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interface - tech analysis and policy ideas for Europe e.V.

interface

interface is an independent think tank specializing in technology policy and the public interest.

Lobbying Activity

Meeting with Matthias Ecke (Member of the European Parliament)

10 Dec 2025 · AI Gigafactories

Meeting with Oliver Schenk (Member of the European Parliament)

10 Dec 2025 · Halbleiterindustrie in Europa

Meeting with Thibaut Kleiner (Director Communications Networks, Content and Technology)

9 Dec 2025 · Interface e. V’s positions on AI policy, notably its paper on AI Gigafactories (AIGFs)

Interface Urges ENISA Funding Boost or a More Focused Mandate

12 Jun 2025
Topic — Evaluation of the European Union Agency for Cybersecurity and its certification framework.
Message — Interface recommends that policymakers either provide the agency with adequate resources or significantly narrow its mandate. They advocate for clarifying ENISA’s strategic role and prioritizing activities to optimize impact.12
Why — Refining prioritization would alleviate operational strain and enable the agency to build specialized expertise.34
Impact — Member States and businesses face a fragmented security landscape if coordination efforts remain under-funded.567
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Response to Delegated Regulation on data access provided for in the Digital Services Act

6 Dec 2024

Thank you for the opportunity to provide feedback on the draft delegated act regarding data access under the Digital Services Act (DSA). This submission highlights some overarching points regarding the procedural steps for data access, with an emphasis on the role of the Digital Services Coordinators (DSCs). The five sections in the attached document are: 1. General comments; 2. Useful approaches in the draft delegated act and potential improvements; 3. Cooperation among Digital Services Coordinators; 4. Additional concrete examples to be included in the delegated act; 5. Open questions
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Meeting with Alexandra Geese (Member of the European Parliament) and Electronic Frontier Foundation

4 Dec 2024 · Digital policies

Meeting with Alexandra Geese (Member of the European Parliament)

6 Nov 2024 · Gender gap in the AI labour market

Meeting with Alexandra Geese (Member of the European Parliament)

4 Nov 2024 · DSA enforcement, addictive design

Meeting with Lina Gálvez (Member of the European Parliament)

9 Oct 2024 · AI and gender biases

Response to Protection of Minors Guidelines

30 Sept 2024

Thank you for the opportunity to submit feedback regarding the development of guidelines for platforms on the protection of minors under the Digital Services Act (DSA). Please see the attached short overview of evidence specifically related to youth protection on TikTok, based on original research, surveys and data analysis conducted in 2023 and 2024 by lead researchers Dr. Anna-Katharina Meßmer and Dr. Martin Degeling at interface (formerly Stiftung Neue Verantwortung).
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Meeting with Alexandra Geese (Member of the European Parliament) and Reset Tech UK and Fundacja Panoptykon

6 Mar 2024 · Event: Protecting the 2024 Elections: From Alarm to Action

Meeting with Alexandra Geese (Member of the European Parliament)

30 Jan 2024 · DSA implementation, political advertising

Response to Implementing Act on an information sharing system under Regulation (EU) 2022/2065 (Digital Services Act)

