Wikimedia Foundation
WMF
The mission of the Wikimedia Foundation is to empower and engage people around the world to collect and develop educational content under a free license or in the public domain, and to disseminate it effectively and globally, through websites like Wikipedia.
ID: 596597913132-95
Lobbying Activity
Meeting with Jörgen Warborn (Member of the European Parliament)
18 Jun 2025 · Forskning
Meeting with Hannah Neumann (Member of the European Parliament)
20 May 2025 · Exchange of views on EoV Iran Archiv
Meeting with Simona Constantin (Cabinet of Commissioner Michael McGrath)
6 May 2025 · Digital information environment, European Democracy Shield, anti-SLAPP
Meeting with Alexandra Geese (Member of the European Parliament, Shadow rapporteur) and Weizenbaum-Institut e.V.
6 Mar 2025 · Event: Bits und Bäume Policy Lab
Meeting with Alexandra Geese (Member of the European Parliament) and European Digital Rights
1 Oct 2024 · Tech and Society Summit: Community based alternatives: a tool to rein in Big Tech and build a healthy online public sphere
Meeting with Alexandra Geese (Member of the European Parliament)
30 Sept 2024 · Digital policy in the new mandate
Meeting with Mohammed Chahim (Member of the European Parliament) and The German Marshall Fund of the United States - The Transatlantic Foundation and
19 Mar 2024 · Transatlantic Tech Exchange
Meeting with Paul Tang (Member of the European Parliament) and The German Marshall Fund of the United States - The Transatlantic Foundation and
19 Mar 2024 · Transatlantic Tech Exchange
Response to Performance of independent audits provided for in the Digital Services Act
2 Jun 2023
The Wikimedia Foundation is the non-profit organization that hosts Wikipedia. We support the global Wikimedia movement whose mission is to bring free educational content to the world. As a service provider, we work to empower communities to collaborate in creating and collecting content and making moderation decisions together. Wikimedia appreciates that the European Commission has published its draft delegation regulation laying down rules on the performance of audits for very large online platforms and very large online search engines. We acknowledge and welcome that the Commission has consulted experts and based its decisions on evidence while drafting the delegated act. The proposed rules are ambitious in their construction and impose a very specific standard and vision for both auditor and auditee. The drawback of imposing an (overly) prescriptive standard is that it limits the choice of auditors and incentivizes auditors to strictly follow the letter of the law, rather than its spirit. The Wikimedia Foundation intrinsically encourages community (i.e. user) visibility, control and autonomy with respect to the free knowledge projects that it hosts. We would like to investigate possible alternative auditing avenues, but consider them essentially foreclosed by the laid out draft. Our goal would not be to find a friendly auditor, but rather, one that truly understands Wikipedias unique governance and content moderation model, and can offer it a fair and specific critique, rather than applying standards developed either in a total vacuum or a one-size-fits-all approach. The timeline and complexity of the proposed rules mean that audits will have to be done in a rush during the first year. This, in turn, will mean that the Wikimedia Foundation will have to divert resources from ongoing efforts to substantially comply with the Digital Services Act and similar laws rolling out worldwide. Another major issue we see, especially with regards to the first years audit, is that the Digital Services Act is just coming into effect. No platform or service has had enough time to implement and fine-tune all the necessary changes and systems required by the DSA. There is a natural lack of experience and of widely-recognised standards to make this effort meaningful and successful in the first years audit. Based on our concerns, our recommendation is that the European Commission should reserve this version of the rules for the second or third year of auditing. In the start-up year we would welcome a more flexible and agile audit environment.
