The 2018 Communication on Fake News and Online Misinformation – A Retrospective
Statement by GISAD – Global Institute for Structure relevance, Anonymity and Decentralisation
A self-commitment without an audit is advertising.
The Commission Communication of 2018 (COM(2018) 236) was the founding moment of European disinformation policy – and a political failure of the first order. The state let the platforms grade their own homework. The Commission knew full well that disinformation is not a marginal phenomenon but a business model – and it treated it like a misunderstanding to be politely resolved with a voluntary code. Seven years were lost before the Digital Services Act had to follow up.
What 2018 got right
Only one thing: It would have been wrong to demand what authoritarians have always demanded – an authority that decides what is true. Such a ministry of truth would itself be the greater structural hazard to democracy. Content-based censorship is and remains the wrong instrument. But whoever rejects censorship has the duty to measure structure. The Commission rejected the one – and omitted the other.
What 2018 got wrong
The 2018 Code of Practice was a fig leaf: no indicators, no verification, no sanctions. Transparency without verification is self-display. The platforms reported what suited them – and politics called it progress. The damage account is well known: a new version in 2022, integration into the DSA in 2025, auditable obligations only since 1 July 2025. Seven years of repair for a mistake that was avoidable in 2018: the renunciation of measurement. Concept fidelity is not created by examples, but by measurement – including in the self-regulation of corporations.
The open question of today
The first transparency reports under the DSA Code are on the table – and the Commission expressly refuses to assess whether the measures are sufficient. This is the old lie of 2018 in a new guise: whoever collects reports instead of measuring effect is doing file administration, not regulation. What must be measured is what costs money and reach: demonetised advertising revenues in euros, the reach of debunked content, the speed of amplification, the independence of auditors. Everything else is figure cosmetics.
Conclusion. European disinformation policy should hold fast to the prohibition of a ministry of truth – and finally enforce the measurement of the amplification structure: independent audits with published methodology, mandatory access for researchers, structural indicators with automatic sanctions. Whoever sells attention also sells the conflict – but a conflict that a platform amplifies algorithmically is no longer an opinion. It is a product. Products can be measured. And what can be measured can be regulated. The 2018 Communication saved Europe from censorship – not from unmeasurability. That is the lesson for every future code: a voluntary commitment is worth exactly as much as its verification – and whoever refuses to be audited has something to hide.
GISAD – Global Institute for Structure relevance, Anonymity and Decentralisation · Registered in the EU Transparency Register, No. 244298340978-40
Sources: European Commission – Have your say: Communication on fake news and online misinformation · EUR-Lex – COM(2018) 236 · European Commission – The Code of Conduct on Disinformation