The digital information environment, once celebrated for democratizing access to knowledge, is today a contested space riddled with manipulation, mistrust, and algorithmic opacity. AI-generated deepfakes, foreign interference in elections, and algorithmic amplification of disinformation, pose unprecedented challenged to legal systems by degrading public discourse and weakening democratic processes.
The concept of information integrity, while still evolving, is gaining traction in international frameworks to preserve democratic values in the digital age. It aims to ensure that online information ecosystems remain trustworthy and grounded in human rights – particularly the right to freedom of expression.
The concept of information integrity
The term “information integrity” lacks a universally agreed definition, but its meaning is converging around the goal of preserving the truthfulness, transparency, and accessibility of online information ecosystems.[1] As it will be discussed below, international institutions such as the United Nations, the OECD, and the European Union are embracing the concept to unite fragmented efforts against disinformation, misinformation, and hate speech, while simultaneously protecting freedom of expression.
In legal contexts, information integrity interacts with fundamental rights protected under the EU Charter of Fundamental Rights (freedom of expression and information enshrined in Article 11), the European Convention on Human Rights (freedom of expression enshrined in Article 10), and international law, including Article 19 of the International Covenant on Civil and Political Rights and the Universal Declaration of Human Rights (the right to freedom of opinion and expression). However, translating these abstract norms into actionable legal obligations for platforms, state actors, and intermediaries is a central challenge.
The rise of integrity as a regulatory lodestar also raises deeper questions. What exactly constitutes “truthful” or “trustworthy” information – and who gets to decide this? While the notion promises neutrality and civic cohesion, it also risks introducing hierarchical mechanisms of control over the digital sphere. New methods of control in the digital age can stifle mass participation, thereby undermining democratic cultural production.[2] As Balkin notes: “freedom of speech will depend on the design of the technological infrastructure that supports the system of free expression and secures widespread democratic participation.”[3] In this light, information integrity must not become a pretext for protecting only institutionalized or authoritative content at the expense of grassroots or countercultural voices.
Emerging norms across the globe
The European Union has taken a leading role in operationalizing information integrity through legislation, institutional development, and international cooperation. Central to this effort is the European Democracy Shield, an umbrella initiative proposed in July 2024 to consolidate the EU’s regulatory and strategic approaches.[4] This framework will “address the most severe risks to democracy in the EU”[5] by integrating key measures such as the Digital Services Act, the European Media Freedom Act, the AI Act, and the Political Advertising Regulation, which, combined together, seek to strengthen democratic resilience and platform accountability:
- The Digital Services Act (DSA): Imposes due diligence obligations on very large online platforms (VLOPs) and search engines (VLOSEs) to assess and mitigate systemic risks, including those stemming from disinformation, with the Commission and the European Board for Digital Services formally endorsing the incorporation of the voluntary EU Code of Practice on Disinformation into the DSA framework in 2025.[6]
- The AI Act: Introduces obligations on high-risk AI systems, including generative AI used in manipulating content (e.g., deepfakes).
- The European Media Freedom Act: Seeks to ensure editorial independence and safeguard pluralistic media against state and commercial pressures.
- The Regulation on Transparency and Targeting of Political Advertising: seeks to promote the effective functioning of the internal market for political advertising while fostering open and fair political discourse.
Together, these EU instruments create one of the most robust legal frameworks globally for promoting information integrity. At the institutional level, the European External Action Service (EEAS) has developed a comprehensive toolkit to counter Foreign Information Manipulation and Interference (FIMI), including strategic communications, data analysis teams, and regional task forces focused on geostrategic threats.[7] The European Parliament, through its Special Committees INGE[8] and ING2,[9] has advocated for a Centre for Information Integrity to foster inter-institutional coordination.[10]
Norm-building efforts extend beyond Europe. Canada and the Netherlands launched the Global Declaration on Information Integrity Online in 2023, endorsed by over 35 countries.[11] This declaration commits signatories to a rights-based digital environment free from state-sponsored disinformation and promotes algorithmic transparency, AI safety, and user empowerment.
The United States, through its May 2024 International Cyberspace Strategy, prioritizes defending information integrity in its digital diplomacy.[12] Joint EU-US mechanisms in regions like the Western Balkans aim to reduce the influence of authoritarian propaganda, notably from Russia and China.[13]
Multilateral Responses
Over the past decade, the multilateral response to challenges in the digital information environment has evolved from fragmented, ad hoc measures to a more structured and principle-based approach. Initially focused on isolated events such as election interference and crisis-related misinformation, international efforts began to coalesce around more coordinated strategies after 2018, led by the European Union, such as the EU’s efforts to counter foreign information manipulation and interference (FIMI) through the European External Action Service (EEAS)[14] and its East StratCom Task Force. This evolution gained momentum with the United Nations’ 2023 policy brief on digital platform governance and culminated in the release of the UN’s five global principles for information integrity in June 2024.[15] These principles – emphasizing societal trust, healthy incentives, and pluralistic media – are now integrated into the broader Global Digital Compact, aligning with the Sustainable Development Goals and international human rights law. Similarly, the OECD has advanced its “Reinforcing Democracy” initiative by launching the Information Integrity Hub and publishing the 2024 report titled “Facts not Fakes”, which advocates a multi-stakeholder, human-rights-based governance model to fortify democratic resilience without compromising media freedom.[16]
Concluding remarks
Despite robust frameworks, challenges remain. The lack of a universally accepted definition of information integrity complicates implementation. Moreover, geopolitical rifts – such as tensions between EU regulatory models and U.S. market-driven approaches – may slow international alignment.[17] The rise of generative AI introduces new vectors for information pollution, necessitating constant innovation in detection, labelling, and governance. Yet, the opportunity lies in convergence: the EU’s democracy shield, UN principles, OECD standards, and regional initiatives together point toward an integrated, rights-respecting architecture for the digital public sphere.
