On February 20 and 23, the final online meetings were held within the session “Rules for the dissemination of audiovisual content in the digital environment” of the Twinning project. Over the course of two days, experts of the National Council, together with European partners, examined in detail the application of the Digital Services Act (DSA) and its interaction with the European Media Freedom Act (EMFA) and the Regulation on the Transparency and Targeting of Political Advertising (TTPA).
If the previous meetings were devoted to media freedom and the transparency of political advertising, this time the focus was on the systemic responsibility of online platforms, particularly very large ones, and the risks they pose to democracy, security, and human rights.
European experts emphasized that the DSA changes the very approach to regulation. Platforms can no longer limit themselves to reacting to individual violations. They are obliged to regularly assess so‑called systemic risks: from the spread of illegal content to the impact of algorithms on public debates, electoral processes, and the mental health of minors.
Special requirements have been established for Very Large Online Platforms (VLOPs) and Very Large Online Search Engines (VLOSEs). These are services with more than 45 million users in the EU. For them, mandatory audits, enhanced standards of advertising transparency, access to data, crisis response protocols, and separate supervision by the European Commission are provided.
For Ukraine, this approach is important because it concerns the removal of illegal content, as well as the analysis of how service design, recommendation algorithms, or targeting mechanisms can reinforce disinformation or opaque political advertising.
During the meetings, European experts explained how the DSA complements the EMFA and the TTPA:
- EMFA introduces additional safeguards for media service providers in their interaction with platforms. A mechanism of prior notification about content restrictions and the possibility of expedited appeals is established. Combined with the DSA’s requirements for transparency of decisions and internal complaint-handling systems, this creates a new model of protecting editorial independence in the digital environment.
- TTPA, in turn, sets detailed requirements for labelling political advertising, disclosing information about the sponsor, and targeting parameters. The DSA reinforces these provisions through platform obligations to assess manipulation risks, ensure transparency of advertising systems, and open data for oversight. For large platforms, this means responsibility not only for the presence of labelling but also for ensuring that their algorithms do not facilitate hidden or discriminatory microtargeting.
For Ukraine, given the constant information attacks and the risks of external interference by the enemy, the interaction of European regulations is particularly important.
Representatives of the media regulators of Greece, Germany, Italy, and France shared their experience in applying the DSA at the national level.
During the meeting, approaches to the implementation of the DSA in Ukraine in the context of European integration were discussed. Experts spoke about practical changes for users:
- clear obligations for platforms to respond quickly to illegal content;
- transparent explanations of decisions regarding its removal;
- disclosure of information about recommendation algorithms and advertising.
In the conditions of war, when Ukrainians face disinformation and hostile information attacks every day, this is a matter of security. The implementation of the DSA will mean greater protection for users, as well as a clear mechanism for appealing platform decisions.
During the four‑day session of the Twinning project, experts of the National Council familiarized themselves with the new regulatory framework for the digital environment in the EU, studied best practices, and approaches to content moderation and the protection of users’ rights. Within the framework of integration into the European Union, this will help align Ukrainian legislation with EU standards and create effective tools for safeguarding the information space and citizens’ rights.
Background: The Digital Services Act (DSA) is an EU regulation adopted in October 2022 that establishes uniform rules for online platforms and internet intermediaries. It provides for:
- protection of users from illegal and harmful content;
- transparency in moderation, advertising, and algorithms;
- support for fair competition and innovation, particularly for small and medium‑sized platforms;
- increased responsibility of platforms for respecting users’ rights.
Some provisions entered into force on November 16, 2022, with full application by February 17, 2024.