5 Jan 2024

The implementing regulation on the functioning of an information sharing system under the Digital Services Act (DSA) is an important pillar of platform oversight in the EU. Another complementary implementing regulation on the interoperability of the information sharing system should follow, as the DSA calls for. Without an infrastructure to share information and ensure timely communication between regulators, enforcing new rules for online platforms will not work. As the DSA stipulates in Article 85, this information sharing system mostly concerns the Commission itself and the member states Digital Services Coordinators (DSCs), but also touches upon other national regulators. The draft implementing regulation reflects this constellation of organizations reasonably well by spelling out the respective roles of the Commission, DSCs and other regulators in an information sharing system. However, the draft almost exclusively focuses on roles regarding data protection matters between the given regulators. This is of high importance and compliance with the General Data Protection Regulation (GDPR) requires thorough attention. Yet, in addition to this necessary emphasis, a clearer explanation of the information sharing system and a more substantive list of tasks or use cases could be included, for instance, regarding joint investigations or data sharing with external partners. It remains unclear what exactly the information sharing system is supposed to be and do. For instance, only a recital states that it is a software application accessible via the Internet. Overall, the draft leaves it somewhat open what the information sharing system looks like and whether it should be used for some or all DSA oversight communication. Understandably, this might be done purposefully to not create a framework that is too narrow. Yet, some more clarity about the use and design of the information sharing system could be helpful. This would underline that the information sharing system is supposed to be a useful tool for regulators day-to-day work and not merely a legal and technical exercise, which might slow its uptake and use. The attached consultation submission focuses on such additional topics, leaving comments on the legal aspects of data protection to experts in that field. While there could be a downside to being too specific about use cases, this risk could be minimized by detailing some cases in a list that is explicitly described as non-exhaustive and that does not just recite individual DSA articles. Such a list of tasks might seem obvious but would give regulators a clearer picture of what is expected of them beyond GDPR details and what benefits the information sharing system brings them and in extension consumers. In particular, national regulators, which contrary to the Commission have not had some months of initial DSA enforcement practice already, could profit from this. Moreover, this might allow a better consideration of if/how the Commission, the DSCs and specifically the Board can share information with non-regulatory actors. The final text should also make clearer by what date the information sharing system should be functional, because it so far remains open as to whether all functions are available right away. Provisions around data security could be strengthened. Useful ideas that should be kept in the final implementing regulation are the multi-language approach, regular evaluation and the coverage of costs via the DSA supervisory fee. We thank the European Commission for the opportunity to provide feedback on the draft implementing regulation and look forward to further engaging with the Commission and other stakeholders.
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Meeting with Alexandra Geese (Member of the European Parliament)

28 Jun 2023 · Political Advertising and Digital Services Act implementation

interface urges EU to strengthen digital platform audit rules

2 Jun 2023
Topic — The consultation defines the rules and methodologies for auditing very large online platforms.
Message — The organization recommends clearer independence criteria for auditors and the use of qualitative risk scenarios. They also propose including diverse stakeholders and non-vetted research in the auditing process.123
Why — These proposals would increase the influence of independent researchers and civil society organizations.4
Impact — Large accounting firms and platforms would lose their ability to control audit methodologies.56
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Meeting with Alexandra Geese (Member of the European Parliament) and the Mozilla Foundation

26 May 2023 · CPDP: The DSA and algorithmic ranking

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

19 May 2023

We thank the European Commission for the opportunity to participate in the call for evidence. For our full response, please see the attached document, which addresses the questions posed in the call as well as a detailed technical appendix. The responses to the questions partly draw on input from colleagues from SNV as well as other European academic and civil society experts, including AI Forensics and AlgorithmWatch, whose work and support we gratefully acknowledge. In the following, we provide a summary of our key points, which can also be found at the beginning of the attached document. SNV strongly welcomes the DSAs intended push for improvements in platform-to-researcher data access. A privacy-friendly, accessible EU-wide regime is necessary to replace the current system of arbitrary and piecemeal access points provided by some platforms on a voluntary basis. This system has created unequal access for researchers, offers incomplete data and lacks key technical features, as SNV has experienced first-hand by conducting platform research and using several platforms APIs. While the provisions in Article 40 DSA are a good start, they do need to be spelled out in greater detail. That is why we applaud the Commission for focusing on this issue and starting work on a delegated act as provided for in Article 40(13). The delegated act can ideally lead to major improvements in how researchers can access platform data. To achieve this goal, we offer several suggestions in this response to the Commissions call for evidence. Data access needs - Current research APIs only provide a limited set of variables and less than is publicly available, for example, via scraping. While the current trend is to limit APIs and the available data, we suggest the opposite: All data that can already be accessed by scraping should be available through APIs. - Research often struggles with lack of relevant meta data. That is why platforms need to properly document data schemas and content removal. - It is necessary to clarify that scraping of public data is in accordance with Article 40(12) to remove legal uncertainties about this vital research practice. Data formats and technical specifications - Platforms should offer regular APIs as well as stream APIs. - Experimentation with automated user accounts should be possible on the platform or in sandboxes to study algorithms like recommender systems. - Data donations and exploratory research should be allowed. Vetting process - It should be reiterated in the delegated act that researchers both from academic and civil society organizations can apply for data access, including those from outside the EU. - In addition to applications regarding specific research projects, it should be allowed for researchers and institutions as such to apply, which would further support exploratory and inductive research. Governance structure - We strongly suggest setting up an independent advisory mechanism as mentioned in Article 40(13). This body, made up of academic and civil society researchers, could facilitate the development of common vetting standards, support DSCs in the actual vetting process and serve as a forum for exchange. - The Commission, the European Centre for Algorithmic Transparency, the DSCs as well as researchers themselves should immediately engage in capacity-building efforts to make the best use of Article 40. Member states should equip their DSCs with strong research and data science units to conduct data analyses themselves and support researchers.
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Meeting with Alexandra Geese (Member of the European Parliament, Shadow rapporteur) and European Digital Rights and

