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Democracy Reporting International

DRI

Democracy Reporting International operates on the conviction that democratic, participatory governance is a human right and governments should be accountable to their citizens.

Lobbying Activity

Meeting with Daniel Freund (Member of the European Parliament) and European Implementation Network

25 Nov 2025 · Speaker at event: "2025 Report – Justice Delayed, Justice Denied - The non-implementation of European Courts’ Judgments and the Rule of Law in the EU"

Response to Digital package – digital omnibus

14 Oct 2025

Our commentary addresses the Digital Omnibus proposal, specifically in relation to modifications to the AI Act. Below, we outline some initial concerns about the Call for Evidence and the broader context in which it has been issued: -We support a digital regulatory framework for the benefit of all involved. The current set-up is too complex in terms of rules and regulatory institutions and bodies. At the same time, we would expect a robust evidence base for such simplification (a clear analysis of overlaps, duplication and redundancies) and a justification of why such problems cannot be solved through other mechanisms such as standards, Codes of Conducts, or Guidelines. Without such evidence, there is a major risk that simplification is a code word for deregulation. We do not support the uncritical endorsement of the Draghi report that makes the US the measure of successful economics. Instead, one should look at globally successful economies (Netherlands, the Nordic states, Switzerland) that are in line with the European model of social market economy and fair competition. -Given the current stage of implementation of AI obligations, claims that it is harming competitiveness remain speculative. Evidence-based policymaking requires regulatory obligations to be balanced with their economic burden based on empirical data. Broad scope of potential intervention. When it comes to the AI Act, the Call for Evidence is notably broad. It states that the proposed intervention aims to ensure the optimal application of the recently adopted rules and provide legal predictability to businesses. It also notes that implementation challenges were identified through consultations with stakeholders and Member States but does not specify the nature or extent of these challenges. -We are concerned that the simplification package will lead to a reopening of the AI Acts core obligations, elements that were the result of a long and difficult negotiation process. In particular, we would advise caution against revisiting key elements such as the risk classification framework (i.e., prohibited, high-risk, and General-Purpose AI systems with systemic risk), the risk identification and mitigation requirements (including Fundamental Rights Impact Assessments for high-risk systems), transparency obligations across the AI value chain, and incident reporting requirements. These measures are central to ensuring accountability, protecting fundamental rights, and maintaining the EUs leadership in setting global standards for trustworthy AI. Growing pressure to stop the clock on AI Act implementation. We are aware of growing calls from tech industry players to delay the implementation of the AI Act by up to two years, citing the slow progress in developing harmonised European standards (hENs) for high-risk AI systems . While we recognise the importance of robust standardisation, we believe that postponing the AI Acts implementation is not helpful and responsible. It is worth noting that tech industry representatives and consultancy firms linked to them reportedly make up around 55% of the members of the CEN-CENELEC committee drafting the hENs . Moreover, extending the timeline does not guarantee a faster or more effective standardisation process; on the contrary, it may dilute the political momentum. In addition, in the last months the Code of Practice on General-Purpose AI entered into force, and the drafting process for the Code of Practice on Transparent AI systems (obligations under Art. 50 of AI Act) has also started. These developments signal a continued progress in the implementation, and further clarity on how tech industry should comply with some of the most stringent AI Act obligations.
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Response to EU Civil Society Strategy

