I. Introduction
From viral disinformation campaigns to the algorithmic mobilisation of “the people” against “the elites,” the digital arena has birthed a novel threat to constitutional stability: digital populism. This new variant exploits the regulatory vacuum of the Internet and the disintermediation of social media. Moving beyond the well-documented socio-economic roots of populism,Footnote 1 this article focuses specifically on the intersection between this new digital variant of populism and existing regulatory frameworks of the online environment. It contends that regulatory efforts to safeguard democracy will fail unless they address digital populism as a holistic ecosystem.
That populism has advanced and claimed institutional authority in several jurisdictions,Footnote 2 and that online platforms can enhance (or harm) free speech in the digital environment,Footnote 3 are well-established facts. There is no consensus on the notion of populism, or on the interplay between the latter and democracy. Yet, it is undisputed that populism, especially in its digital form, has become a topic of central importance in understanding the evolution of contemporary constitutionalism, especially in the EU.Footnote 4 For instance, the role of online platforms in crucial elections for European and global democracy,Footnote 5 or the influence exercised by external actors over the public perceptions and representations of the EU channelled through online fora,Footnote 6 has been documented and explored at length.Footnote 7
Also, much has been said on online platforms and their regulation. Existing literature has unpacked the intersection between democracy and online free speech, standing in a synergetic yet conflictual interaction.Footnote 8 Multiple scholarsFootnote 9 have highlighted how the relationships of power among actors of the digital environment have induced and shaped the current challenges around online free speech,Footnote 10 with social media platforms positioned to influence this right within their environments. AcademicsFootnote 11 have denounced a number of loopholes in EU digital regulation, ranging from the incoherent rationale of rules,Footnote 12 as well as their partial, ineffective enforcement.Footnote 13 Against this background, the view has been advanced that regulation should tackle the imbalances in structure and access characterising the digital environment,Footnote 14 as well as the concentration of data and market power in the hands of digital platforms.Footnote 15 Notwithstanding their richness and breadth, both EU frameworks and academic debates have failed to take into account the pressing phenomenon of digital populism, thus disregarding its pivotal role and influence in the transformation of EU politics and public discourse. A comprehensive understanding of digital populism has yet to emerge, and scholarly works have not explored the regulatory challenges of this phenomenon, thus far.
This article submits that embracing an ecosystem perspective provides analytical clarity on the concept of digital populism and lays the foundation for improving its regulation. Although ecosystems are traditionally identified in the natural world, the idea of relational networks – which underpins the concept of “ecosystem” – is also used in other fields of academic enquiry, including organisational and management studiesFootnote 16 and economics.Footnote 17 Due to their complexity, online platforms have been compared to ecosystems, where, often, conflicting dynamics and interests clash.Footnote 18 Studies on online platforms’ ecosystems have unearthed the economic and governance repercussions of the various models; yet the same lens has not been applied to digital populism and its regulatory challenges.Footnote 19
The more holistic perspective offered by an ecosystem standpoint illuminates concealed patterns and forces at play in the digital environment, particularly regarding digital populism, that could be redirected and reshaped by regulation. By unpacking the actors, processes and dynamics involved in digital populism under an ecosystem approach, it is possible to reveal thus far hidden aspects of this political strategy and to identify regulatory approaches to more effectively counter this novel political strategy. This analytical perspective is particularly fitting for identifying the weaknesses of current EU frameworks regulating digital platforms,Footnote 20 which are populated by a plethora of entities with varying interests and complex dynamics. By strengthening EU rules on the digital space and digital populism, liberal democracy could also be bolstered.
Accordingly, the article provides a twofold innovative contribution to the literature: first, it advances conceptual clarity around digital populism and unpacks its ecosystem; second, while acknowledging the efforts of jurisdictions, such as the EU, to adopt measures to govern the digital environment, and, by proxy, digital populism, it offers proposals on policy objectives and recommendations for improving the fight against this phenomenon through regulation under an ecosystem standpoint.Footnote 21 We demonstrate that exploitation of the digital environment’s structures, as well as gaps in existing regulation due to a limited understanding of the ecosystem of digital populism, are contributing causes of digital populism.Footnote 22 Our analysis crucially sheds light on the limitations of current and emerging regulatory approaches to digital platforms, especially in the EU. The limited effectiveness of these measures is essentially due to a narrow focus on actors and practices (e.g., online platforms and content moderation), enforcement mechanisms (e.g., the data subject’s procedural rights under the General Data Protection Regulation,Footnote 23 or the notice and take-down mechanisms of EU directive 2000/31, now provided for in the Digital Services Act),Footnote 24 and a regulatory model (i.e., co-regulation) that address only some aspects of digital populism’s ecosystem. Accordingly, our proposals aim to stimulate regulatory approaches to the digital environment that address these drawbacks.