27 Mar 2023 · Political advertising

Meeting with Alexandra Geese (Member of the European Parliament)

15 Mar 2023 · Digital Services Act implementation and political advertising

Meeting with Alexandra Geese (Member of the European Parliament, Shadow rapporteur)

20 Dec 2022 · Political advertising

Meeting with David Cormand (Member of the European Parliament, Shadow rapporteur for opinion)

8 Sept 2022 · Chips Act

Meeting with Marc Angel (Member of the European Parliament, Shadow rapporteur for opinion)

14 Jul 2022 · EU Chips Act

Meeting with Alejandro Cainzos (Cabinet of Executive Vice-President Margrethe Vestager), Pierre-Arnaud Proux (Cabinet of Executive Vice-President Margrethe Vestager)

11 Jul 2022 · EU Chips Act / SMEI, mapping value chains.

Meeting with Paul Tang (Member of the European Parliament, Shadow rapporteur for opinion) and European Partnership for Democracy and

28 Jun 2022 · Event on Political Advertising Regulation (assistant participated)

Meeting with Marc Angel (Member of the European Parliament, Shadow rapporteur for opinion)

28 Jun 2022 · EU Chips Act

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 Maria-Manuel Leitão-Marques (Member of the European Parliament, Rapporteur for opinion)

25 May 2022 · Chips Act

Meeting with Martin Schirdewan (Member of the European Parliament, Shadow rapporteur)

25 Apr 2022 · Digital Services Act

Response to Transparency of political advertising

27 Jan 2022

The enclosed document with feedback draws on SNV’s previous work on online political advertising (https://www.stiftung-nv.de/en/publication/rules-fair-digital-campaigning) and on defining political advertising (https://www.stiftung-nv.de/en/publication/defining-online-political-advertising). It includes input from colleagues from SNV as well as other think tank and civil society representatives. We thank the European Commission for the opportunity to provide feedback to the draft and look forward to engaging further with the Commission as well as the European Parliament and other interested stakeholders. In the following, the key points from the feedback document are summarized: The Commission’s legislative proposal contains many important and timely innovations in ensuring political advertising transparency. This, in turn, can contribute to fair and pluralistic political debates and elections in the EU. To further bolster this effort, European lawmakers could and should considerably improve some of the key proposals. The main strengths of the proposals that should be maintained are: - The draft takes the view that political advertising is not limited to just electoral periods. It covers many different political advertisers as well as issue ads, thus placing a wide range of political advertising within the scope of the rules. This is also accomplished by including both online and offline ads in the rules. Taken together, this broad view is the right approach and should be maintained in the upcoming negotiations. - The draft is structured into articles containing a set of transparency rules and principles, and two annexes with specific pieces of information that should be provided to regulators and other external observers. These annexes can be changed faster and more easily than a law. This flexibility is desirable and should be kept because it would ideally allow for a more dynamic review and update of the transparency requirements. The key improvements that should be implemented are: - The definition would benefit from clarifications and examples. Especially because of the wide range of different advertisers and advertisements covered, it is imperative to delineate the at times overlapping definitions better. - For political advertising, the use of highly sensitive personal data (as defined in EU data protection law) and inferred data should be banned without exceptions. The Commission acknowledges the risk of discrimination stemming from the segmentation of the electorate and the delivery of narrowly tailored political ads, but precisely because this is the case, it is not suitable to rely on consent rules. - The law should provide a framework for determining what good and bad design practices regarding ad disclosures and notice mechanisms are. This could be done in an additional annex. Particularly if the consent option is kept, a ban on deceptive design practices should be considered. - Regulators and researchers should be able to request data access to all data points mentioned in the draft, not just a selected few. - The Commission should mandate a cross-platform, real-time political ad repository. This would help citizens and specifically those researching political advertising to understand online ad campaigns better than the combination of suggested rules for single-platform database from the Digital Services Act and this draft. - Enforcement mechanisms should be streamlined by giving EU-level oversight agencies more powers and/or establishing clearer cooperation guidelines for national authorities.
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Meeting with Renate Nikolay (Cabinet of Vice-President Věra Jourová)

