1. European Democracy Shield: Comprehensive Review
1.1 Context and motivation for the initiative
On 12 November 2025, the European Commission and the High Representative of the Union for Foreign Affairs and Security Policy presented a joint communication entitled ‘European Democracy Shield: Empowering strong and resilient democracies’. This thirty-page document represents the European Union’s most ambitious attempt to date to build a comprehensive system for protecting democratic institutions, processes and values in the face of growing internal and external pressures.
The initiative did not arise in a vacuum. It is a logical continuation and extension of previous EU efforts, most notably the 2020 European Democracy Action Plan and the 2023 Democracy Package. However, the scale of the new initiative far exceeds its predecessors, reflecting a growing awareness that democracy in Europe faces unprecedented challenges that require a systematic and coordinated response at the level of the entire Union.
The document is based on the recognition of a fundamental truth: democracy is the cornerstone of the European Union and the key to building peace, security, economic prosperity, competitiveness and social cohesion. Moreover, democracy is seen not simply as a system of government, but as a way of life that guarantees the rights and freedoms of citizens, ensures equality before the law, promotes open and fair societies, and holds those in power to account.
According to Flash Eurobarometer 550 ‘Challenges and priorities in the EU’, conducted in July 2024, EU citizens see respect for democracy, human rights and the rule of law as the main strength of the European Union. Thirty-eight per cent of respondents cited these values as the EU’s most important strength. This creates both a mandate and a responsibility for European institutions: citizens not only value democracy, but also expect the Union to actively defend it.
1.2 The nature of threats: from external pressure to internal challenges
The document presents a multi-layered analysis of the threats facing European democracies. In an era of growing geopolitical confrontation, international and regional conflicts, and technological upheaval, democracies are under pressure from both outside and within. Authoritarian regimes, as the document explicitly states, view democracies as a threat and are deploying increasingly aggressive tactics, including the use of state and non-state proxies, to weaken them.
The logic of authoritarian interference is based on a deep understanding of the nature of democracy. While democracy is based on bringing together different voices in society and seeking common solutions, authoritarian regimes seek to create or amplify divisions, instrumentalise conflicts, discredit democratic actors — especially free media and civil society — and undermine free and fair elections. The ultimate goal of these efforts is to erode citizens’ trust in democratic institutions and in the ability of democracy to work for the benefit of the people.
Of particular concern is the situation in EU candidate countries and potential candidates. These countries, which aspire to join the European family of democracies, are simultaneously the targets of intense destabilisation and interference efforts. In addition to its brutal war of aggression against Ukraine, Russia is escalating hybrid attacks and waging a battle for influence against Europe. The tactics used by Russian actors are penetrating deep into the fabric of European societies, with potentially long-term consequences. By spreading misleading narratives, sometimes involving manipulation and falsification of historical facts, these campaigns seek to undermine trust in democratic systems.
But these threats do not come in isolation. They are fuelled and amplified by other important challenges facing democracy today. Among these, the document cites growing extremism and polarisation, declining trust and engagement among citizens, threats to the integrity of elections and the pluralism of public debate and freedom of expression, and a deteriorating environment for journalists and civil society. According to the 2025 Strategic Foresight Report, ‘Resilience 2.0: Empowering the EU to thrive amid turbulence and uncertainty,’ these challenges pose a complex threat to the democratic order.
1.3 Digital transformation: new opportunities and new vulnerabilities
All these challenges are unfolding against the backdrop of a profound digital transformation of European societies, which has fundamentally changed the ways in which public debates are conducted, information flows and citizens participate in the public sphere. On the one hand, this has brought significant new opportunities for people to freely access information, express their opinions and participate in public life and democratic debates. On the other hand, it has also exposed and created new vulnerabilities.
People’s views are increasingly shaped by algorithmic, personalised sources, which limits the common space for democratic debate. Social media platforms also affect the sustainability of media revenue models, threatening the financial viability of independent journalism. The development of artificial intelligence could have a serious impact on the democratic space, including electoral processes. The ability of generative AI to create convincing synthetic content — from deepfakes to AI-generated texts — opens up new opportunities for the large-scale dissemination of disinformation at a lower cost of production.