The discussion is structured as follows. First, the article introduces the concept of populism (section II) before expounding its digital dimension (section III) and its systemic challenges to liberal democracy (section IV). Subsequently, the discussion highlights the partial effectiveness of recent EU regulatory measures, which focus on online platforms’ governance, free speech and data protection (sections V and VI). The ecosystem of digital populism is then outlined and discussed, jointly with the actors, processes and dynamics at play in this phenomenon (section VII). Building on that analysis, the article advances policy recommendations to achieve more effective regulation of the digital environment, with a view to governing the threats to liberal-democratic values posed by digital populism (section VIII). Concluding remarks follow (section IX).
II. Populism: a conceptual analysis
In common parlance, the term “populism” is often employed with a negative connotation, which “tends to evoke the popular element as an irrational demonic force unleashed on otherwise functional liberal democracies.”Footnote 25 However, some scholars have argued for a more neutral understanding of the termFootnote 26 and have interpreted it as a logic.Footnote 27 Others argue that the way populism is conceptualised remains a subject of ongoing scholarly debate,Footnote 28 due to the “constitutive ambiguity” of the phenomenon.Footnote 29 Rather than representing only a pathological or detrimental reality, populism is better understood as a “complex phenomenon”Footnote 30 and “an essentially contested concept.”Footnote 31 This diversity of analytical approaches has led to multiple, and sometimes competing, understandings of what populism entails.Footnote 32 Berlin once memorably described populism as suffering from a “Cinderella complex.”Footnote 33 Populism is presented as a “thin-centred ideology”Footnote 34 which “can be easily combined with very different (thin and full) other ideologies, including communism, ecologism, nationalism or socialism.”Footnote 35
In recent scholarship, the tension between populism and democracy has been explored through analyses of the contested use of direct democracy mechanisms and the role of counter-majoritarian institutions.Footnote 36 For instance, Canovan offered a compelling definition of populism as the “shadow” of democracy.Footnote 37 Urbinati, instead, interprets populism as a source of democratic disfiguration.Footnote 38 She also highlights the transformative role of populism, noting that it asserts a claim over the deliberately constitutionally inclusive notion of “the people,” representing it instead as a unified and exclusionary category,Footnote 39 thereby casting “the other” as the enemy.Footnote 40 This means that populism and democracy need not be viewed as strictly opposing ideas; they may instead be seen as coexisting in a state of conceptual and institutional tension, which can shed light on the complex role attributed to “the people” in democratic systems.
Another important difference is between populism as a movement of opinion (critical or oppositional) and populism as a ruling power.Footnote 41 Populism has also been portrayed as a political mobilisation strategy, marked by a rhetoric that uses simple language to appeal to the broader public.Footnote 42 Populist forces and political movements have recently secured parliamentary majorities in a number of countries.Footnote 43 The emergence of populist governments inevitably reinvigorates the debate surrounding the relationship between populism and constitutionalism. Corrias sought to explain why constitutional scholars have only recently begun to engage with populism, moving beyond a purely conflict-based perspective and showing that, to some extent, populism can even be interpreted as possessing its own form of constitutional reasoning.Footnote 44
Instead of offering a single definition, scholars have sought to grasp the essence of populism by identifying key elements,Footnote 45 such as the prominence of “the people” – understood in various waysFootnote 46 – and anti-elitism.Footnote 47 Populism is often associated with demagogy,Footnote 48 yet it manifests in a range of forms, demonstrating remarkable ideological flexibility.Footnote 49 Further features of populist movements include “identity politics,” the “politics of immediacy,” and extreme majoritarianism. These characteristics are central to distinguishing the form of democracy promoted by populists from that safeguarded by post-World War II constitutionalism.
“Identity politics” involves portraying the majority as a unified entity endowed with moral superiority, in contrast to the elite, which is often depicted as corrupt.Footnote 50 Here, the reductionist attitudeFootnote 51 of populism reveals itself, leading to the representation of all those who cannot be traced back to the majority as the “others.” Populism appeals to a “mythical Volksgemeinschaft”Footnote 52 and constructs “imagined communities”Footnote 53 by searching for political enemies. Jan-Werner MüllerFootnote 54 has discussed how populism’s tendency to divide society into a homogeneous “people” and a “corrupt elite” mirrors Carl Schmitt’s concept of the political, which is grounded in the friend-enemy distinction. Müller argues that this dynamic reflects a Schmittian approach to politics, where the identification of an enemy becomes central to political identity and action.Footnote 55 This also helps explain the often bombastic nature of populist rhetoric. Populists rely on “walls” to delineate a boundary between what they claim to be the “real” people and others, constructing their identity by excluding political competitors from the circle of legitimacy. In other words, the majorities envisioned by populists are rarely inclusive, creating a paradox with respect to the very democratic aspirations populism claims to champion.
“Politics of immediacy,”Footnote 56 instead, refers to a kind of politics which rejects the idea of mediation offered by representative institutions. This further confirms that populism seeks to craft a constitutional counter-narrative, drawing on constitutional concepts while simultaneously exposing its anti-pluralist conception of democracy promoted by populist movements.Footnote 57 Accordingly, the populist narrative is imbued with emotional appeals, assertions of moral superiority, quasi-messianic rhetoric, and a divisive stance towards society. Both the dynamics of “identity politics” and the “politics of immediacy” reinforce a form of extreme majoritarianism, grounded in the dominance of the majority. For these reasons, populism is often associated with illiberalism,Footnote 58 although it cannot be ruled out that the phenomenon might also encompass more liberal political orientations.