26 Oct 2021 · Digital rulebook, DSA, DMA

Response to European Democracy Action Plan

27 Aug 2020

Democracy is a work in progress. Especially in Europe, with its history of authoritarian rule and the present danger of authoritarian backsliding, it is up to citizens, governments, businesses and civil society to continuously work on upholding and improving democratic principles. It is to be welcomed that the EU recognizes this need and aims to use its European Democracy Action Plan “to ensure that citizens are able to participate in the democratic system through informed decision-making free from unlawful interference and manipulation”, as the roadmap states. For the Commission to achieve this goal, it is crucial to acknowledge that “interference” today refers to more and different activities and dangers than it did even a few years ago. Interference might still come from governments, e.g. via censorship. Yet, interference might also take the form of citizens being unable to freely form their opinions due to a fear of discrimination or harassment or due to a deluge of false or misleading content online, for instance, which might not emanate from government actors. Such interference is particularly visible during the COVID-19 pandemic. On this topic of European public health and economic concern touching the entire population, disinformation spread wide and fast. Arguably, not a shortage of information interfered in people’s decision-making processes, but a flood of content. Digital platforms and governments worked to address this disinformation, but their efforts, in turn, raised questions about what institutions can push or suppress what content under what conditions. The pandemic showed, once again, that the risks of interference are heightened in the digital public sphere. While the use of digital infrastructure and communication platforms for political debates and processes can support democratic participation, it also poses serious risks for democracy. Namely, the online news and information space that has become a big part of many citizens’ opinion-formation processes amplifies existing threats of interference. Some of the issues mentioned in the roadmap, e.g. the spread of public health disinformation or the dangers to election integrity, can in part be attributed to the current setup of the digital sphere, where many dominating platforms seek revenues solely through targeted advertising, which might create the incentive to show the most “engaging” content/advertising, even (or especially) if it is discriminatory, disputed or outright disinformation. In seeking to address such pitfalls of the digital public sphere, the EDAP therefore needs to be ambitious in its scope and its actions. It should use a range of available tools to achieve its goals, such as legislation, recommendations to member states and well-funded programs for civil society and other institutions. The development of the EDAP should be in sync with other Commission initiatives, most crucially the Digital Services Act, and involve diverse stakeholders, especially considering the EDAP’s emphasis on the role of civil society and active citizen participation. The EDAP, along with the DSA and other initiatives, should empower citizen through a combination of regulation and education. Reasoned regulation is necessary for tech companies that are integral to citizens’ opinion formation processes. This includes binding transparency and accountability rules for political advertising and reporting standards for content moderation, among other things. The EDAP should also drive modernization of EU and national campaign finance regulation. This empowers citizens by ensuring accountability for those actors trying to reach them with (paid) political messages. In addition, citizens need to be educated to spot and tackle disinformation and other potential interferences to their decision-making processes. Journalism and digital news literacy programs for all ages can empower citizens in this regard, which is why support for both is crucial.
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