The document emphasises that protecting democracy and building the democratic resilience of citizens, societies and institutions is an urgent collective endeavour that requires a “whole-of-government” and “whole-of-society” approach. This is not only necessary to preserve EU values, but also to ensure Europe’s security and protect its independence, freedom and prosperity. EU institutions, Member States, candidate and potential candidate countries, civil society and the private sector all have a crucial role to play, guided by shared values. Citizens and their freedoms must be at the heart of all efforts.
1.4 Structure of the European Democracy Shield: three pillars
Building on the solid political and legal foundation laid by the 2020 European Democracy Action Plan and the 2023 Democracy Package, the European Democracy Shield presents a set of new measures in three priority areas. These three pillars do not exist in isolation, but interact and reinforce each other, creating a comprehensive ecosystem for the protection of democracy.
The first pillar focuses on strengthening situational awareness and supporting response capabilities to protect the integrity of the information space. This includes developing the ability to anticipate, detect and respond quickly to threats, in particular foreign information manipulation and interference, as well as disinformation. The document recognises that many existing structures only address specific areas and communities, use different methodologies and often offer limited response capabilities with limited links to the work of competent authorities at national and EU level.
The second pillar aims to strengthen democratic institutions, free and fair elections, and free and independent media. Free and independent media, free and fair elections, and strong and resilient democratic institutions and processes are recognised as essential for citizens to participate meaningfully in political life, choose their representatives, hold them accountable and fully exercise their rights and freedoms. Recent elections, including those in Romania and Moldova, have illustrated a broader escalation of interference by Russia and its proxies in the European democratic space.
The third pillar focuses on enhancing societal resilience and citizen engagement. Engaged and empowered citizens and an active civil society are the foundation of democracy. Promoting civic education, including media and digital literacy and critical thinking, raises awareness of risks and threats and empowers citizens of all ages and communities to navigate the information environment, access reliable information, exercise their democratic rights and participate in democratic processes.
1.5 European Centre for Democratic Resilience: the institutional core of the initiative
To support better cooperation and coordination in addressing the various aspects of these three priority areas, a European Centre for Democratic Resilience will be established. This is an institutional innovation designed to be the key coordination mechanism for the entire initiative. The Centre will bring together the expertise and capabilities of Member States, candidate countries and potential candidates, as well as EU institutions, bodies, offices and agencies, including the European External Action Service, where appropriate.
The Centre will facilitate information sharing and support operational cooperation and capacity building to counter emerging common threats, in particular foreign information manipulation and interference and disinformation. Its aim is to improve situational awareness and the ability to anticipate and detect threats, develop a robust and coordinated early warning system, and support rapid response capabilities. The Centre will also support awareness-raising to prepare and empower societies and institutions, making them more resilient to information manipulation and disinformation.
The Centre will primarily function as a specialised hub for exchange and operational cooperation between EU institutions and Member States. It will link existing networks and structures working on the prevention, detection, analysis and response to threat patterns in the information space, and will work on developing joint approaches, practices and methodologies, and sharing relevant data and analysis. It will support training and capacity-building activities. Furthermore, it may advise on common response tools, strategies, standard operating procedures, protocols or joint exercises.
The Centre will be supported by and work in close coordination with the Rapid Alert System, which is an established mechanism for sharing information on FIMI and disinformation between EU institutions and Member States. This creates a direct link between the Centre’s analytical capabilities and the operational response mechanisms already in place at EU level.
1.6 Stakeholder Platform: a space for civil society
A critical element of the Centre’s architecture is the Stakeholder Platform for independent non-institutional actors. This platform will be established to ensure contributions from a wide range of relevant stakeholders and communities and to feed these contributions into the Centre’s work. The platform will bring together stakeholders such as civil society organisations, think tanks, researchers and academia, fact-checkers and media providers.
While fully respecting the independence of all participants, this platform will facilitate the exchange of information, expertise and advice, and will gradually build on existing stakeholder communities such as the European Digital Media Observatory (EDMO) and new communities such as the European Fact-checkers Network and the future common research support framework. The platform will support the dissemination of research and other outputs and encourage exchange between different stakeholders.
This recognises that effective protection of democracy is not possible without the active involvement of civil society, which often has specialised expertise, operational flexibility and legitimacy among citizens that public authorities lack. The stakeholder platform creates an institutionalised space for this experience and knowledge to feed into the Centre’s work without undermining the independence of civil society organisations.