For the purposes of this article, populism can be understood as a political approach that seeks to advance a constitutional counter-narrative,Footnote 59 which is often in tension with liberal-democratic principles such as equality, inclusivity, and deliberation.Footnote 60 In its more extreme manifestations, it may be seen as the instrumentalisation and amplification of majoritarianism, potentially resulting in a form of “majority rule” that undermines broader democratic safeguards.Footnote 61 The rise of online platforms and social media has contributed to the emergence of a new form of populism, which can be seen as one of the factors driving the spread of populist agendas and the associated weakening of liberal-democratic norms worldwide. Addressing populism, particularly in its digital form, and the systemic challenges it poses, should be a priority for any democratic system grounded in liberal principles.
III. The blueprint of digital populism
In recent years, a new variant or mediated formFootnote 62 of populism has emerged, exploiting the piecemeal regulation of Internet platforms and the disintermediation enabled by social media. We call this “digital populism”Footnote 63 instead of “techno-populism”Footnote 64 in order not to confuse the former with phenomena related to technocracyFootnote 65 and to better specify the media channel on which this populism depends. Digital populism, like all media populisms,Footnote 66 is strongly connected to the media tools (i.e., digital technologies such as the Internet and social media platforms) that make its existence possible. Numerous scholars have highlighted the connection between digital platforms and populism. In particular, the concept of “online opportunity structure”Footnote 67 describes the relationship between social media platforms and digital populism. The distinctiveness of the digital version of populism,Footnote 68 compared to its “offline” variant, can be appreciated by reference to at least four characteristics of the phenomenon.
First, digital populism benefits from the significant volume of data processed through online platforms.Footnote 69 The collection of that information has been used by political actors to understand individual preferences and general trends of ideas shared by online users – knowledge subsequently exploited by populist leaders both to their advantage and to disseminate targeted propaganda.Footnote 70
Second, digital populism has grown thanks to the deployment of content personalisedFootnote 71 to online users. Using the preference patterns embedded in social media algorithms, users have been incrementally targeted with populist material while being gradually shielded from other content offering contrasting views, a dynamic that ultimately contributes to the formation of so-called “echo chambers.”Footnote 72
Third, the possibility of targeting online users with personalised content has reinforced the impact and relevance of digital populist actors in the online communities. It is well established that the “similar-to-me” effect, or affinity bias, leads to stronger convergences of ideas and, ultimately, trust.Footnote 73 Accordingly, the spread of personalised content enabled by social media algorithms, which provided insights on the preferences expressed online by the targeted individuals, has found receptive audiences due to the psychological resonance of the content used for targeting.
Fourth, by exploiting the direct appeal of content to the addressees, as well as the openness of social media platforms, digital populist actors can create a militant audience. This has contributed to the diffusion of propagandistic material in an increasingly polarised social media environment. In addition to genuine supporters of populist agendas, less virtuous practices, such as astroturfing and the use of bots, facilitated the dissemination of propagandistic, often incorrect, information. The initial disintermediation inherent in these new media channels has also facilitated the widespread use of disinformation.Footnote 74 As a result, the diffusion of populist content online has been exponential.Footnote 75 More recently, digital populists have even begun to employ micro-influencers to circumvent new regulations or self-regulation by social media platforms;Footnote 76 the 2024 Romanian presidential election was a notable case in this trend.Footnote 77
Therefore, digital populism differs from “offline” populism in its particularly compelling appeal and far-reaching spread through online channels. The core features of populism – such as extreme majoritarianism, the “politics of immediacy,” and identity-based mobilisation – are amplified through digital channels. In other words, it is through the presence of specific socio-technical mechanisms and disintermediation typical of the online environment that this amplification occurs. The key difference between “offline” and “online” populism, therefore, is in terms of the reach and magnitude of the phenomenon and its features: populist propaganda shared on online platforms can be visualised and read by thousands of users at a time, facilitating the exponential diffusion of extreme majoritarianism, the “politics of immediacy,” and identity politics in the online world.
A clarification is required, especially given the central roles assumed by controversial tech figures in shaping the global digital environment, such as Elon Musk and Peter Thiel – the latter being a philosophically far more complex individual than the former. While it is true that the current wave of digital populism did not originate from technology but rather emerged within it, figures like Musk and Thiel actively amplify overtly anti-democratic and authoritarian traits through their public discourse and, in Thiel’s case, writings.Footnote 78 Such elements are not inherently present in broader digital populist dynamics, which, despite their contradictions, often claim to pursue the ideal of a “fuller” democracy.
A common denominator undoubtedly exists in the shared rejection of liberal constitutionalism and the rule of law. In this context, Elon Musk embodies the visibility and spectacular disintermediation of power, while “thinker-entrepreneurs” like Peter Thiel provide the underlying ideological infrastructure: a radical critique of institutional mediation and liberal constitutionalism, cloaked in anti-elite rhetoric – notably, a rhetoric driven by a billionaire elite. By definition, digital populism does not necessarily culminate in authoritarian outcomes; rather, it operates precisely within this tension: the language of the people paired with an architecture of control; a sovereignty that is constantly evoked, yet never truly restored.
