Systemic Risk in Digital Services: Benchmarks for Evaluating the Management of Risks to Electoral Processes

In March 2024, just in time for the European elections, the European Commission issued its Guidelines for very large online platforms (VLOPs) and very large search engines (VLOSEs) on the mitigation of systemic risks for electoral processes.  

These Guidelines set out a list of mitigation measures for services to implement in order to prevent negative effects on the upcoming electoral processes and future ones. However, as explored in a previous CERRE paper, risk assessments under the Digital Services Act lack clear benchmarks for evaluating these measures.

In this new CERRE Tech, Media, and Telecom report, authors Sally Broughton-Micova, and Daniel Schnurr take an ambitious step towards to fill this gap by proposing benchmarks and a framework for assessing the negative effects to electoral processes that VLOP and VLOSE providers are expected to mitigate. 

These benchmarks define what ‘good’ electoral integrity looks like and set out the positive roles that VLOPs and VLOSEs can play as well as how to diagnose systemic failure. From these benchmarks, the paper defines a set of 13 potential negative effects and proposes a set of metrics and data for their evaluation. 

Overall, the implementation of the DSA’s provisions on these very large services should be about learning how to effectively prevent “negative impacts of systemic risks on society and democracy”. The effective implementation of the DSA cannot be a box-ticking compliance exercise. To that end, the authors propose the following recommendations: 

1. The Digital Services Board and the European Cooperation Network on Elections should lead cooperation on the development of an evaluation and learning strategy to steer data sharing. 
2. An effects-based framework as developed in this paper with specific metrics and types of data. 
3. Standard practices and formats should be developed based on the experiences of information disclosure and sharing between VLOPs/VLOSEs and election-specific civil society groups and Election Management Boards during the electoral period.  
4. VLOP and VLOSE providers should invest in tools that help them hold political actors to account. 
5. Develop common adaptive standards on what can be considered appropriate levels and types of automatisation in election campaigns and discourse.  

This report is part of the ‘Systemic Risk in Digital Services: Operationalising’ project, which will be completed with two other upcoming issue papers focusing on cross-cutting sources of systemic risk and principles for risk management and benchmarking and mitigating risk from terrorist content. This project builds on our earlier report ‘Elements for Effective Systemic Risk Assessment under the DSA’ which was published in July 2023.