Report March 2025

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Your organisation description

Political Advertising

Commitment 12

Relevant Signatories commit to increase oversight of political and issue advertising and constructively assist, as appropriate, in the creation, implementation and improvement of political or issue advertising policies and practices.

We signed up to the following measures of this commitment

Measure 12.1 Measure 12.3

In line with this commitment, did you deploy new implementation measures (e.g. changes to your terms of service, new tools, new policies, etc)?

Alliance4Europe has defined unlabelled political or issue advertising as one of our focus areas in our influence operations research, and have been providing feedback to the platforms on how to improve their policies.

If yes, list these implementation measures here

We listed unlabelled political or issue advertising in the training we provide and the different collaborative monitoring projects we engage in, such as elections monitoring. From the cases we identified, we have developed recommendations.

Do you plan to put further implementation measures in place in the next 6 months to substantially improve the maturity of the implementation of this commitment?

If yes, which further implementation measures do you plan to put in place in the next 6 months?

Measure 12.1

Relevant Signatories agree to work individually and together through the Task-force to identify novel and evolving disinformation risks in the uses of political or issue advertising and discuss options for addressing those risks.

Alliance4Europe worked to research, monitor and report on the use of online political or issue advertising across Member States. Our reports highlighted systemic issues with one specific social media. The two issues detected were:
- Automated ad labelling systems circumvention methods used by foreign threat actors to intervene in the French elections,
- Platform regulation of state-controlled media ads - not labelling an authoritarian state's ads as political or issue advertising.

Both issues were at least partially addressed.

QRE 12.1.1

Alliance4Europe has monitored the ad libraries of social media platforms for unlabelled political and social issues ads. In 2024, we identified 611 unlabelled ads and reported them to the social media platforms through the CoP RRS. In these conversations, we highlighted the underlying techniques used to circumvent their ad policies. We also publicly published reports on these cases and provided recommendations.

Measure 12.3

A4E have alerted fellow Signatories to issues in the implementation or enforcement of political or issue advertising policies or of this Code.

Commitment 13

Relevant Signatories agree to engage in ongoing monitoring and research to understand and respond to risks related to Disinformation in political or issue advertising.

We signed up to the following measures of this commitment

Measure 13.1 Measure 13.2 Measure 13.3

In line with this commitment, did you deploy new implementation measures (e.g. changes to your terms of service, new tools, new policies, etc)?

If yes, list these implementation measures here

Do you plan to put further implementation measures in place in the next 6 months to substantially improve the maturity of the implementation of this commitment?

If yes, which further implementation measures do you plan to put in place in the next 6 months?

Measure 13.1

Alliance4Europe worked individually and together through the Task-force to identify novel and evolving disinformation risks in the uses of political or issue advertising and discuss options for addressing those risks.

QRE 13.1.1

Through the Task-force, the Relevant Signatories will convene, at least annually, an appropriately resourced discussion around novel risks in political advertising to develop coordinated policy.

A4E worked to identify novel and evolving disinformation risks in the uses of political or issue advertising and discuss options for addressing those risks together with other members of the Counter Disinformation Network and the CoP RRS taskforce. We identified TTPs employed by threat actors to circumvent Meta’s automated content moderation systems.

Measure 13.2

Alliance4Europe consulted with the Task-force and other relevant stakeholders to assess the opportunity and impact of short election “blackout periods” for political or issue advertising.

Measure 13.3

N/A

Integrity of Services

Commitment 14

In order to limit impermissible manipulative behaviours and practices across their services, Relevant Signatories commit to put in place or further bolster policies to address both misinformation and disinformation across their services, and to agree on a cross-service understanding of manipulative behaviours, actors and practices not permitted on their services. Such behaviours and practices include: The creation and use of fake accounts, account takeovers and bot-driven amplification, Hack-and-leak operations, Impersonation, Malicious deep fakes, The purchase of fake engagements, Non-transparent paid messages or promotion by influencers, The creation and use of accounts that participate in coordinated inauthentic behaviour, User conduct aimed at artificially amplifying the reach or perceived public support for disinformation.

We signed up to the following measures of this commitment

Measure 14.3

In line with this commitment, did you deploy new implementation measures (e.g. changes to your terms of service, new tools, new policies, etc)?

If yes, list these implementation measures here

Do you plan to put further implementation measures in place in the next 6 months to substantially improve the maturity of the implementation of this commitment?

If yes, which further implementation measures do you plan to put in place in the next 6 months?

Measure 14.3

Relevant Signatories will convene via the Permanent Task-force to agree upon and publish a list and terminology of TTPs employed by malicious actors, which should be updated on an annual basis.

Allinace4Europe has continuously mapped and reported on tactics and techniques used by threat actors on social media platforms, supporting the signatures with data for their reviewing of the list of TTPs.