The rise of populism on digital platforms is evidently a complex phenomenon that affects liberal-democratic values in wide-ranging ways.Footnote 79 Several adverse effects materialise, which underpin systemic challenges to liberal-democratic values, such as pluralism, the fundamental right to information, and diversity. The following section examines the challenges posed by digital populism to liberal democracy.
IV. The “democratic” challenges of digital populism
The first democratic challenge posed by digital populism is the disintermediation of users from epistemic communities:Footnote 80 populists have often described scientists, academics, and journalists as members of a “corrupt elite.”Footnote 81 While the end of the traditional media’s monopoly on the production and dissemination of culture democratised the dissemination of content, it also led to the disappearance (or near-disappearance) of expert knowledge in the online world. Disintermediated channels such as social media platforms make it possible to overcome the filter of traditional mass media. Digital populists have exploited this disintermediation to challenge, disqualify and provide alternative scientific “truths” to their own supporters, who are often (due to ideological self-selection)Footnote 82 trapped in filter bubblesFootnote 83 with a high populist potential (i.e., self-selected personalisation).Footnote 84 In this regard, Nichols spoke of the death of expertise online.Footnote 85 The anti-vaccination populist social media campaign which emerged during the COVID-19 pandemic may be regarded as a chief example of this dynamic.Footnote 86 The constitutional relevance of “expert” communication and information, which would be undermined by digital populist practices, could be linked to the European “right to be correctly informed,”Footnote 87 although the existence and scope of such a right remains controversial.Footnote 88
Indeed, the debate over the constitutional protection of the dissemination of expert knowledge in Europe under the European Convention on Human Rights and EU fundamental rights has left several constitutional questions remaining unresolved.Footnote 89 In particular, it is unclear whether European States bear positive obligations to protect the dissemination of expert knowledge, and whether such knowledge should receive enhanced protection or greater visibility within online public discourse to secure the conditions necessary for the circulation of public-interest knowledge. Regardless, the disappearance of expert knowledge could undoubtedly undermine the functioning of liberal democracies and the fundamental rights they protect, such as the rights to access accurate information, to health, and to good administration.Footnote 90
The challenge of disintermediation is linked to that of polarisation.Footnote 91 This phenomenon is favoured by the hyper-simplification of complexity offered by social media, where the presentation of information and the possibility to “react” to content have created an over-simplified hierarchy of epistemology. Through these structures, social media have contributed to a flattening of critical skills and thus built a fertile ground for the polarisation of public opinion. If this kind of polarisation was perceptible even in the offline world, it has taken on an even more pronounced character on social media, greatly impacting the founding values of European constitutionalism, first and foremost, that of pluralism.Footnote 92 Exposure to a single and continuous political ideology, however “thin”Footnote 93 and unstructured (as populist ideologies are), prevents the exchange of opinions and ideas that is the basis of liberal democracy. Research has revealed that online polarisation tends to occur over a period of time through clustering of users.Footnote 94 Clustering can be measured by the degree of belonging to one or the other of the communities, and by the diversity of sources users interact with within each of these communities.Footnote 95 Dynamics of polarisation and thus clustering have been traced in relation to events such as the COVID-19 pandemic and the war in Ukraine.Footnote 96
This phenomenon is also a consequence of pre-selected personalisationFootnote 97 mechanisms of digital platforms, which favour the creation of involuntary closures in filter bubbles. Accordingly, populists can easily secure broad virtual audiences.Footnote 98 The mechanisms of pre-selected personalisation have supported populist “us versus the corrupt elites” narratives, allowing populist leaders to create and maintain filter bubbles of disintermediated and polarised content without a dialogue with other political/scientific/journalistic viewpoints.Footnote 99 Pluralism is accordingly eroded in the absence of regulatory safeguards ensuring the diffusion of diverse political views that, for instance, applied to traditional broadcasting services in Europe.Footnote 100 The rise of anti-establishment thinking through social media has reinforced far-right parties worldwide,Footnote 101 leading to the election of several extremist politicians in numerous jurisdictions.Footnote 102
Additionally, the disintermediated new media channels have provided the infrastructure for the development of alternative, bottom-up forms of e-democracy, thus fuelling the advancement of the “politics of immediacy” and of instantaneous democracy, removed from deliberative processes at the institutional level. In sum, disintermediation is central to digital populist actors. As has been observed:Footnote 103
The medium fits the message: it is distributed, non-hierarchical and democratic. It is an alternative to the mainstream media, which many supporters of populist parties strongly distrust. It is not controlled by the elites. Instead, the content is generated by us – the honest, hardworking, ordinary citizens, exactly the people who the populists are defending.
