On 12 November 2025, the European Commission (Commission) published a Communication to the European Parliament, the Council, the European Economic and Social Committee, and the Committee of the Regions on the European Democracy Shield (EUDS). While legally non-binding, the Strategy Paper sets out, amongst a series of voluntary measures for various stakeholders, potential outlines for the enforcement and revision of existing legislative acts in addition to the revisions planned with the Digital Omnibus. It aims to strengthen EU democracies and empower Europeans to exercise their rights, freely form and express opinions, and participate actively and safely in Union democratic life.
The Commission warns that democracies face increasing internal and external pressures due to geopolitical tensions, technological disruption, and the aggressive actions of authoritarian regimes. Additionally, the Commission points out that the “deep digital transformation of society” has opened new opportunities for participation and information access, but it has also created vulnerabilities. By highlighting that democracy forms “the cornerstone of the European Union and is key to building peace, security, economic prosperity, and social cohesion”, the Commission pursues three main strategic priorities with the EUDS: (i) reinforcing situational awareness and response capacity to safeguard the integrity of the information space; (ii) strengthening democratic institutions, free and fair elections, and free media; and (iii) boosting societal resilience and citizens’ engagement.´
In this blog post, we will give a brief overview of the EUDS and analyse the possible impact of the proposed actions on businesses in the EU.
Key Takeaways
Whilst the EUDS itself does not create legal obligations, it draws attention to a wide range of existing laws and regulations. As a result, it is anticipated that these legal frameworks will be invoked more frequently and receive heightened scrutiny going forward. This applies in particular to the following:
- For Gatekeepers under the DMA, the actions taken via the EUDS enhance the risk of enforcement regarding obligations that promote an independent and diverse media landscape.
- VLOPs and VLOSEs should expect more detailed guidance by the Commission on the handling of foreign information manipulation and interferences (FIMI). In addition, regulators are expected to intensify their scrutiny on the efforts from VLOPs and VLOSEs to mitigate systemic risks to society and democracy stemming from their algorithms and recommender systems.
- Providers and deployers of AI systems could be subject to closer scrutiny regarding transparency obligations imposed, inter alia, by the AI Act.
- The outcome of the review of the Directive on Copyright in the Digital Single Market could provide a baseline for an overhaul of copyright law in the EU. Especially for stakeholders in the AI industry, revised copyright legislation could lead to new compliance obligations and bureaucracy but also to more clarity.
- The EUDS reiterates the Commission’s willingness to continue enforcement of antitrust rules in the digital/media sector. In the revised Merger Guidelines, the Commission therefore wants to provide guidance on maintaining competition to promote media pluralism, which is in line with recent EU policy, such as the new review mechanism for media market concentrations under Art. 22 EMFA (see our previous blog post on this topic here).
European Centre for Democratic Resilience
The Commission is proposing to establish a European Centre for Democratic Resilience (Centre), to bring together the efforts and expertise of Member States, candidate countries and EU institutions that are currently dispersed. The Centre aims to enhance information sharing between EU-Institutions and Member States, and support operational cooperation and capacity building in response to threats such as FIMI, as well as disinformation. As a hub, the Centre will link existing prevention, detection, analysis, and response networks and coordinate with the EU Rapid Alert System to develop joint approaches and exchange relevant data and analyses. Development will be rolled out progressively, based on the voluntary participation of Member States, and the Centre is to fully respect EU and national competences.
A Stakeholder Platform affiliated to the Centre will be established for independent, non-institutional stakeholders, such as civil society organisations, think tanks, researchers, academia, fact-checkers and media providers, to enable contributions from a broad set of relevant stakeholders and communities. This may present an interesting opportunity for companies to contribute to the work of the Centre.
Safeguarding the integrity of the information space
To safeguard the integrity of the information space, particularly regarding FIMI and disinformation, the Commission is proposing concrete actions and measures targeting, inter alia, providers of VLOPs and VLOSEs under the Digital Services Act (DSA). These are to supplement existing legal frameworks, such as the transparency and deepfake labelling obligations for certain AI systems under the AI Act, and the systemic-risk assessment and mitigation obligations (Art. 34, 35 DSA), as well as requirements for the transparency of recommender systems (Art. 27, 38 DSA) and mechanisms for data access and scrutiny by researchers and authorities (Art. 40 DSA) under the DSA.
Platform-facing measures include:
- The preparation of an incident and crisis protocol under Art. 48 DSA, by the Commission in cooperation with the Centre. The aim is to orchestrate rapid, coordinated responses to large-scale and potentially transnational operations, with the Centre and its stakeholder platform supporting exchanges among these mechanisms. This protocol will work alongside crisis mechanisms already in place, and by taking into account relevant EU legislation, e.g. the NIS-2-Directive and the Cybersecurity Act.