Read full responseResponse to Methodology for the calculation of the supervisory fee provided for in the Digital Services Act
19 Jan 2023
To whom it may concern: The Wikimedia Foundation welcomes the opportunity to comment on the future fee structure for supervision of very large online platforms (VLOPs) under the Digital Services Act (DSA). The Wikimedia Foundation hosts Wikipedia and a number of other collaborative, volunteer-governed projects that serve the public interest by providing access to reliable educational content. Based on preliminary analysis it is possible that Wikipedia will be designated as a VLOP. The Wikimedia Foundation supports the European Commissions goals of increasing transparency, fairness, predictability, accountability, and respect for fundamental rights on the internet, and specifically when it comes to content moderation online. We are ready to further engage with the Commission to ensure the DSA is successful at delivering on those goals and to set a global example for how collaboration, openness, and transparency can improve the quality and safety of our online spaces. We are, however, worried that the fee requirements will disproportionately impact nonprofit hosts of platforms like the Foundation. We already operate Wikipedia with a fraction of the budget and staff of organizations behind comparable online platforms, and rely predominantly on donations for funding. We also demonstrate how an alternative platform model, whose main goal is community empowerment instead of profit making, can function and be successful. Precisely because we are not driven by profit but by dedication to common good and because all income, beyond what is necessary to host the platforms and run the organization, is invested in free knowledge and educational activities, we are recognized as a charity and enjoy tax exemptions. We believe that a similar approach is appropriate for the VLOP fee structure under the DSA. VLOP services that are run non-commercially, dedicated to enriching the public good, and owned and operated by a provider that is a recognized as a charitable organization should be exempted from supervisory fees. This would be especially important if the fees levied on VLOPs were to grow year over year, commensurate with the Commissions expenditures as the cost of oversight may rise. Europe and the world need more platforms with alternative models of governance and content-moderation, internet services that dont rely on advertisement, tracking, data collection, and/or the backing of very rich individuals, for the digital ecosystem and information society to be healthy and robust. The European Commission can help foster such alternatives by removing financial barriers that amount to a competitive disadvantage when it comes to supervisory fees. The EU is setting a global example and many jurisdictions around the world will follow its lead. It will be harder to ask for support and protection for alternative platform models at the Member State level or elsewhere, e.g. across the Asia-Pacific region, if the EU doesnt lead by example. Sincerely, Jan Gerlach Public Policy Director, Wikimedia Foundation
Read full responseResponse to Child sexual abuse online: detection, removal and reporting
12 Sept 2022
Please see attached document for the feedback of the Wikimedia Foundation.
Read full responseMeeting with Raphaël Glucksmann (Member of the European Parliament, Committee chair)
11 May 2022 · ING2 - Lutte contre la manipulation de l'information
Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services
31 Mar 2021
The Wikimedia Foundation (WMF) and the Free Knowledge Advocacy Group EU (FKAGEU) appreciate the Commission’s thoughtful approach to addressing the rights and responsibilities of providers of digital services.
The WMF is the charitable organization that hosts the Wikimedia movement’s free knowledge projects, including Wikipedia. FKAGEU is an NGO that represents the users of Wikimedia projects through their chapter organizations. As such, our organizations represent two different stakeholders in the creation of our projects, which seek to let people share the sum of human knowledge with each other through freely editable, free-of-charge websites. The WMF provides the servers and the hosting platform for Wikipedia, while the community of users provides and maintains the content: the knowledge contained within it.
The user community also develops the rules that make Wikipedia an encyclopedia, as opposed to a repository of personal essays or a generalized debate forum. Those rules, such as citing secondary sources, avoiding conflicts of interest, and avoiding dictionary-style entries, are what ensures that Wikipedia remains as useful as possible. Violations of these rules make the site less successful, but such violations do not typically violate laws or harm other users. Community-developed procedures also settle disputes about editing and accuracy, meaning that no centralized body tries to impose its perspective on user debates. This includes the WMF, whose role explicitly excludes dictating the content of the projects.
In contrast to the community-developed policies and guidelines, the WMF’s Terms of Use are structured primarily around legal liabilities, such as privacy violations, IP infringement, or harassment. Since the WMF pledges broadly not to interfere with the content of the site, the WMF only alters project content when harmful content meets a higher threshold of concern, or there is a legal requirement to do so.