A third related challenge is that of radicalisation.Footnote 104 The radicalisation of political discourse by populist movements online inevitably leads to more aggressive narratives between political parties and among citizens, thus fragmenting the social substratum. In turn, radicalisation undermines the peaceful coexistence of community members, which is crucial to the functioning of democratic systems. Examples such as the assaults on institutional buildings in BrazilFootnote 105 and the United StatesFootnote 106 occurred within a framework of online radicalisation, polarisation and disinformation.Footnote 107 Radicalisation is also increasing in the EU,Footnote 108 prompting multiple reactive measures from the EU institutions.Footnote 109
Radicalisation tends to be, among other factors, a consequence of hate speech,Footnote 110 a form of expression that is not protected by European fundamental rights, even on the Internet, and that constitutes one of the earliest conflicts between European and US views on freedom of speech online.Footnote 111 Whether the Internet merely increases the visibility of hate speech or contributes to its rise remains debated.Footnote 112 In any case, greater visibility of, or an increase in, hate speech is also due to the (original) absence on social media platforms of the the filters that traditional media used to apply to the dissemination of certain forms of hateful speech in the analogue world. The anonymity that shields Internet users’ identities enables the expression of hatred while evading the social consequences that would arise in the analogue world,Footnote 113 and likewise facilitates the deployment of bots or astroturfers operating under false identities to spread hate speech.Footnote 114
The fourth systemic challenge brought about by digital populism is disinformation. The Strasbourg Court has repeatedly stated that the role of the press, one of the watchdogs of democracy, is to hold power accountable and report accurate facts.Footnote 115 However, as mentioned above, online social media have challenged this model, ending journalists’ monopoly on the dissemination of news and facts. Without the filter of professional journalists and experts, populists use disinformation as a propaganda weapon not by seizing power and subjugating traditional media, but by competing with them through digital platforms. Indeed, digital populists have made extensive use of disinformation, with completely fabricated news or with a mix of true and false facts,Footnote 116 exploiting the relative absence of filters and intermediationFootnote 117 and reinforcing identity politics:Footnote 118
[p]opulism embraces the notion that truth does not exist as a common good. Truth as a collective enterprise is dismissed as a pure ideological illusion of liberalism (…). Truth is divided, partisan, and ideological; it is anchored in particular social interests. Truth-seeking politics is about reaffirming “popular” truths against “elite” lies.
Urbinati utilised the concept of “objectocracy” to describe such a phenomenon.Footnote 119
The final challenge posed by digital populism concerns the modalities through which its promotion operates. These include circumventing electoral rules,Footnote 120 targeting users in ways that violate data protection rights, and using exploitative practices in relation to the personal data circulating online.Footnote 121 Several companies have collected personal data, without disclosing the types of data, to profile and target voters with political content.Footnote 122 The original lack of regulation of electoral content in the digital environment has conferred a significant advantage on digital populist actors, enabling them to deploy new forms of propaganda based on users’ personal data and sustained by substantial financial investment.Footnote 123 This phenomenon has been further characterised by attempts to evade emerging regulatory frameworks through the covert hiring of astroturfersFootnote 124 or micro-influencers,Footnote 125 or by deploying botsFootnote 126 to amplify populist messages. The opacity of these forms of political communication, the non-compliance with electoral spending rules, and the targeting of users in breach of data protection standards constitute central challenges to the effective functioning of contemporary democracies.
Those challenges intensified during election periods, when pluralism, journalistic standards and electoral rules – such as those governing campaign finance – could be undermined by propaganda disseminated on social media. All these dynamics have profoundly affected the way in which public discourseFootnote 127 has developed to date.
It is against this background that we should consider the measures adopted in the EU regarding online platforms, especially those governing content moderation, transparency duties and personal data protection. The EU has been touted as one of the most active regulators of the digital environment.Footnote 128 In particular, several recent EU frameworks impose content moderation obligations on digital platforms and develop new regulatory approaches to target online political propaganda, thereby countering digital populist communication strategies.
This regulatory strategy may appear, at first glance, appropriate: the systemic challenges posed by digital populism to liberal democracy, as described above, are related, although to varying degrees, to online speech and its governance. Nonetheless, existing EU measures present crucial gaps that undermine their effectiveness. By targeting digital platforms and imposing obligations on them in relation to content moderation, personal data protection and transparency, the EU regulatory model misses a more holistic and complete picture of the actors, processes and dynamics involved in digital populism – in other words, its ecosystem. By contrast, it will be argued, an ecosystem perspective on digital populism is likely to lead to the adoption of more effective rules to address the challenges it brings, thus ultimately reinforcing liberal democracy. The next sections illustrate these points.
V. Emerging (partial) regulatory responses: the EU’s multifaceted and incremental approach
The EU has historically been one of the most comprehensive regulators of personal data; it has also increasingly engaged in regulating hate speech, disinformation, content moderation, and online political targeting, as shall be discussed.
