High-level expert group

Recommendations for Moldovan and Ukrainian legislators and regulators for mitigating systemic risk – particularly during electoral periods.

As social media platforms, messaging services and search engines have amplified the spread of disinformation, particularly during elections, the mitigation of systemic risks stemming from the design, function, or use of these digital services is of great concern.

Both Moldova and Ukraine are rife with conflicting narratives and manipulative discourses that are undermining trust in institutions and media, driving political polarisation, and distorting public opinion by attacking credible and fact-based information sources, sometimes leveraging AI generated content and impersonation techniques to interfere in elections and undermine elected leaders.

In the online space, algorithms often facilitate the dissemination of illegal or violating content, which can erode social cohesion and put democratic dialogue and public debate at severe risk. Furthermore, some platforms are retreating from established approaches to content moderation content and weakening their terms of service to limit their responsibility when it comes to the protection of their users. 

This report offer recommendations primarily intended for Moldovan and Ukrainian legislators, regulators, and policy makers to help them address these formidable circumstances. 

Key recommendations include:

-Establish independent platform regulators, inspired by the model of Digital Service Coordinators under the EU’s DSA, and adapted to each country’s institutional context and democratic needs.

-Foster bilateral cooperation between EU and candidate-country regulators to strengthen DSA-aligned enforcement and facilitate knowledge exchange.

-Encourage observer status for Moldovan and Ukrainian regulators in the European Board for Digital Services (EBDS) to support cross-border collaboration and shared learning

All recommendations are a solely expert-driven product of High-Level Expert Group for Resilience Building in Eastern Europe (HLEG).

HLEG comprises of experts from across the region and beyond — media regulators, digital rights advocates, journalists, and policymakers — through a consultative process that included several in-person workshops held from Latvia to Austria and Denmark.

IMS’ work with the HLEG is supported by the Danish Ministry of Foreign Affairs.