- The strengthening of anti-manipulation measures under the Code of Conduct on Disinformation. The Commission will evaluate the commitment levels of individual Code signatories and the extent to which they are implemented. If deemed necessary, the Commission intends to hold regulatory dialogues with these signatories under the DSA and consider other appropriate follow-up actions.
- The collaboration with signatories to bolster their efforts as regards the transparency of recommender systems and to demonetise disinformation and remove financial incentives for it via advertising revenue. This includes the detection and labelling of AI-generated and manipulated content on social media, as well as voluntary user verification tools (complementing both the DSA and AI Act).
Measures to ensure content integrity and infrastructure include:
- The Commission will support the preparation of an EU Blueprint on FIMI/disinformation, standardising tools and guidance for anticipation, detection and response, as well as shaping public-private operational alignment.
- Further, under an extended mandate, the European Digital Media Observatory will be able to develop new, independent monitoring and analytical capabilities to support situational awareness, particularly around elections and in crisis situations.
- Establishing an independent European Network of Fact-Checkers operating in the EU, as well as in candidate and neighbouring countries associated with the Digital Europe Programme. The network will support fact-checking capacity in all EU official languages, especially during elections, health emergencies or natural disasters, to ensure access to reliable information.
- Setting up a common research support framework to provide access to data and advanced technologies. The framework will rely, inter alia, on the privileged access to data under the DSA and the Regulation on the Transparency and Targeting of Political Advertising (TTPA).
- Developing a list of common criteria to guide national media regulators protecting the EU information space from “rogue non-EU media services”, in collaboration with the European Board for Media Services established under the EMFA.
Strengthening the fairness and integrity of electoral and other democratic processes
To strengthen the fairness and integrity of electoral and other democratic processes, the Commission intends, for example, to reinforce its cooperation with Member States through the European Cooperation Network on Elections (ECNE). Together with the national Digital Services Coordinators and in cooperation with ECNE, the Commission will update the DSA Elections Toolkit based on experiences from recent elections. This concerns the obligation for providers of VLOPs and VLOSEs under the DSA to mitigate systemic risks related to negative effects on civic discourse and electoral processes. The Commission has already adopted Guidelines on this matter, while cooperating with national authorities regarding preparedness ahead of elections.
In addition, the Commission plans to work with Member States and stakeholders to prepare dedicated guidance on the responsible use of AI in electoral processes. It will encourage commitments on the use of technology, particularly AI, in political activities by relevant parties. Further, new election-related work under the Code of Conduct on Disinformation will focus on novel and emerging threats linked to information manipulation campaigns.
The Commission highlights other important measures in this regard, such as the recently implemented TTPA, the securing of election infrastructure through the NIS-2-Directive and the Cyber Resilience Act, and advancing transparency of political funding.
Strengthening the resilience of free and independent media
With the goal to strengthen free and independent media as a cornerstone of democratic societies, the Commission intends to reinforce existing regulations. This includes backing Member States in implementing the European Media Freedom Act (EMFA), offering guidelines, and ensuring compliance.
The Commission is determined to strengthen media pluralism by maintaining antitrust enforcement in the digital sector. This includes addressing conduct that limits competition in the online space. Additionally, as part of the revision of the Merger Guidelines, the Commission will provide guidance on maintaining competition in terms of quality, to promote media pluralism and diversity for consumers and citizens. As with any antitrust enforcement, this could potentially have significant implications for media businesses. However, it should be noted that the EUDS does not propose any new antitrust regulations.
Regarding the Digital Markets Act (DMA), the Commission intends to include amongst its priorities enforcement actions that promote an independent and diverse media landscape, including by increasing the transparency of online advertising. Further, the Commission intends to hold regulatory dialogues on AI-powered services with the concerned gatekeepers.
According to the EUDS, online piracy and the use of copyrighted material to train AI models without permission remains a significant threat to the media sector, eroding revenues and impacting the quality and diversity of media. The Commission will review the Directive on Copyright in the Digital Single Market and consider how to improve its effectiveness in the context of these developments.
Other measures envisioned by the Commission include, e.g., the launch of a Media Resilience Programme for independent journalism and media literacy, and the support of independent media beyond EU borders. The Commission will also assess ways to strengthen media services and modernise advertising rules to support EU media in the upcoming review of the Audiovisual Media Services Directive.
Boosting societal resilience and citizens engagement
The EUDS advances societal resilience and citizens engagement as backbone of democracy via four strands: promoting citizenship, education and skills for democracy, encouraging citizens’ engagement and participation next to whole-of-society actions, as well as safeguarding evidence-based decision making.
Next Steps
While the EUDS does not itself impose binding legal requirements and primarily operates on a voluntary basis, it nevertheless brings existing regulations into focus, which are likely to be applied more frequently and examined more closely. Finally, it is also worth noting that strategic planning documents like the EUDS often provide an initial outlook or set the direction for further regulation that can be expected at the European level.
We would like to thank Lorenz Kammerl (Research Assistant) for his valuable contribution to this article.