1. Personal data duties for online processors and controllers
The foundation of much of the EU’s regulation of online interactions is found in the GDPR. It introduces a set of rights for data subjects, alongside obligations for controllers and processors, to create guarantees for personal data control and oversight. For instance, data subjects have accessFootnote 129 and erasureFootnote 130 rights in relation to the processed information that allows their identification. Processors and controllers are subject to a joint liability regime to ensure that the processing of personal data is lawful,Footnote 131 requiring, among other obligations, that the purpose of processing is specified, explicit and legitimate.Footnote 132
Moreover, the GDPR prohibits the processing of special categories of data that could reveal sensitive details about data subjects, including political opinions.Footnote 133 This rule signals the objective of protecting political views and perspectives from manipulation and undue uses by controllers and processors – such as micro-targeting of users based on their personal data by online populist actors.
The GDPR’s governance aims to ensure a degree of control over personal data and its use by online platforms and the actors operating within them. In turn, such control helps users and regulators identify and contrast abuses of data power online that could lead to targeting data subjects with populist propaganda and harmful content. Thanks to these mechanisms, the GDPR could play a crucial role in preventing and combating the targeting of online users with populist content, thus reducing the democratic challenges of disintermediation, polarisation, radicalisation and disinformation.
2. Content moderation duties for online platforms
Content moderation duties for social media platforms were introduced in the EU with the e-commerce directive, which established mechanisms such as the notice-and-takedown systemFootnote 134 and the principle of absence of liability for mere conduits and carriers.Footnote 135 Since then, a series of codes, jointly with the DSA, have reinforced content moderation policies in the EU.
To begin with, the 2016 Code of Conduct on Countering Illegal Hate Speech Online, later updated in 2025 as “The Code of Conduct on Countering Illegal Hate Speech Online+”Footnote 136 and implemented pursuant to Article 45 of the Digital Services ActFootnote 137 (discussed below), addresses hate speech online. Striving to strike a balance between the free speech rights of social media users and the prohibition of hate speech, the Code establishes a system that limits the dissemination of illegal hate speech, based on collaboration among digital platforms and trusted flaggers, that is, entities designated by national Digital Services Coordinators,Footnote 138 who are responsible for detecting potentially illegal content and alerting online platforms under the DSA.Footnote 139 The Code requires social media platforms to adopt clear terms and conditions outlining the prohibition of hate speech on their services, including redress measures in the event of violations.Footnote 140
The 2018 Code of Practice on DisinformationFootnote 141 and the subsequent Strengthened Code of Practice also deserve mention. The Strengthened Code of Practice on Disinformation, adopted in 2022 and recently endorsed by the Commission as a Code under Article 45 of the DSA,Footnote 142 sets out a broader range of commitments and measures to counter online disinformation. In the Code, “disinformation” is defined as “misinformation, disinformation, information influence operations and foreign interference in the information space.”Footnote 143 Several are the obligations undertaken by the Signatory Parties through the Code. By way of example, they commit to defund the dissemination of disinformation, while improving the policies and systems that determine the eligibility and control of content for monetisation, and the monitoring of data used to report on the accuracy and effectiveness of controls and services around ad placements.Footnote 144 They also endeavour to prevent the misuse of advertising systems to disseminate disinformation.Footnote 145 Moreover, they undertake to cooperate with all relevant parties,Footnote 146 and pledge to adopt transparency measures to distinguish political from non-political advertising.Footnote 147 Finally, they are to empower users and the research community to better identify and tackle disinformation.Footnote 148
Through the fight against hate speech and disinformation, these Codes contribute towards several specific challenges of digital populism, such as radicalisation, polarisation and disinformation itself. A less hateful online agora is conducive to “healthier” speech, which aligns with pluralism, diversity and other liberal-democratic values.
Yet the DSA is now the centrepiece of EU content moderation. Accordingly, this instrument has significant potential for addressing the liberal-democratic challenges of digital populism. It promotes responsible and diligent behaviour by providers of intermediary services. As with the Code explored above, the DSA does not fight digital populism per se. Rather, while the tenets (e.g., notice-and-action mechanism;Footnote 149 exemption from liability)Footnote 150 of the e-commerce directiveFootnote 151 remain the same, the DSA introduces several novelties to partially address the challenges posed by digital populism.
Regulatory innovations concern transparency and reporting duties for platforms, as well as the enhancement of procedural rights for individuals. Providers of intermediary services should publicly issue machine-readable annual reports on the content moderation they engage in, including measures taken in applying and enforcing their terms and conditions.Footnote 152 The DSA also opens the door to limiting “echo chambers” or filter bubbles, stating that providers of Very Large Online Platforms (VLOPs) and Very Large Search Engines (VLSEs) should test the algorithmic systems they use, and are encouraged to mitigate the negative effects of personalised recommendations and correct the criteria used in their recommendations.Footnote 153
Moreover, Article 22 DSA provides for the existence of trusted flaggers who can report illegal content: these are subjects designated by the Digital Services Coordinator and equipped with a certain amount of expertise in the subject of the reports to which they are “deputed.” The institutionalisation of trusted flaggers may help counter the diffusion of illegal content, such as hate speech or pieces of radicalised, polarised disinformation spread by digital populist movements that have incited civil unrest and violence.Footnote 154
Additionally, the DSA introduced a set of provisions strengthening transparency around user targeting, thereby reinforcing the protection afforded by the GDPR.Footnote 155 The rules essentially revolve around disclosure duties for online platforms, which are required to maintain a publicly available repository of the entities that paid for advertisements, the nature of content shared in the advertisement, and whether the advertisement was intended to be presented specifically to one or more particular groups of recipients of the service, including the parameters used for targeting those users.Footnote 156 The reinforced transparency regarding advertising and targeting could help regulators, trusted flaggers and data subjects to identify instances of malicious behaviour that could further disintermediation, disinformation, radicalisation, and polarisation.