Yet, another risk emerges from the very structure of the integrity discourse itself. As regulatory and institutional actors formalize expectations around content moderation, the hierarchization of digital speech becomes more visible. Integrity may slide into a moralized, even punitive framework – a label that disciplines non-conformity rather than embracing pluralism. This is particularly acute in the algorithmic curation of platforms, where the prioritization or suppression of content often reflects not neutral principles, but deeply embedded value systems.
Thus, information integrity is not merely about defending against disinformation – it is about constructing the boundaries of legitimate speech in a digital society. For legal professionals, this is both an opportunity and a responsibility: to ensure that these boundaries remain rights-based, transparent, and inclusive, rather than tools of exclusion cloaked in the language of security or order.
[1] Bentzen, Naja. Information Integrity Online and the European Democracy Shield. European Parliamentary Research Service, Dec. 2024. PE 767.153.
https://www.europarl.europa.eu/thinktank/en/document/EPRS_BRI(2024)767153.
[2] This was recognized already at the beginning of the 21st century, see: Balkin, Jack M. “Digital Speech and Democratic Culture: A Theory of Freedom of Expression for the Information Society.” New York University Law Review, vol. 79, no. 1, 2004, pp. 1–58.
[3] Ibid., page 1.
[4] Bentzen, 2024.
[5] European Commission. “European Democracy Shield.” Better Regulation – Have Your Say. European Commission, https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14587-European-Democracy-Shield_en.
[6] European Commission. “Commission Endorses the Integration of the Voluntary Code of Practice on Disinformation into the Digital Services Act.” European Commission, 13 Feb. 2025. https://ec.europa.eu/commission/presscorner/detail/en/ip_25_505.
[7] European External Action Service. “Information Integrity and Countering Foreign Information Manipulation & Interference (FIMI).” European External Action Service, 14 Mar. 2025, https://www.eeas.europa.eu/eeas/information-integrity-and-countering-foreign-information-manipulation-interference-fimi_en.
[8] European Parliament. INGE ICM on the Foreign Interference in All Democratic Processes in the European Union, Including Disinformation. 9 Nov. 2021, https://www.europarl.europa.eu/relnatparl/en/inge-icm-on-the-foreign-interference-in-/products-details/20211025CPU37462.
[9] European Parliament. First ING2 ICM on „the Legislative Resilience, Electoral Laws or Information Manipulation Campaigns.” 1 Dec. 2022, https://www.europarl.europa.eu/relnatparl/en/-first-ing2-icm-on-the-legislative-resil/products-details/20221027CPU39741.
[10] Bentzen, 2024.
[11] Government of Canada. Global Declaration on Information Integrity Online. Sept. 2023. https://www.international.gc.ca/world-monde/issues_development-enjeux_developpement/peace_security-paix_securite/information_integrity-integrite_information.aspx?lang=eng.
[12] U.S. Department of State. International Cyberspace and Digital Policy Strategy. May 2024. https://www.state.gov/wp-content/uploads/2024/07/United-States-International-Cyberspace-and-Digital-Strategy-FINAL-2024-05-15_508v03-Section-508-Accessible-7.18.2024.pdf.
[13] U.S. Department of State. U.S.-EU Coordination Mechanism on Information Integrity in the Western Balkans. Media Note, Office of the Spokesperson, 23 May 2024, https://2021-2025.state.gov/u-s-eu-coordination-mechanism-on-information-integrity-in-the-western-balkans/.
[14] European External Action Service. 1st EEAS Report on Foreign Information Manipulation and Interference Threats. Strategic Communications Division, 7 Feb. 2023, European External Action Service, https://www.eeas.europa.eu/eeas/1st-eeas-report-foreign-information-manipulation-and-interference-threats_en.
[15] United Nations.United Nations Global Principles for Information Integrity. June 2024, https://www.un.org/en/information-integrity/global-principles.
[16] OECD. Facts not Fakes: Tackling Disinformation, Strengthening Information Integrity. OECD Publishing, 2024. https://www.oecd.org/en/publications/2024/03/facts-not-fakes-tackling-disinformation-strengthening-information-integrity_ff96d19f.html.
[17] Bentzen, 2024.
