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Civil Liberties Union for Europe

Liberties

The Civil Liberties Union for Europe is a watchdog NGO protecting human rights and the rule of law.

Lobbying Activity

Liberties demands transparency for monetized political influencer content

24 Oct 2025
Topic — EU initiative addressing unfair digital practices like dark patterns and addictive design.
Message — The organization wants platforms to label content where creators receive financial rewards. They also recommend creating a public repository for all monetized creators.12
Why — Enhanced transparency helps civil society track how commercial interests shape online politics.34
Impact — Tech giants lose the ability to profit from unlabelled and manipulative engagement.5
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Civil Liberties Union: Digital Simplification Must Not Undermine Rights

14 Oct 2025
Topic — The Commission is proposing a digital omnibus to simplify various technology regulations.
Message — Liberties demands that the Commission maintains all digital rights protections and avoids deregulation. They specifically call for the timely implementation of the AI Act without any delays.12
Why — This ensures that human rights and democratic values remain central to EU policy.3
Impact — AI developers and providers would lose the opportunity to delay rules or reduce oversight.4
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Meeting with Birgit Sippel (Member of the European Parliament)

6 Oct 2025 · Tansparency and targeting of political advertising

Response to EU Civil Society Strategy

5 Sept 2025

As Liberties (Civil Liberties Union for Europe) we completed the questionnaire that formed part of this consultation and contributed to submission by Civil Society Europe. The attached presentation details a proposed structure for a Protection Mechanism for Human Rights Defenders and Civil Society Organisations in Europe which should be established as a core component of the future Civil Society Strategy. Liberties will publish a paper in the coming weeks on the Civil Society Strategy which we will share with the Commission. Further details can be found in several past Liberties Publications: 2022 Civil Society Paper: https://dq4n3btxmr8c9.cloudfront.net/files/xlaipc/Liberties_Civic_Space_Policy_Paper_2022.pdf 2025 Rule of Law Report: https://www.liberties.eu/f/vdxw3e 2024: Protection Mechanism: https://www.liberties.eu/en/stories/protection-mechanism-mapping/45162 2025 MFF https://www.liberties.eu/f/15liql
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Response to Guidance on the implementation of Regulation (EU) 2024/900 on the transparency and targeting of political advertising

25 Jun 2025

The Civil Liberties Union for Europe (Liberties) welcomes the European Commissions initiative to develop guidance that supports the consistent application of the Regulation on transparency and targeting of political advertising (TTPA). Clear guidance will be essential to ensure that the Regulation indeed strengthens democracy, the integrity of elections and the fairness of democratic processes. Liberties has previously submitted a detailed position paper to the Commission outlining our key concerns and recommendations. In the context of this call for evidence, we would like to take the opportunity to reiterate the importance of those issues. In particular, we highlight the need for clarification in the following areas: - the broad and potentially ambiguous definition of political advertising, which risks encompassing a wide range of civil society and advocacy communications unless narrowly and precisely interpreted; - the application of the Regulation to political influencers, including the treatment of intent, indirect remuneration, and organic content, where uncertainty may lead to overregulation or inconsistent enforcement; - the interpretation of best efforts under Articles 12 and 15, especially with regard to the correction of incomplete information and the design of notification mechanisms for non-compliant ads; - the possible chilling effect on CSOs relying on third-country funding, particularly in the pre-election period, where safeguards are needed to prevent disproportionate restrictions on rights-based advocacy; - and the need for guidance on the division of responsibilities among competent authorities to ensure coherent enforcement and avoid regulatory fragmentation. As the TTPA allows for multiple divergent interpretations, it is essential that the Commission provides clear and practical guidance that can be consistently applied by both enforcement authorities and relevant market actors. Liberties appreciates the opportunity to contribute to this process and remains committed to supporting a rights-respecting implementation of the Regulation.
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Civil Liberties Union backs standardized political advertising labels