Through the risk assessment practicesFootnote 157 and mitigation measures introduced by the DSA,Footnote 158 polarisation could be reduced while fostering the re-emergence of pluralism, thus combating populist filter bubbles.Footnote 159 Furthermore, the DSA introduces emergency powers for the Commission to deal with “crises” under Article 36. According to that article, a crisis is defined as “extraordinary circumstances [that] lead to a serious threat to public security or public health in the Union or in significant parts of it.” One may reasonably suppose that the spread of misinformation/disinformation as part of digital populist propaganda could qualify as a “crisis,” for instance, when it concerns false facts relating to public health measures during a pandemic, or when it leads to civil disorder.Footnote 160
Another major regulatory innovation brought about by the DSA, which contributes to tackling digital populism’s challenges to liberal democracy, concerns the introduction of “procedural rights” for users in content moderation. Examples include out-of-court dispute mechanismsFootnote 161 and detailed rules for complaints and appeals before online platforms.Footnote 162 These mechanisms enhance procedural fairness and dialogue around content, and thus could support reducing the spread of radicalised, polarised content online by digital populists.
Notably, by combining a content moderation and transparency-enhancing approach, the DSA, the Strengthened Code of Practice and the Regulation on the Transparency and Targeting of Political Advertising (TTPAR)Footnote 163 take positive steps in enhancing transparency online. Through the various transparency reports to be published by the service providers under the DSA,Footnote 164 the dynamics of radicalisation, polarisation and misinformation may become clearer and, ultimately, easier to mitigate.Footnote 165 Ultimately, the attention paid to transparency in instruments such as the DSA, the TTPAR and the GDPR can break the veil of ignorance underlying the power dynamics of digital populism in the long term, through effective systems of oversight and removal.
The DSA’s content moderation duties have further important benefits: they will facilitate the identification of harmful content by expanding the range of entities involved in content moderation and by strengthening users’ procedural rights online. The DSA also indirectly targets election-related content by enhancing disclosure duties where it states that “A third category of risks concerns the actual or foreseeable negative effects on democratic processes, civic discourse and electoral processes, as well as public security.”Footnote 166 This aspect intersects with the fight against disinformation, but it also concerns the lack of transparency of online political advertising. Specifically, the DSA addresses online advertisingFootnote 167 with regard to both transparency and user-targeting activities.Footnote 168 These provisions are strengthened and complemented by the TTPAR, which, in accordance with the GDPR, reinforces protections against targeted advertising.Footnote 169
3. Additional regulations for online content in the field of political ads and deepfakes
The TTPAR complements the DSA provisions on user targeting and personal data protection discussed below. The scope of this latter Regulation is narrower compared to that of the DSA, insofar as it aims to ensure that users are adequately informed about sponsored political content. To this end, political advertisements must be clearly identified and labelled, and the political party or actor on whose behalf the content is promoted must be disclosed.Footnote 170 Moreover, Article 9 TTPAR imposes record-keeping obligations requiring the preservation of information relating to, inter alia, expenditure, the elections concerned, and the identity of sponsors.
As regards user targeting in political advertising, beyond the general rules established under the GDPR, the governance of online political ads relies on Articles 18 and 19 TTPAR. The use of personal data for targeting purposes is permitted only on the basis of the data subject’s consent, whereas the use of special categories of personal data within the meaning of Article 9 GDPR is prohibited, even where such data are not explicitly identified as sensitive. In addition, Article 19 TTPAR requires controllers engaged in political advertising to maintain records of the targeting techniques employed.
The constraints on user targeting and the transparency requirements laid down in the TTPAR may mitigate several problems associated with violations of electoral spending rules – through enhanced transparency – as well as with personal data protection, insofar as the GDPR rules are to be respected within the scope of the TTPAR. They may also address the opacity of sponsored content by informing users of the reasons they have been targeted and by clearly signalling the political nature of sponsored communications.
Finally, it is worth noting that the EU Artificial Intelligence ActFootnote 171 addresses the dissemination of deepfakes, another tool often used to spread propaganda and manipulated information.Footnote 172 Article 50 introduces specific transparency obligations aimed at limiting the spread of manipulated information online by requiring that AI-generated or altered content be clearly labelled as such, particularly where it may mislead individuals or affect public discourse. These obligations are especially relevant in contexts of political communication and electoral processes, as they seek to preserve users’ awareness and to safeguard the integrity of democratic debate – a measure that could help counter the sharing of disinformation and misinformation by digital populists.
