58. To react in a timely manner, providers of VLOPs and VLOSEs should integrate their possible collaboration with electoral authorities and relevant non-state actors in incident response mechanisms.

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