5 Sept 2025

Civil society actors are vital to upholding democracy, human rights, and social cohesion throughout the European Union. They give voice to diverse communitiesespecially those that are marginalised or underrepresentedby ensuring their participation in democratic life and by holding institutions to account. Many organisations also provide essential services that support people and communities directly, stepping in during crises and addressing needs where public systems fall short. We support the detailed recommendations of Civil Society Europe (attached). We therefore welcome the proposed EU Civil Society Strategy. This is a long-overdue step to recognise civil society not only as a policy implementer, but as a genuine partner, and to equip it with the resources and tools necessary to thrive. In recent years, however, civil society across the EU has come under extraordinary pressure. Shrinking civic space, restrictive laws and procedures, smear campaigns, abusive lawsuits, surveillance, and growing financial insecurity are eroding CSOs ability to act freely and effectively. These threats weaken both democracy and fundamental rights within the Union. A strong, coherent, and adequately funded Civil Society Strategy is essential to protect and empower civil society so it can continue its indispensable role. Key initiatives we expect to be included in and fostered through the Civil Society Strategy include: 1. Carry out a systematic civic space impact assessment across all legislative and regulatory proposals, to ensure that all EU policies support rather than restrict civic space. 2. Develop clear EU guidelines outlining both legal and non-legal actions to prevent and respond to civic space deterioration, including structured engagement with national authorities. 3. Develop a comprehensive, multi-layered EU protection system for Human Rights and Environmental Defenders and Civil Society Organisations. 4. The coordinated EU protection system would provide timely legal, financial, psychosocial, and digital security support to defenders and CSOs under attack. This system should be independent, sustainable, and rooted in human rights standards, with rapid response capacity and follow-up for systemic reform. 5. Ensure strong and structural support for civil society in the new MFF through directly managed funding programmes dedicated to civil society and strengthening civic space. Increase the overall funding allocation to Operating Grants, improve their accessibility, explicitly include advocacy as a legitimate activity, and simplify their functioning procedures. 6. Develop a binding Agreement on Civil Dialogue between the European Commission, the European Parliament and the Council of the European Union to establish regular structured practices of engagement of civil society across all stages of the policy cycle. Include specific provisions dedicated to civil dialogue within the Better Regulation toolbox, to ensure the European Commissions engagement with civil society is meaningful and result-oriented. 7. Structure the upcoming Civil Society Platform as a mechanism to support systematic, transversal and vertical dialogue between the EU Commission and values-based civil society organisations and strengthen civic participation in shaping the political agenda. 8. Encourage Member States to develop formal, transparent, and inclusive civil society engagement frameworks to strengthen civil dialogue and participation mechanisms at the national level 9. Develop recommendations for an enabling environment for civil society at national level. 10. Remove obstacles to cross-border cooperation of non-profit organisations and foundations in the single market, guaranteeing them freedom of establishment and free movement of goods, services and capital. The European Cross-Border Association Directive would be an important first step.
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Response to European Democracy Shield

23 May 2025

This submission combines the joint recommendations led by the European Partnership for Democracy (EPD) and points made by Democracy Reporting International as lead of the Nets4Dem consortium to the Horizon Europe consultation to the EDS. Joint recommendations by EPD: 1. The European Democracy Shield should enable the swift and effective implementation and enforcement of existing legislation in this domain such as the Digital Services Act, Digital Markets Act, the Regulation on the Targeting and Transparency of Political Advertising, the European Media Freedom Act and the AI Act. 2. Combatting disinformation is a necessary and inevitable component of the democracy support agenda. 3. A robust media sector working in the public interest is one of the strongest guarantees against the harmful effects of disinformation and polarisation. 4. The European Democracy Shield should encompass both an internal and external dimension. Strengthening democratic standards in neighbouring regions will create a more stable environment for the European Union. 5. A stronger commitment to ensuring an enabling environment for civil society to operate in, and for citizens to mobilise and make their voices heard. 6. As a foundational value of the EU, democracy should be at the core of the EUs security and defence strategy. Such a strategy must ensure that fundamental rights and democratic standards are not sacrificed in the name of strengthening Europes security. 7. The European Democracy Shield should help create interlinkages and strategic coordination between different Directorates, Departments and Agencies, the EEAS and the Service for Foreign Policy Instruments to ensure a holistic approach to democracy support. Nets4Dem recommendations: 1. Dis- and misinformation 1.1 The European Commission must prioritise mitigating AI-related threats to pluralism, democratic processes, and electoral integrity. 1.2 AI governance should account for cultural risks that impact public discourse, collective identity, and civic engagement. 1.3 Increase funding for Civil Society Organisations and independent research to monitor Digital Services Act (DSA) and AI Act compliance. 1.4 Strengthen national-level DSA implementation by supporting Digital Services Coordinators (DSCs) to effectively enforce the DSA, particularly regarding non-VLOPs. 1.5 Standardised guidelines for researcher access to publicly available data under Article 40(12) of the DSA. 2 Rule of Law 2.1 Strengthen the role of the Court of Justice of the European Union (CJEU) in protecting European Parliament (EP) elections by giving it the final interpretation and oversight of election-related cases. This requires establishing an emergency preliminary ruling procedure. 2.2 Enhance oversight of electoral processes before the 2029 elections by enhancing a uniform interpretation of EU election law, thus maintain the legitimacy of the European Parliament and protecting equal voting rights across Member States. The CJEU should closely monitor EP elections. 3 Emerging Technologies 3.1 The EU must tackle the dominance of large platforms over data accumulation and advertising revenue, which distorts the democratic information space. 3.2 The EU should enhance efforts to counter disinformation by equipping citizens with media literacy tools and debunking frameworks. 3.3 Ensure ethical AI, democratic oversight, and accountability in AI governance. 3.4 The AI Office must prioritise democracy-related concerns in AI governance by ensuring meaningful civil society representation. 4 Democratic Innovation 4.1 Strengthen participatory democracy through capacity-building and quality control by supporting governments and civil society to enhance participatory democracy at the local level and counter populist narratives. This requires investing in capacity-building initiatives. 4.2 Establish a clear framework for European quality standard for ensuring fairness, transparency, and legitimacy in deliberative processes.
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Meeting with Marie-Helene Boulanger (Head of Unit Justice and Consumers) and EU DisinfoLab and