28 May 2025
Topic — Technical specifications for the format and template of political advertising transparency labels.
Message — The group supports information-rich labelling to help voters understand how they are being targeted. They recommend monitoring market impacts on small providers and researching label effectiveness in real-world contexts.123
Why — Detailed templates will help civil society organizations monitor compliance and close loopholes.4
Impact — Smaller advertising providers risk being driven out of the market by technical requirements.5
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Meeting with Anna Herold (Head of Unit Communications Networks, Content and Technology) and Reporters sans frontières and

22 Jan 2025 · Exchange of views in the context of preparatory work on draft guidelines on Article 18(1) European Media Freedom Act (EMFA) to be issued by the European Commission under Article 18(9) of the EMFA. Anna Herold was replaced by Audrius Perkauskas

Response to Report on the 2024 elections to the European Parliament

4 Dec 2024

The Civil Liberties Union for Europe (Liberties) appreciates the opportunity to contribute to this important initiative. In the attached report (Understanding Threats to Election Integrity in the Digital Age: 2024 European Parliamentary Elections), Liberties shares the findings of its 2024 European elections monitoring exercise, offering insights and recommendations to support free, fair, and resilient elections across the European Union. The report examines the role of digital platforms in the 2024 European Parliament (EP) elections and evaluates compliance with key EU regulations: General Data Protection Regulation (GDPR), Digital Services Act (DSA), and (Regulation on Transparency and Targeting of Political Advertising) TTPA. The findings are based on data from six EU Member States (Bulgaria, France, Germany, Hungary, Poland, Spain) and focused primarily on Facebook and YouTube due to their widespread use and data availability. Key findings: Targeting practices: Political advertisers extensively used Facebooks Custom Audiences and Lookalike Audiences to target supporters. Interest-based targeting and age-based targeting were also prevalent, while gender-based targeting was rare but notable in some instances. Ad delivery algorithms may contribute to public discourse fragmentation, with minimal transparency regarding how ads are distributed across audiences. Transparency issues: Googles and Metas ad repositories provide insufficient information, with Googles lacking keyword search and platform-specific breakdowns. Defining political advertising: TTPAs broad definition of political advertising risks non-compliance from platforms like Google, which announced plans to cease serving political ads in the EU. Key recommendations: Strengthen enforcement capacities for GDPR, DSA, TTPA. Improve transparency in targeting practices and ad delivery algorithms. Introduce spending caps and transparency requirements to ensure fair political competition. Liberties hopes that the insights and recommendations shared in our report will contribute to reaching the goals of this initiative. We remain at your disposal for any further discussion on the findings presented. Thank you for considering our input.
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Meeting with Daniel Freund (Member of the European Parliament) and Amnesty International Limited and

16 Oct 2024 · Cooperation on LIBE related matters

Meeting with Tineke Strik (Member of the European Parliament) and Amnesty International Limited and

16 Oct 2024 · LIBE Civil Society Meeting

Liberties Urges Clear and Accessible EU Digital Transparency Reports

24 Jan 2024
Topic — This consultation addresses mandatory templates for content moderation transparency reports under the DSA.
Message — They demand that transparency reports remain clear, meaningful, and easily comprehensible. They also request the use of open-source formats for better data analysis.12
Why — Standardized data would improve their ability to monitor risks to democratic civic discourse.3
Impact — Tech platforms would lose the freedom to use diverse and non-comparable reporting models.4
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Meeting with Maurits-Jan Prinz (Cabinet of Commissioner Thierry Breton) and Forum Civique Européen and European Center for Not-for-Profit Law Stichting

20 Nov 2023 · AI Act

Meeting with João Albuquerque (Member of the European Parliament)

