At a time when the digital environment has become an important space for shaping public opinion, online platforms are increasingly used for manipulation, disinformation, and undermining trust in institutions. The High-Level Expert Group on Building Resilience in Eastern Europe (HLEG), established by the international organization IMS (International Media Support), has prepared “Recommendations for Moldovan and Ukrainian Legislators and Regulators for Mitigating Systemic Risk – Particularly During Electoral Periods.” Oleksandr Burmahin, a member of the National Council, contributed to their development.
The document was developed for Ukraine and Moldova as countries that are candidates for membership in the European Union.
HLEG consists of experts from across the region (Eastern Europe) and beyond – including representatives of media regulators, digital rights advocates, journalists, and policymakers. The consultative process included several in-person workshops held in Latvia, Austria, and Denmark.
According to Oleksandr Burmahin, the expert group is intended to provide answers to current challenges related to the activities of major platforms. These platforms are gaining increasing influence and have begun to shape content regulation themselves. Ukraine faces even greater threats due to the war, as Russia uses information as a weapon.
“The international group of experts gathered to assess the situation in the context of all these challenges and threats posed by platform activities and, perhaps, to try to steer the ongoing discussions into a practical dimension.”
The recent parliamentary elections in Moldova demonstrated that the online space is actively used for foreign interference aimed at influencing the outcome of citizens’ voting. This creates risks of weakening democracy, its institutions, and processes. The EU Digital Services Act (DSA) is designed to balance challenges and rights in the digital environment. Ukraine and Moldova are currently studying its provisions and may implement some of its tools at the national level to curb the power of major tech companies. For Ukraine, this issue is particularly important in the context of future post-war elections.
The recommendations developed by the expert group are intended to support Moldovan and Ukrainian regulators and legislators in their efforts to strengthen democratic resilience in the digital age. The document offers a roadmap for aligning national legislation with standards based on human rights, as well as strong and independent enforcement mechanisms.
Key recommendations included in the document:
- Establish independent platform regulators similar to Digital Services Coordinators under the DSA, adapted to the institutional context and democratic needs of each country.
- Promote bilateral cooperation between EU regulatory bodies and those of candidate countries to strengthen enforcement under the Digital Services Act (DSA) and facilitate knowledge sharing.
- Encourage granting Moldovan and Ukrainian regulators observer status in the European Board for Digital Services (EBDS) to support cross-border cooperation and joint learning.
Ukraine does not yet have access to the mechanisms for implementing the DSA, but at the national level it can already begin introducing provisions set out in the Act.
“The DSA is a law that contains many different requirements for platforms and standards, and we can, in principle, start implementing them at our legislative level, even though we are not an EU country,” said Oleksandr Burmahin. However, there is currently no active movement in this direction in Ukraine. Therefore, there is hope that the developed recommendations will push for decisions at the national level.
The work of the HLEG group will continue. It will move into a practical phase focused on supporting candidate countries in building resilient digital ecosystems that operate within the rule of law.
IMS intends to further promote cooperation among multiple stakeholders, regulators in Moldova and Ukraine, and their counterparts in the EU.