29 Apr 2025 · Consultation of civil society representatives in the context of the preparation of the upcoming European Democracy Shield (“focus group”)

Meeting with Florian Geyer (Head of Unit Justice and Consumers) and European Implementation Network

10 Mar 2025 · Rule of Law Report

Response to Delegated Regulation on data access provided for in the Digital Services Act

25 Nov 2024

We, Democracy Reporting International -DRI- and the undersigned organisations, Das Nettz, Fundación Maldita.es, and Science Feedback, sincerely appreciate the European Commission's efforts in shaping the data access framework under the DSA. We recognize that this is a complex issue, intersecting with various regulations and requiring significant coordination among different authorities. Before addressing potential areas for improvement, we would like to highlight some of the most positive aspects of this Delegated Act that we strongly believe should remain part of the framework 1. We appreciate the inclusion of Art. 15 (3) in the Delegated Act, which states that data providers cannot impose archiving, storage, refresh, and deletion requirements that hinder the research referred to in the reasoned request in any way. Given that the vetted researcher mechanism represents the most stringent form of data access for researchers, we believe that this provision should also extend to Art. 40 (12), which is less restrictive. Put simply, if such requirements are prohibited in the most restrictive mechanism, they should not be permitted in a less restrictive context either. 2. We also commend the inclusion of an Independent Advisory Mechanism as a third-party body that DSCs may consult when assessing data access applications and amendment requests. However, we recommend making this consulting mechanism mandatory, at least during the initial years of the data access framework's implementation, to help establish a solid baseline for future cases. 3. Finally, we welcome the introduction of a Data Access Portal, which will be essential in streamlining data access applications. In particular, the requirement for DSCs to publish their reasoned requests in the portal (Art. 11) and making them publicly available will undoubtedly help researchers to understand the types of research questions covered by the vetted researcher mechanism and get an overview of previously conducted research that they can be built on. Feedback and Recommendations A. Comments on Section II Information and contact obligations A.1. Data Inventories and metadata documentation: transparency, standarisation and quality issues Context: Article 6(4) of the Delegated Act mandates that VLOPs and VLOSEs (i.e., data providers) must publish an overview of the data inventory of their services, which includes examples of available datasets and suggested modalities to access them. This requirement is a key feature of the Delegated Act, aimed at bridging the gap in researchers understanding of data available from online platforms. Recital (12) of the Delegated Act highlights that the data that can be applied for to study systemic risks in the Union may vary over time. Recital (26) of the Delegated Act further requires data providers to include relevant metadata and documentation describing the available data, such as codebooks, changelogs, and architectural documentation. Our concerns: Transparency: data providers should not be limited to sharing an overview of their data inventories. Instead, they should provide a comprehensive structure of the data they collect, with the only exception being data that poses a risk to trade secrets. This expectation should also apply to data documentation, which would also greatly benefit from standardised formats. Consistent documentation practices would make it easier for researchers to interpret and compare similar data across different platforms Definition of data: Article 40(4) specifies that researchers should be granted access to data for the sole purpose of conducting research that contributes to the detection, identification, and understanding of systemic risks in the Union. While this provision has primarily been interpreted as referring to user-related data from VLOPs and VLOSEs, we believe it should also encompass other types of data such as information on platforms internal processes for handling harmful content.
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Meeting with Diana Vlad-Calcic (Cabinet of Vice-President Věra Jourová), Veronika Musilova (Cabinet of Vice-President Věra Jourová) and

