The DSA’s Role in Safeguarding Election Integrity

In the wake of recent European elections, questions are mounting about the effectiveness of the EU’s Digital Services Act (DSA) in safeguarding electoral integrity on social media platforms. An examination of elections in Romania, Germany, and Poland reveals significant challenges in implementing the regulatory framework designed to combat online threats to democratic processes.

Social media platforms have become central arenas for public discourse, but the rules governing these spaces remain largely in the hands of a few private companies. While Europe has positioned the DSA as its primary defense against platform-driven electoral harm, recent evidence suggests the legislation may not be living up to expectations.

The DSA’s systemic risk framework requires major platforms to identify, assess, and mitigate risks stemming from their services, particularly those affecting “civic discourse and electoral processes.” This self-assessment model is meant to foster collaboration between platforms, regulators, and civil society, with platforms publishing annual reports and submitting to independent audits.

In March 2024, the European Commission published guidelines outlining recommended measures to protect election integrity, but implementation has been inconsistent across platforms.

Across the Romanian, German, and Polish elections, several recurring issues emerged. Coordinated influence operations were prevalent, with Romanian intelligence services uncovering a campaign involving over 25,000 TikTok accounts. While TikTok claimed to have banned these accounts, questions remain about detection timing and effectiveness.

Improper labeling of political content was another common problem. In Germany, many political profiles lacked proper election labels, while in Poland, there were attempts to impersonate candidates. Though platforms claimed to have mitigation measures in place, external observers frequently documented failures.

Electoral misinformation and disinformation appeared in all three elections. During the German campaign, political advertisements on Facebook contained misinformation and hate speech. In Poland, TikTok videos falsely claiming election fraud garnered millions of views. Despite these issues, content-related risks do not appear to have been the central public concern for election integrity.

Three issues seem underappreciated in platform risk assessments: political advertising irregularities, undisclosed influencer promotions, and algorithmic bias leading to asymmetric amplification of political candidates. In Romania, political content was mislabeled as entertainment on TikTok, while some influencers received undisclosed payments for promoting candidates. The situation may have worsened since Meta and Google stopped serving political ads in October 2025.

Civil society organizations across all three countries reported concerns about algorithmic bias, particularly on X (formerly Twitter) during the German elections. While the Commission offers guidance on mitigating manipulation in recommender systems, platforms primarily focus on combating fake engagement rather than ensuring balanced political reach.

The effectiveness of the DSA’s framework is difficult to evaluate due to limited data transparency. While platforms claim to have effective mitigation measures, external observations frequently contradict these assertions. The DSA and Commission guidelines lack clear operational benchmarks for what constitutes “reasonable, proportionate and effective” mitigation measures in electoral contexts.

The European Commission has launched formal proceedings against several platforms, including X, TikTok, Facebook, and Instagram, related to systemic risks to electoral processes. These cases could establish important precedents for future elections.

A fundamental challenge to the DSA’s collaborative approach is emerging as some platforms become increasingly non-cooperative. X continues to deny researchers access to platform data despite court rulings and a €40 million fine. With the Trump administration threatening trade retaliation against EU platform regulation, US-based tech giants may have diminishing incentives to comply with European rules.

Commission Executive Vice-President Henna Virkkunen has promised more DSA enforcement decisions in the coming months. To maintain the credibility of the systemic risks framework, the Commission cannot allow potential US backlash to deter enforcement actions, particularly as platforms’ role in electoral integrity remains a critical concern for European democracy.