29 Sept 2023 · European Media Freedom Act

Response to Recommendation on covert interference from third countries

13 Apr 2023

Civil society organizations are critical to protecting the resilience of our democracies, therefore, any initiative aimed at protecting and promoting democracy needs to foster an enabling environment. However, the concrete measures envisaged to be part of the Defence of Democracy package are at odds with the goals of the package, because they risk having a serious negative impact on civic space. First of all, it is far-reaching to maintain that all entities, including NGOs, which pursue lobbying activities and receive funding from third countries, are potential tools for covert foreign interference. Transparency obligations, in order to be justified, should be based on real, rather than hypothetical danger. Secondly, the concept of lobbying activities in this context is overly vague. The Venice Commission considers that only a narrow category of formal lobbying activities involving communication with public officials with the aim of influencing public decision-making may justify the imposition of funding transparency requirements. Imposing transparency obligations on the basis of flawed assumptions and vaguely worded concepts risks creating a burden for civil society actors disproportionate to the activities they carry out. This risk is already demonstrated by the concrete application of the US Foreign Agents Registration Act, which has seen organisations receiving support from abroad in the pursuit of legitimate aims caught up in its registration requirements. In addition, the margin of appreciation which EU governments will have in transposing the directive risks unintended, damaging consequences for NGOs, such as authoritarian governments introducing more restrictive measures to tarnish critical voices. Given that many NGOs rely on funding by foreign entities to carry out their advocacy and campaigning work, the directive risks having a serious chilling effect. Furthermore, over-regulation targeting entities, including NGOs, involved in public affairs on grounds that they receive foreign funding risks feeding smear campaigns already used to destroy public trust in civil society. The purported measures are likely to be weaponized by authoritarian governments to fuel attacks on civil society. They may also represent a threat to the EUs credibility: given the context of the EUs own efforts to de-stigmatise NGOs receiving foreign funding, including EU funding, the EU risks damaging its own reputation. Alternative solutions to address the EU and its Member States legitimate concerns regarding covert foreign interference, which dont unduly restrict civic space, should be considered: - Impact assessment: A fundamental rights impact assessment, ideally carried out in consultation with expert human rights bodies as well as civil society, should take place to assess whether the measures envisaged unduly restrict freedom of association and are fit for purpose, and to explore alternative policy options. - More targeted measures and a different framing: Use pre-existing tools, such as strengthening the EUs transparency register and better enforcement of existing rules on ethics of officials and MEPs. Targeted rules on the transparency of interest representation at national level could be considered as part of legislation aimed at providing safeguards for the free establishment and operations of non-profits across the EU, in full respect of their role and freedoms. - Investing in positive measures: The EU should privilege positive measures aimed at strengthening the EUs resilience to covert foreign interference over restrictive measures which carry a serious risk of negative impact on the democratic space as a whole. - Pursuing a clear and coherent democratic agenda: The EU should lead by example by pursuing a coherent democratic agenda to respond to existing threats, both in its internal policies and its external action, including by integrating objectives to be achieved through the EUs funding and support policy.
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Meeting with Ramona Strugariu (Member of the European Parliament, Rapporteur for opinion) and Transparency International Liaison Office to the European Union and

26 Jan 2023 · Anti-SLAPP Directive

Civil Liberties Union Urges Stronger Media Independence and Transparency

20 Jan 2023
Topic — New EU regulation aims to protect media freedom and pluralism across Member States.
Message — Liberties seeks to limit the circumstances of journalist surveillance and broaden media ownership transparency. They demand the media board receive more autonomy and recommend rejecting Article 17 privileges. The group also proposes lowering the threshold for reporting on state advertising spending.123
Why — This would advance their mission by embedding human rights protections into EU media law.4
Impact — Opaque local governments and rogue media outlets would lose their ability to hide funding.56
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Meeting with Paul Tang (Member of the European Parliament, Shadow rapporteur for opinion) and European Partnership for Democracy and

21 Jun 2022 · Shadows meeting on Political Advertising with stakeholders

Meeting with Věra Jourová (Vice-President) and Greenpeace European Unit and

28 Apr 2022 · SLAPP

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

20 Jan 2022 · Digital Issues

Meeting with Didier Reynders (Commissioner) and

19 Jan 2022 · Rule of Law

Meeting with Irina Stefuriuc (Cabinet of Vice-President Věra Jourová) and ARTICLE 19 and Umweltinstitut München e.V.