Monitoring of the Code

Commitment 39

Signatories commit to provide to the European Commission, within 1 month after the end of the implementation period (6 months after this Code’s signature) the baseline reports as set out in the Preamble.

We signed up to the following measures of this commitment

In line with this commitment, did you deploy new implementation measures (e.g. changes to your terms of service, new tools, new policies, etc)?

If yes, list these implementation measures here

Do you plan to put further implementation measures in place in the next 6 months to substantially improve the maturity of the implementation of this commitment?

If yes, which further implementation measures do you plan to put in place in the next 6 months?

Crisis and Elections Response

Elections 2024

[Note: Signatories are requested to provide information relevant to their particular response to the threats and challenges they observed on their service(s). They ensure that the information below provides an accurate and complete report of their relevant actions. As operational responses to crisis/election situations can vary from service to service, an absence of information should not be considered a priori a shortfall in the way a particular service has responded. Impact metrics are accurate to the best of signatories’ abilities to measure them].

Threats observed or anticipated

Threats observed or anticipated at the time of reporting: Alliance4Europe saw an increased use of AI in influence operations. We are also concerned about the uneven enforcement of sanctions by social media platforms, allowing influence operation actors to operate on social media, spreading their illegal content.

We are also observing how anonymous accounts and CIB networks are still operating freely, engaging in influence operations while hiding their affiliations.

- 700 channels violating sanctions against Russian media or sanctioned individuals on social media platforms.
- 611 influence operation ads not labelled as political at the time of posting.
- 131 instances of unlabeled AI-generated images used by European political parties.
- 1.6k Doppelganger tweets.
- Over 800 organizations were targeted by a Russian influence operation.
- Approximately 99k violations against the French election silence period.
- Two platforms' reporting systems fell short of their DSA obligations during the French elections.
- Serious attempts to manipulate the Romanian elections results through coordinated inauthentic behaviour trying to manipulate TikTok’s algorithm.

Mitigations in place

Alliance4Europe is working to convene a wide range of civil society actors who can work together to on a systemic level analyse and tackle these threats. We have also reported numerous influence operations to the platforms and regulators, highlighting the systemic vulnerabilities being exploited.

Integrity of Services

Outline approaches pertinent to this chapter, highlighting similarities/commonalities and differences with regular enforcement.

Measure 16.1
Alliance4Europe shared relevant information about cross-platform information manipulation, foreign interference in the information space and incidents via the CoP rapid response system and through our Counter Disinformation Network Slack Workspace.

QRE 16.1.1
Alliance4Europe has developed a one-page template to summarise cases, allowing readers to quickly get an overview of a case, the TTPs and narratives used, the impact, actions we have taken, and recommendations.

SLI 16.1.1
Nr of actions taken (total): 37.
Type of detected content: AI content, silence period violations, unlabelled ads, influence operations, CIB networks, sanctions violations

Measure 16.2
A4E has published 37 alerts that show the tactics and techniques employed by threat actors, showing how these change over time.

QRE 16.2.1
A4E has alerted affected platforms about the tactics and techniques we have spotted being used on their platforms, providing them with the tools they need to mitigate them.

Empowering Users

Outline approaches pertinent to this chapter, highlighting similarities/commonalities and differences with regular enforcement.

Measure 17.2
Alliance4Europe has developed and run activities to improve media literacy and critical thinking, including running campaigns to raise awareness about disinformation and the TTPs being used by malicious actors.

QRE 17.2.1
Conducted 16 workshops and presentations targeting a broad European Audience.

Conducted a large media campaign to inform the public about Doppelganger.
Contributed twice to TVP’s Anatomy of Disinformation series.

Ran an information campaign on Operation Overload’s use of QR Codes.

SLI 17.2.1 - actions enforcing policies above
Nr of media literacy/ awareness raising activities organised/ participated in: 20
Reach of campaigns: 500,000.
Nr of participants: 450

Empowering the Fact-Checking Community

Outline approaches pertinent to this chapter, highlighting similarities/commonalities and differences with regular enforcement.

Measure 30.1
Alliance4Europe has established MoUs with Fact-checking organisations, EDMO Hubs, and leaders of EDMO hubs to join A4E’s Counter Disinformation Network.

Their membership enables easy and quick collaborations between fact-checkers, OSINT researchers, academics, and journalists. We provided fact-checkers with data access, free training, and a space for coordination. The agreement does not entail any obligations nor in any way control.

SLI 30.1.1
Number of languages covered: Polish, Swedish, English, Danish, Finish, French, German, Moldovan, Italian, Belarusian.
Nr of agreements with fact-checking organisations: 10.

Measure 30.3
Actions taken by Alliance4Europe to facilitate cross-border collaboration between fact-checkers.

QRE 30.3.1
Alliance4Europe has brought together fact-checkers with other counter-disinformation practitioners from different EU countries, giving them a space to coordinate their work and launch larger projects.