This division of roles allows the WMF to address legal matters more precisely and directly than community processes, while allowing the community to address violations of their own rules and policies that are both more frequent and require a closer understanding of the immediate context of the dispute.
As the DSA is further refined, we want to ensure that our community retains the ability to create and enforce its policies and guidelines as part of a system considered separately from the responsibilities of the WMF, which reside in the host’s legal obligations and in the WMF Terms of Use. Preserving this distinction not only prevents the centralized WMF from being required to adjudicate norms developed by communities around the world; it also preserves the self-determination of those communities, apart from constraints imposed by the WMF or other potential platform gatekeepers. Defining the obligations of hosts and other providers to accommodate community structures is critical to protecting this self-determination.
The WMF and FKAGEU also wish to guarantee that the DSA’s provisions ensure that content moderation systems do not inadvertently suppress legitimate knowledge sharing and expression, or prevent the abuse of content moderation systems by bad actors. For instance, requirements for transparency should maintain strong privacy protections for potential victims of harassment, keeping in mind that victims may themselves be falsely accused of violations by their harassers. Nor should service providers be obligated or incentivized to take steps upon notice that would hamper or remove legitimate content. For example, overbroad interpretations of the knowledge created by a notice could trigger overbroad suppression of other users’ expression--typically in ways that disadvantage marginalized and minoritized people. The DSA should ensure that notice provisions do not conflict with the lack of a monitoring requirement, which can easily be abused to the disadvantage of the already-disadvantaged.
Read full responseMeeting with Thierry Breton (Commissioner) and
9 Dec 2020 · Roundtable with NGOs on DSA and DMA
30 Jun 2020
The Wikimedia Foundation and the Free Knowledge Advocacy Group EU welcome the initiative of devising ex ante rules to ensure that markets characterised by large online platforms remain fair and contestable for innovators, businesses, and new market entrants. We believe it is equally important to ensure that the ex ante rules benefit users by ensuring choice between platforms offering similar services while protecting users rights to privacy and to participation in public debate.
We support the scope of the IIA recognising that a small number of large online platforms occupy the biggest market share. We share the opinion that the digital landscape is far more diversified.
The value of a healthy online ecosystem of services is also larger than just the value of user-generated data. It also encompasses the digital commons: openly/freely licensed resources that include projects such as Wikipedia and Wikidata. Considering their uptake in the society at large and in business (i.e. Wikidata is commonly used by commercial voice assistants (see https://www.wired.com/story/inside-the-alexa-friendly-world-of-wikidata/)) the value produced by them is tangible. These and myriad other commercial and non-commercial projects currently fall into one large category of information society services providers (Directive 2000/31) just as do large online platforms that increasingly bundle a broad range of digital services into a seamless, data-driven offer.
We believe that the Commission should focus attention on the services characterised by the IIA as those that (i) accumulate large quantities of data, (ii) easily access different technical assets, (iii) easily expand into new markets. This will ensure that effective ex ante rules are tailored to gatekeepers, while not imposing costly and complicated obligations or remedies on others who do not hamper fairness on the market and the benefit of users.
We argue that characteristics of gatekeepers that exacerbate competition harms include a) content curation practices that lead to presenting different users with different information and opportunities of interaction, and b) data-driven business model based on the use of algorithmic tools in order to commercialise behavioral data. These platforms’ main clients often are not the users that generate content and interact with them, but services and businesses that benefit from being connected with many consumers through their services. We believe that these parameters should be incorporated in establishing whether a platform displays a gatekeeping potential or is, in fact, a gatekeeper.
Collecting information from platforms as an important function of a dedicated regulatory body at the EU level. To successfully apply remedies and ensure users’ rights to receive and impart information, a degree of transparency about algorithmic tools used to curate content and act on users’ engagement and behaviour should be required. It should encompass the right of a user to understand why they are presented with certain content.