22 Jul 2024 · AI, elections, disinformation

Meeting with Věra Jourová (Vice-President) and

10 Jun 2024 · Elections and disinformation

Meeting with Daniel Freund (Member of the European Parliament) and European Partnership for Democracy

8 Mar 2024 · Money talks – the Rule of law and the EU budget

Meeting with Daniel Freund (Member of the European Parliament) and Transparency International Liaison Office to the European Union and

1 Feb 2024 · The Rule of Law ahead of the EU elections

Response to Delegated Regulation on data access provided for in the Digital Services Act

31 May 2023

Political discourse on social media has become increasingly important in recent years. However, researching this discourse has been challenging due to limited access to data. Data access varies from platform to platform in terms of privacy levels, access points, and data types. This can create obstacles for researchers studying the impact of social media on democratic discourse. Hence, DRI welcomes the upcoming changes in the data access regime under the DSA Article 40. Based on the recent study about data access on large online platforms and years of experience in social media monitoring, DRI put together the recommendations for the delegated regulation on data access provided for in the DSA. - There is a need to specify what falls under publicly accessible data under the DSA Article 40.12, as currently many platforms do not provide access to data, despite they are of public nature (comments under public posts, etc.) - Metadata should fall within the publicly accessible data under the DSA Article 40.12, and accessibility should go beyond data that is visible on interfaces - The format of data should be diverse to enable verification, adaptability of data collection and higher usability. Therefore we recommend that the delegated act will specify that VLOPs need to provide access to data through online research interfaces, APIs and will allow scraping of data. - Both online research interfaces and APIs should be regularly maintained and updated to avoid bugs and limit research. - It is important to stress that the data access should be provided to both academic and non-academic research institutions as defined in the DSA Article 40, and that API Terms of Service will reflect that set of rules. - It is crucial that assessments of researchers applications under articles 40.12 and 40.4 will not be extensively long and follow clear rules and transparent processes. Therefore, it is crucial that the institution responsible for the evaluation of applications under 40.4 (either the DSC of establishment or an intermediary body) will have sufficient capacities to carry out the assessment in a timely manner, whereas the independence of such a body should be ensured. - It is important, that the body responsible for the assessment of data access applications under Article 40.12 will grant access without undue delay and for a longer time period. The application process should follow a standardised mechanism of an application evaluation, which will avoid unreasonable conditions. Further evidence and explanation to each recommendation can be found in the attached document.
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Meeting with Katarina Barley (Member of the European Parliament)

6 Mar 2023 · Unabhängigkeit der Gerichte in der EU (staff level)

Meeting with Katarina Barley (Member of the European Parliament)

13 Jul 2022 · Exchange of views

Meeting with Marie Frenay (Cabinet of Vice-President Věra Jourová)

24 Jun 2021 · Media pluralism

Meeting with Alvaro De Elera (Cabinet of Vice-President Věra Jourová)

5 May 2021 · Rule of Law - panel discussion

Meeting with Renate Nikolay (Cabinet of Vice-President Věra Jourová)

29 Sept 2020 · Digital agenda for Europe