In February 2024, the European Commission published draft guidelines for Very Large Online Platforms (VLOPs) and Very Large Online Search Engines (VLOSEs) designed to offer them best practices and measures to mitigate systemic risks their service may pose to democratic elections. The Civil Liberties Union for Europe (Liberties) and the European Partnership for Democracy (EPD) have reviewed these guidelines, and while we found the Commission's work thorough and in-depth, we advocate for a broader approach. In our view, the guidelines must address not only electoral risks but also the wider challenges to online democratic discourse as these have a non-negligible impact on elections too.

In our feedback to the Commission, we highlight several concerns such as the potential for content amplification and algorithm curation to silence diverse voices, the exacerbation of polarisation, the over-removal of copyrighted content, organised attacks against civil society, and the risks associated with micro- and nano-targeting of political advertising.

To mitigate these risks, we suggest measures like promoting inclusive discussions, developing algorithms that expose users to a variety of viewpoints, ensuring fair use of copyrighted material, protecting civil society from online attacks, and regulating the use of observed and inferred data in political advertising.

We also advocate for fostering collaboration between VLOPs/VLOSEs and civil society experts, and ensuring the guidelines are enforced through robust mechanisms.

In conclusion, Liberties and EPD greatly appreciate the Commission's efforts but stress the importance of broadening the scope of the guidelines, ensuring collaboration, and effective implementation.

Read our response to the European Commission here.

Read our policy paper on identifying, analysing, assessing and mitigating potential negative effects on civic discourse and electoral processes here.