We welcome the plan to adopt a regulatory framework that includes restrictions to unfair trading practices by gatekeepers as well as tailor-made remedies on a case-by-case basis where necessary and justified. The restricted unfair trading practices should include, among others, deceptively vague or imprecise information in terms of service/user agreements (on behavioral data collection etc.). ToS could be audited by a regulatory body that would restrict these bad practices.
We strongly believe that, on a case-by-case basis, requirements regarding personal data portability and interoperability should be among the remedies enforced by a competent regulatory body. This could be reinforced by a request to demonstrate that a platform is capable of offering adequate services in a given Member State by providing adequate human overview/moderation services in the language of the MS and within its cultural and historical context.
Read full responseResponse to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services
30 Jun 2020
The Wikimedia Foundation and the Free Knowledge Advocacy Group EU welcome the debate on the responsibilities of digital services. We believe that a regulatory framework must preserve and promote the freedom of imparting and receiving information without interference by public authority; promote freedom of expression; and protect users from harmful and illegal activities.
Online services not only facilitate commercial activity, they also function as an extension of the public sphere. Users share knowledge and information via platforms. Important societal debates take place at least partly on dominant social-media platforms. At the same time, most digital services are profit-oriented and function according to market logic. For all measures contemplated at the EU level, including legislative action, non-binding guidance, and voluntary cooperation, careful consideration needs to be given to how changes in the incentive structure might affect the enjoyment of fundamental rights. As the roadmap states, “protections of users’ rights - including the freedom to receive or impart information - are not always sufficiently robust across the board.”
Special consideration needs to be given to how the commercialization of the public debate (which now takes place on platforms regulated by private terms of service) affects the freedom of expression. New regulatory instruments must not create incentives for overblocking content. For this reason, we strongly believe that the foundation of the e-Commerce Directive (liability exemption for intermediaries and no general monitoring obligation) should remain in place.
We agree, however, that an update to the horizontal framework that defines the responsibilities and obligations of digital services is necessary to protect and empower users. In the process of updating and harmonizing the European-level regulatory framework, special emphasis should be put on strengthening users as consumers vis-à-vis dominant digital service providers.
As stated in the roadmap, an important step in this direction would be to reduce information asymmetries between platforms and users by improving transparency around online advertising and algorithmic accountability. Users of digital services should always be able to tell the difference between user-generated content and paid content. Moreover, users must have an accessible option to sort the content displayed to them. It is clear that some of these problems, including issues related to the spread of misinformation, are inextricably linked to the data-driven business model of social media platforms. Introducing interoperability requirements could enable users to choose different services based on different business models. Greater consideration should be given to the question of how to promote public good-oriented digital services as an alternative to commercial platforms.
With regard to objectives and policy options we believe that such a comprehensive update to the horizontal framework would require a comprehensive legal intervention and the creation of an effective system of regulatory oversight, enforcement, and cooperation across Member States, supported at the EU level. This particularly applies to obligations relating to an effective notice-and-action framework, which would have to include functioning redress mechanisms in order to ensure that users or their content are not blocked arbitrarily and can appeal blocking decisions.
Content moderation is necessary to address illegal activities online and where there is discrimination based on identity. Online public debate should be inclusive. At the same time, content moderation needs to adhere to high quality standards, which can only be achieved through sufficient human oversight. Automated decision-making systems should only be used to flag potentially problematic content. Content filters should not be mandated as tools of automated decision making for content removal, as they are unable to recognize context
Read full responseResponse to New competition tool
30 Jun 2020
The Wikimedia Foundation and the Free Knowledge Advocacy Group EU welcome the European Commission’s initiative to address structural competition problems in the form of a New Competition Tool, and recommend the Commission pursue Option 3. Structural competition issues pervade many different markets, and defining specific sectors as being “digital” or “non-digital” may create incentives for gamesmanship with sectoral definitions or corporate structuring. Many sectors not typically included in commonplace definitions of “digital” may generate structural competition risks. We therefore recommend the Commission use a horizontal scope in addressing these issues.