The Centre will fully respect EU and national competences, as well as the independence of existing structures at national and EU level. Its development will be gradual, based on the voluntary participation of Member States and their contributions and needs for support and cooperation, to ensure that it provides the best possible support to national authorities and jointly at EU level. Building on the EU’s current support and engagement with international partners, the Centre will also be open to the association of candidate countries and potential candidates to support them and facilitate mutual learning. Cooperation with like-minded partners may also be envisaged.
1.7 Protecting the integrity of the information space: a multi-level approach
Strengthening the integrity of the information space to support everyone in society in accessing reliable and trustworthy information, exercising their democratic rights and engaging meaningfully with institutions and communities is essential. Transparency, accountability and integrity in the information space are key to ensuring that people’s voices are heard, empowering them to be active citizens, and building and maintaining their trust in democratic processes.
Foreign information manipulation and interference and disinformation campaigns are deliberately designed to undermine public trust in the information space and democratic institutions, while amplifying social divisions. They are facilitated by the proliferation of new online manipulation techniques. These techniques include inauthentic use of social media, fake social media accounts, websites designed to mimic official sources, artificial amplification of divisive content, use of synthetic content such as deepfakes, and other content generated by artificial intelligence.
Their dissemination often relies on inauthentic behaviour such as fake accounts, amplification driven by AI and bots, and inauthentic interactions. Such coordinated operations, often part of broader hybrid campaigns, are becoming increasingly sophisticated and decentralised and may involve networks operating across multiple platforms and jurisdictions, often under the cover of anonymity, making them particularly difficult to detect, attribute and effectively counter.
To address these challenges, the EU has specific legislation in place. The AI Act establishes transparency obligations for providers and users of certain AI systems, including a duty to label and ensure detection when content has been artificially generated or manipulated, and a labelling obligation for deepfakes and certain other AI-generated publications on public issues. The Digital Services Act also contributes to strengthening the integrity of the information space by regulating responsibilities and requiring providers of very large online platforms and very large online search engines to mitigate systemic risks to society and democracy arising from their services, while fully respecting users’ freedom of expression.
The Digital Services Act strengthens algorithmic transparency by empowering users to control how recommendation systems influence the content they see online and by giving researchers access to platform data. The Digital Services Act also gives the Commission the power to scrutinise the design of algorithmic systems, with the support of the European Centre for Algorithmic Transparency. The implementation and enforcement of this legislation are key priorities, and several procedures relating to certain providers of very large online platforms for assessing and managing systemic risks to civil discourse and electoral processes are ongoing.
To prevent and address major incidents and interference in the information environment, the Commission will prepare an incident and crisis protocol under the Digital Services Act, in conjunction with the European Digital Services Board. This will facilitate coordination between relevant authorities and ensure rapid responses to large-scale and potentially transnational information operations. This protocol takes into account and will work alongside other crisis mechanisms, in particular the Cybersecurity Blueprint, to ensure that actions are coordinated and consistent, and taking into account relevant EU legislation.
1.8 Code of Practice on Disinformation: Self-regulation and Accountability
The Code of Practice on Disinformation, supported by a collaborative working group, provides a robust set of commitments and detailed measures that together help mitigate the risks associated with disinformation, while fully respecting freedom of expression, for example through enhanced tools for users to recognise, understand and flag disinformation and to empower researchers. The Code is also useful for determining compliance with commitments on systemic risks related to disinformation for providers of very large online platforms and very large online search engines that adhere to and comply with the commitments under this Code.
The Commission will assess the levels of commitment of individual signatories to the Code and their implementation. Where necessary, the Commission will conduct regulatory dialogues under the Digital Services Act with these signatories and decide on other appropriate follow-up actions. For example, the Commission will work with signatories to strengthen their efforts on the transparency of recommendation systems and the demonetisation of disinformation, including removing financial incentives for disinformation through advertising revenue, and to develop relevant indicators to measure platforms’ efforts in this regard.