13 Jan 2022 · SLAPP

Meeting with Věra Jourová (Vice-President) and Amnesty International Limited and

9 Nov 2021 · Rule of Law

Response to Requirements for Artificial Intelligence

14 Jul 2021

The Civil Liberties Union for Europe (www.liberties.eu) welcomes the opportunity to provide feedback to the AI Regulation proposal. We recognize that Artificial Intelligence (AI) can contribute positively to our societies. But AI systems can also undermine our fundamental rights, by perpetuating bias in criminal justice, manipulating public opinion and enabling mass surveillance practices. Liberties’ aim is to make sure that the Regulation protects the fundamental rights of EU citizens. In general, the proposal marks an improvement to last year’s White Paper. Recognizing that AI should be “a force for good in society with the ultimate goal of increasing human well-being” is the right approach. Article 5, which bans AI systems considered “unacceptable as contravening Union values”, and Article 60, which suggests the creation of a database for high-risk systems, are much welcome initiatives. However, the proposal contains certain loopholes that can lead to severe breaches of fundamental rights. Six issues are of special concern. First, the proposal’s prohibition of remote biometric recognition technologies contains too many exceptions. The vague wording leaves room for discretion: Law enforcement authorities can justify the use of facial recognition technologies and circumvent the obligatory authorization by a judicial authority in “a duly justified situation of urgency”. Further, the ban only concerns ‘real-time’ remote biometric identification systems, allowing law enforcement authorities to first collect the data and then mine it, using mass surveillance technologies. In addition, the ban only concerns law enforcement authorities. Other public authorities and private actors are exempt, although the risks associated with these systems remain. Similarly, the ban on social scoring systems does not apply to private actors. Second, the proposal fails to recognize the risks of predictive policing, although multiple studies have shown that they are, by default, discriminatory towards marginalized communities. Furthermore, there is little evidence of the effectiveness of such systems and a lack of transparency as to where they are used and by whom. Third, the proposal severely underregulates biometric categorization, emotion recognition and systems that manipulate image, audio or video content, such as deep fakes. Biometric categorization systems discriminate against non-binary people and minority groups and can be dangerous for people belonging to the LGBTQI+ community or political dissidents. Systems that generate or manipulate content are used to humiliate people, spread disinformation and interfere in democratic processes. Emotion recognition technologies are unreliable and prone to bias. It is extremely disconcerting to see how the proposal underestimates the potential impact they can have on a person’s life and access to opportunities. Fourth, businesses with high stakes in seeing their products make it to the market are allowed to self-regulate. This is an inappropriate solution because businesses have no incentive or inclination to proceed with caution and respect for fundamental rights, but are rather keen to downplay the risks and release their products as soon as possible. Fifth, it is not clear how the Commission wants to ensure enforcement. The proposal to create an AI board is sensible. However, it is not given sufficient autonomy to act independently from the Commission and not given sufficient resources to act effectively. The proposal further suggests that each Member State create their own national competent authority, which may come into conflict with existing authorities. Sixth, the proposal fails to address power imbalances between providers of AI systems and consumers. It lacks clarity around citizens’ rights to lodge complaints and access to a remedy for persons adversely affected by AI systems. Find further information and recommendations in the attached paper.
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Response to Guidance on tackling disinformation