In our opinion, structural risks to competition can create the conditions for consumer harms and market inefficiencies even before any particular firms might be recognized as dominant; conditions for structural competition problems can often be diagnosed ex ante. Therefore, we recommend that the Commission use a market structure-based approach.
The Commission’s April 2019 Report identifies a number of promising areas for future work, including tying or leveraging market dominance into other markets. This not only occurs when a firm has achieved dominance through normal competitive means in the first market, but also when it attains dominance through the operation of law, such as when limited monopolies are legally provided (by the state, or by licensors) via intellectual property exclusivities. IP rights, particularly when aggregated by large entities, provide substantial means for a firm to leverage other markets, whether they be for distribution of media containing copyrighted works, or for competitors using methods or systems that allegedly read on a patent. These problems can be exacerbated by the prevalence of software-as-a-service models or other leasing or licensing models, which provide a rightsholder increased mechanisms to restrict the uses of a work to gain competitive advantage in more varied, related markets.
The Report also notes the issues of network externalities in two-sided markets. These issues can be further compounded when the business model involves more than two sets of distinct users, such as content producers, content consumers, advertisers, advertising networks, and advertising audiences. In various types of media, whether social media, broadcast, or print, the entity at the nexus of these different user groups has multiple ways of influencing competition and the shape of the market.
The Wikimedia Foundation and Free Knowledge Advocacy Group EU therefore recommend the Commission purpose Option 3 for exploring a future competition tool, and urge the Commission to address the specific market features raised above.
Read full responseResponse to Evaluation of the Commission Notice on market definition in EU competition law
15 May 2020
The evaluation of the Market Definition Notice should verify if its instruments of analysis are adequate for the digital sphere/markets. There is a need to update the competition rules and definitions in general to better include platforms hosting user-generated content. Many of those that make this content publicly available do not operate on a market as much as they create their own market by being on the forefront of digital innovation that aims at building what we now call the “attention economy”.
The analysis of a relevant market should be centered around user behaviour and how the results of examining that behaviour can be integrated in the market definition. Particularly, the scope of the evaluation should include the above aspects into the analysis of effectiveness, relevance, and EU added value.
The proposed shape of the evaluation should fulfill, among others, the following objectives related to the definition of relevant market in the digital realm:
1) The evaluation should explore vertical integration of markets and its results, including the impact of network effects on competition, e.g. the need for structural remedies based on openness and consumer freedom, rather than only the number of direct competitors.
2) For the relevant product market aspects, the analysis of demand substitutability should include restrictions to switching (incl. portability of content, personal data, and identity), as well as substitutability of digital services. Substitutability can be affected by consumers’ important non-monetary interests, such as the ability to participate on a platform anonymously, pseudonymously, or with a limited audience.
3) For the relevant product market aspects, the analysis of supply substitutability should include the cost of complying with applicable laws, including the availability of technologies (variety and pricing) that make it possible for services to effectively manage their legal obligations and risks as a condition of competitiveness (for example, the affordability or accessibility of content moderation tools, based on machine learning and/or artificial intelligence influences the ability to compete in the market where some companies can afford such technologies and others cannot).
4) The evaluation should consider the multi-jurisdictional nature of the internet, which has several effects:
a) It can favor competitors with the resources to comply across national boundaries, raising market entry costs.
b) It can favor competitors willing to provide uniform products or services that meet the lowest common denominators across jurisdictions (e.g., production in jurisdictions with the lowest labor or environmental standards, enforcement of content moderation policies according to the most speech-restrictive regimes, etc.)
Many of these above effects lead to the conclusion that markets dealing with informational goods and services are frequently natural monopolies, suggesting that effective remedies are not limited to increasing the number of horizontal competitors, but to ensure that consumers and other marketplace actors in these ecosystems are treated fairly and given appropriate choice and freedoms.
Read full responseMeeting with Pauline Rouch (Cabinet of President Jean-Claude Juncker)
14 Nov 2014 · Meeting with Mr Dimitar Dimitrov - Wikimedia Position Paper on EU Copyright