The Commission will also explore possible further measures with the signatories to the Code. These could include ways to improve the detection and labelling of AI-generated and manipulated content circulating on social media services, and voluntary user verification tools. Such measures would be complementary to the AI Act and other relevant EU rules. EU digital identity wallets, which will be available to EU citizens and residents by the end of 2026, could facilitate such measures and promote trust and security in online interactions by providing secure identification and authentication.
1.9 Support at Member State level and international cooperation
Member States’ efforts to ensure the integrity of the information space can be strengthened at EU level through the coordination of approaches and the pooling of expertise and information, building on the existing FIMI toolbox. Working with national authorities and experts, the Commission will support the development of a Blueprint to counter FIMI and disinformation, including tools and guidance on measures for anticipation, detection and response, as well as a dedicated mechanism for professional exchange and teamwork to support national capacity building and mutual learning.
Strengthening the capacity of the independent fact-checking community across the EU is critical to improving the detection and monitoring of FIMI and disinformation campaigns. An independent European network of fact-checkers will be established with the support of the Commission, and its work will contribute to the European Centre for Democratic Resilience’s Stakeholder Platform. The network will be based on the highest ethical and professional standards and will operate in the EU and in candidate countries, potential candidates and neighbouring countries associated with the Digital Europe programme.
The network will enhance fact-checking capacity in all official EU languages, especially during situations such as elections, health emergencies or natural disasters, where access to reliable information is critical. The network will also create and maintain an independent fact-checking repository to consolidate fact checks published by independent, relevant and trusted organisations, and will facilitate access to verified information for journalists, online platforms, researchers and civil society, supporting cross-border cooperation and ensuring timely responses. It will also provide access to a protection scheme for fact-checkers in the EU against threats and harassment, including legal and psychological protection.
The European Digital Media Observatory provides a pan-European, independent and interdisciplinary research and analysis network to counter FIMI and disinformation campaigns. Under its expanded mandate, the EDMO will be able to develop new independent monitoring and analysis capabilities to support situational awareness, particularly around elections or in crisis situations. Its monitoring will cover all Member States, candidate countries (e.g. Ukraine, Moldova) and potential candidates, and will contribute to the work of the Stakeholder Platform within the European Centre for Democratic Resilience.
The research and academic community has also made relevant contributions by providing independent analysis and evidence on FIMI campaigns and disinformation. The Commission will support the creation of a common research support framework to provide access to data and advanced technologies, bringing together and strengthening these independent capabilities. This framework, which will rely, among other things, on privileged access to data under the Digital Services Act and the Political Advertising Regulation, will contribute to the work of the European Centre for Democratic Resilience’s Stakeholder Platform.
To anticipate and respond effectively to FIMI, it is important to make full use of the FIMI toolbox. This toolbox includes a wide range of responses, including Union restrictive measures against non-EU individuals and organisations that have participated in FIMI campaigns targeting the EU, candidate countries and potential candidates. The scope of the EU sanctions regime targeting Russia’s destabilising activities includes a ban on the broadcasting of Kremlin propaganda channels involved in FIMI.
FIMI and disinformation campaigns may also rely on criminal behaviour or activities, such as money laundering or organised crime. The EU criminal law acquis covers certain forms of FIMI and disinformation activities, and enhanced EU cooperation in this area can help to better counter them. The planned review of the Europol and Eurojust mandates will explore ways to further strengthen these efforts.
In a context of geopolitical tensions and increased polarisation, it is important for the EU to strengthen its efforts to build alliances with like-minded countries and regional partners. Supporting democratic actors and the integrity of information ecosystems around the world will benefit European democracy, security and prosperity. The EU will step up its efforts to counter FIMI in its external action through the European External Action Service, in close cooperation with the Commission, Member States and international partners.
1.10 Concluding remarks on the structure of the document
This comprehensive overview shows that the European Democracy Shield is not just a set of disparate measures, but a systematic approach to protecting and strengthening democracy in Europe. The document covers a wide range of topics, from technological solutions to educational programmes, from legal instruments to international cooperation, from the protection of journalists to the empowerment of citizens.
For civil society organisations such as FactCheck.LT, this document opens up unprecedented opportunities for engagement, contribution and cooperation with European institutions and Member States in the defence of democracy. The European Centre for Democratic Resilience’s stakeholder platform creates an institutionalised space where specialised expertise, operational experience and innovative methodologies can directly inform policy and practice at the European level.
