
Jamily Maiara Menegatti Oliveira (Masters in European Union Law from the School of Law of University of Minho)
As we mentioned in last week’s post, on 18 November 2025, the European Board for Digital Services – in cooperation with the European Commission – published the first annual report under Article 35(2) of the Digital Services Act (DSA), dedicated to identifying the most prominent and recurring aspects of systemic risks associated with Very Large Online Platforms (VLOPs), as well as the respective mitigation measures.[1] This is an institutionally relevant document, not only because it inaugurates a new reporting cycle under the DSA, but above all because it reveals how the European Union is beginning to translate classic democratic concerns – such as the integrity of public debate and electoral processes – into the language of risk governance.
Among the various areas analysed, Section 3.3 stands out, in which the report identifies systemic risks associated with civic discourse, electoral processes and public safety. The decision to treat these elements as structural risks, rather than as isolated incidents or mere pathologies of the digital environment, is particularly significant. It highlights the recognition that the regular functioning of platforms – through their algorithmic systems, amplification models and moderation practices – can profoundly affect the conditions under which public opinion is formed in a democratic society.
Continue reading “Systemic risks, digital platforms and electoral integrity in the European Union: reflections from the first report under Article 35(2) of the Digital Services Act”