29 Apr 2021

The Civil Liberties Union for Europe (Liberties) submits its policy paper in a pdf attachment. Here we list the key findings of our report. - The EU is under an obligation to respect the Charter of Fundamental Rights in addressing disinformation. Therefore, any solution to mitigate the impact of disinformation should respect the users' fundamental rights, primarily freedom of expression and the protection of personal data. - One of the EU’s goals is to promote the values on which it is founded, including democracy. Healthy democracy furthers the well-being of citizens and provides an environment where commercial enterprises can flourish. Private commercial interests cannot be allowed to undermine the very democracy that allows them to prosper. - The EU's response to disinformation should not be to further empower big tech companies. Authorising or mandating tech companies to engage in more data gathering, more tracking, more monitoring, and more fact-checking would give them more information about their users. This will provide them with even greater power and influence and allow them to collect the very kind of information that makes disseminating disinformation possible and profitable. - A common definition is needed for disinformation in order to elaborate the scope of any regulation properly, let that be self- or co-regulation or legislative approach. The definition should be limited to avoid possible over-regulation that would pose unjustifiable limitations on free speech. - To protect democracy and fundamental rights, policy-makers, researchers and regulators must understand the impact of tech companies on fundamental rights and democratic debate. Therefore, tech companies must be transparent about their activities. They should provide coherent reports, meaningful data sets, and both state- and language-level databases. - Tech companies must also be transparent about their algorithms. Tech companies might have legitimate interests in selling their goods and services and protecting their intellectual property. However, this cannot be accepted as a justification to bar users, researchers, and regulators from understanding what goals and criteria companies have built into the algorithms they use in order to protect democracy and fundamental rights. - Strengthening measures to protect the integrity of their services against the use of manipulative techniques will limit the amplification of disinformation campaigns. Therefore, risk assessment and risk mitigation, service design, including the recommender system, content curation and moderation, and the advertising system should be transparent and auditable. - We warn against 'real account policy' or suspending the opportunity to communicate anonymously. At-risk groups, such as members of the LGBTQ community, people who live with mental illness, or victims of domestic violence, are either targeted by their governments or face societal discrimination. These groups rely on anonymity to protect themselves and should not be deprived of access to services, such as social media platforms. - Tech companies employ micro-targeting/surveillance advertising by using user data as the basis for decisions about what adverts to show them. This misuse of data to manipulate users reinforces the need for a strong ePrivacy Regulation to change the balance of incentives for companies away from a model that relies on data harvesting and data dissemination. - Fact-checking is a somewhat limited solution to counter disinformation. The mere act of signalling to users that content they see has been fact-checked as accurate or not can play a role in mitigating the impact of disinformation. However, further action such as removing or blocking content should be based on a transparent mechanism with safeguards such as human review.
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Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services

30 Mar 2021

The Civil Liberties Union for Europe submits its position to give feedback to the European Commission about the Proposal for a Regulation of the European Parliament and of the Council on a Single Market For Digital Services (Digital Services Act). See the attachment in pdf. We strongly support that the Digital Services Act (DSA) is not an updated version of the 20-year-old eCommerce Directive but instead delivers a new concept of data economy and digital ecosystem, introducing new rules on intermediary services and the enforcement of the law. We need new rules and measures to restore the equilibrium, where the fundamental rights of users, the digital market system, and innovations are in balance. We need big platforms to change, have accountability to users, and ensure that users’ fundamental rights are respected. The role of the big platforms has changed significantly in the past years. They have grown into state-size companies with a huge influence on democratic institutions, such as public debate, the outcome of elections, freedom of expression, and privacy. These big tech companies enjoy the ability to monitor users’ activities and create profiles to sell or use for targeted advertising, while at the same time they are able to set the rules for content curation, access to information, and, ultimately, freedom of expression. Because of their size and power, these companies also limit the possibility of free competition and for newcomers to enter the market. These companies are not only similar size-wise and financially to a state, but they also impose regulation on users through terms of services and act as privatized law enforcement entities to regulate speech and avoid liability for user content set out in the laws. Now DSA offers an opportunity to change this system for the better. In the attachment, Liberties analyzes the rules of the proposed DSA and flags the elements that need to be revised. Our approach is based on fundamental rights. We need legislation that serves to better protect consumers and fundamental rights online, establishing a powerful transparency and accountability framework for online platforms, and leading to fairer and more open digital markets.
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Meeting with Věra Jourová (Vice-President)

