Introduction
This report marks the culmination of a year-long effort to monitor elections across four countries by the “FIMI Defenders for Election Integrity” project, drawing on the collective work of partners engaged in exposing Foreign Information Manipulation and Interference (FIMI). Its purpose is to take a step further from incident documentation to reflect on what these findings reveal about systemic violations and potential breaches of the EU Digital Services Act (DSA). The exercise is not a legal assessment, but rather a bridge between research and policy: an attempt to show how civil society monitoring can inform real accountability and guide future enforcement.
Because the analysis builds on secondary materials provided by partner organisations, it remains necessarily interpretative. Each case offers a window into how platform governance operates in practice, how certain forms of manipulation persist despite clearly defined but poorly enforced rules, and how the boundaries between illegal and permissible behaviour continue to blur. By revisiting twelve descriptive Incident Alerts (IAs) through a DSA lens, the report aims to identify what evidence is still missing to transform qualitative observations into actionable evidence for current and future DSA infringement proceedings.
The report is organised in three parts. It first outlines the methodology guiding the project. It then turns to the analysis, beginning with an overview of the selected cases before exploring their relevance under the DSA and platform Terms of Service (ToS). The final section reflects on emerging lessons and best practices – how researchers and policymakers can work together to close evidence gaps, strengthen systemic risk monitoring, and ensure that future election cycles are met with a more resilient digital environment.