Response to the European Commission’s consultation on draft guidelines to mitigate systemic risks for electoral processes

How should and can large online platforms ensure that opinion-formation and democratic elections are not undermined? The Digital Services Act (DSA) stipulates that such platforms must analyze and mitigate potential risks to electoral processes. To this end, the European Commission has drafted guidelines, for which it has asked for feedback via a public consultation. SNV project director Julian Jaursch took part in the consultation. He argues that possible measures must be proportionate and strike an appropriate balance, because platforms have a responsibility for the online spaces they provide, but not all interventions by companies and governments are justified just because they are supposedly meant to protect elections. Therefore, the consultation submission focuses on fundamental considerations about the purpose of the guidelines and proposals for transparency obligations