26 Mar 2021 · Anti-SLAPP coalition launch

Meeting with Didier Reynders (Commissioner) and

22 Jul 2020 · Anti-SLAPPs measures

Meeting with Věra Jourová (Vice-President) and Reporters sans frontières and

20 Jul 2020 · Media freedom

Response to New competition tool

30 Jun 2020

The European Commission rightly highlights that a small number of large online platforms are now able to control the entire platform ecosystem, and that they act as economic gatekeepers. The Commission also mentions that these online platforms increasingly determine 'the parameters for future innovations, consumer choice and competition'. We agree, but we are convinced that the challenge is broader than that. We believe that this small number of large online platforms not only act as economic gatekeepers, but also as 'fundamental rights' gatekeepers. Through their business models, their terms of services and community guidelines, these platforms set standards in the market with regards to, among others, consumers' rights to privacy, data protection and freedom of expression. These large platforms are able to do so because, on the one hand, barriers to entry are so high that it is extremely difficult, if not impossible, for new players to enter the market and put competitive pressure on gatekeepers. And, on the other hand, because consumers do not have viable alternatives to switch to. Data harvesting business models and content curation and distribution practices also result in uncertainty and lack of transparency around how we form our opinion on platforms and how these mechanisms impact, structure, and potentially control the public discourse. In addition to the impact on media pluralism, democratic debate, participation and political processes and fundamental rights, these business choices lead to further engagement on the platforms that helps these companies' that cements their market power. The impact of these platforms' behaviours and business models on the guarantee of fundamental rights in the digital single market is a major challenge for the EU, and the European Commission should include it in its understanding of the problem it aims to fix with these welcomed initiatives. Furthemore, the Commission points at the imbalance in bargaining power between large platforms and consumers. Once again, we highlight that the consequences of the imbalance are not simply economic. Consumers are deprived of the capability to negotiate not only prices (indeed, the majority of these services are provided for 'free', or without the need for a monetary payment), but also other elements, such as, for example, to what extent are their data protected by the service provider or to what extent the automated systems for content moderation used by the platforms affect their exposure to content diversity. At this point we underline that it is essential that, throughout this process, personal data is not regarded/framed as a mere economic asset and urge caution in this regard. It is essential that the Commission does not endorse the position that many companies take, that there is a binary choice between offering up your data or receipt of a service. There is a risk that the already asymmetrical situation is further exacerbated with any effort to monetise data.
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Response to Digital Services Act package: ex ante regulatory instrument of very large online platforms acting as gatekeepers

30 Jun 2020

To Whom It May Concern: Hereby I submit the feedback on behalf of the Civil Liberties Union for Europe. In case of any questions please contact info (at) liberties.eu. Kind regards, Eva Simon
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Response to EU Whistleblower protection

13 Jul 2018

Civil Liberties Union for Europe submits its opinion (see attached file) on the proposal for the Directive of the European Parliament and of the Council on the protection of persons reporting on breaches of Union law. Civil Liberties Union for Europe (Liberties) is a European non-governmental watchdog organisation. Liberties’ mission is to promote, protect and uphold human rights, civil liberties, the rule of law and democratic values in the European Union. Liberties is built on a network of 16 national civil liberties NGOs from across the EU. Liberties, together with its members, carries out advocacy, campaigning and public education activities.
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Meeting with Thomas Zerdick (Cabinet of First Vice-President Frans Timmermans) and Helsinki Foundation for Human Rights

22 Feb 2018 · Rule of Law in Poland

Meeting with Thomas Zerdick (Cabinet of First Vice-President Frans Timmermans) and Magyar Helsinki Bizottság and Társaság a Szabadságjogokért

10 Oct 2017 · Exchange of views on the current situation with NGOs in Hungary