4. Enhanced protections for the rule of law and traditional media outlets online
Alongside these measures, other EU frameworks that protect democratic values as components of the rule of law should be cited.Footnote 173 Through the constitutional vocabulary of the rule of law, EU institutions have attempted to address some of the challenges posed by digital populism. Via the European Media Freedom Act,Footnote 174 the EU has sought to restore the role of traditional media online by granting them certain privileges in content moderation processesFootnote 175 and by fostering collaboration among traditional media, social media platforms, and EU authorities.Footnote 176 This Regulation both strengthens the role of traditional media in social media content moderation and involves them in efforts to create a pluralistic, disinformation-free environment on social media platforms.
5. Fighting digital populism’s democratic challenges: the EU way
The EU regulatory strategy concentrating on online platforms, data protection, content moderation, and transparency is built on co-regulation mechanisms. They are deemed necessary to ensure that private entities, such as platforms, effectively cooperate with public regulators.Footnote 177 The co-regulatory approach established under EU regulations, which relies on close cooperation between public authorities and private actors (consider, for instance, the transparency duties for advertisers and online platforms under the DSA and the TTPAR), may appear well-suited to addressing the challenges posed by digital populism, insofar as these challenges stem from the structure of the digital sphere, which is dominated by a few major platforms. Co-regulation could slowly but progressively bring public values into an environment, such as that of online platforms, whereas self-regulation could only strengthen private values undisturbed.Footnote 178
Moreover, the procedural fairness turn of these frameworks, laying down several procedural rights for users as mechanisms of enforcement, could contribute towards fighting the challenges posed by digital populism: it has the advantage of fostering dialogue in the resolution of cases involving alleged illegal content and personal data protection violations, which would support the creation of a more nuanced and pluralistic online environment. Procedural rights were arguably seen as a tool to foster dialogic dynamics and fairness in the environment of online platforms.Footnote 179 In other words, the enhancement of procedural rights entails a reflexive mode of governanceFootnote 180 on the Internet that could ultimately facilitate exchanges of ideas, while strengthening the legitimacy of and the trust in the regulatory answer from the EU.Footnote 181 To give but one example, the EMFA provisions on “structured dialogue” among platforms, civil society, and media actors may offer useful practices for fostering access to a diverse range of viewpoints from independent media on VLOPs.Footnote 182
While moving in a positive direction towards addressing the systemic democratic challenges of digital populism identified above, these measures also present critical drawbacks that undermine their effectiveness vis-à-vis this phenomenon. As will be argued, the considered rules appear to be constructed in a piecemeal manner and without a holistic perspective on the online public sphereFootnote 183 and the relevant actors, processes and dynamics – in other words, the digital populism’s ecosystem. The following section unpacks those inefficiencies and limitations.
VI. Are existing EU regulatory measures missing the target?
In section IV, we identified several challenges of digital populism: disintermediation, polarisation, radicalisation, disinformation/misinformation and new propaganda tools based on personal data, often fostered by malicious actors (e.g., astroturfers, bots, micro-influencers). These strike at the core of liberal-democratic values. Yet the EU instruments examined in section V do not offer full relief against these risks owing to the design of these EU frameworks, compounded by contemporary enforcement challenges.
As shall be discussed, the focal point of these frameworks on content moderation, personal data protection and transparency seems to be premised on two assumptions. First, by better governing online platforms as duty bearers while enhancing procedural guarantees for online users, the digital environment will become safer and better aligned with public-oriented values by reflection. Second, the dominance of online platforms as gatekeepers of the Internet can be rebalanced through greater transparency, allowing regulators and the public to better scrutinise their conduct. The main advantage of this regulatory strategy is the clear attribution of accountability to online platforms and data controllers, which aims to improve their governance and oversight.
At the same time, these policies target only selected entities, while disregarding less overt practices and dynamics that support the diffusion of digital populist content. The focus of EU digital frameworks on selected entities (e.g., online platforms) and policies (e.g., transparency duties under the DSA), which shape the chosen enforcement structures (e.g., procedural rights under the GDPR) and regulatory model (i.e., co-regulation), addresses only some of the problematic actors, processes, and dynamics driving digital populism – that is, its ecosystem. Seen from another perspective, the lack of a careful analysis of the ecosystem of the digital environment, and, especially, its configuration in relation to digital populism, has produced partial regulatory responses that tackle only selected controversial actors and practices, introduced weak regulatory mechanisms, and ultimately compounded underenforcement of the EU digital toolkit.
1. Missing central actors and practices of digital populism
Frameworks such as the DSA, the Strengthened Code of Practice, the GDPR and the TTPAR fail to capture pivotal actors and processes behind digital populism, such as covert payments to micro-influencers and astroturfers, and coordination practices aimed at exponentially spreading populist agendas online.Footnote 184 These categories of entities and behaviours de facto operate in a grey zone that none of the considered instruments may easily govern. What is more, online platforms have financial incentives to support engagement with the content shared in their environment, and micro-influencers and astroturfers serve the economic model of online platforms by spreading sensational content and increasing their followers.Footnote 185 It is precisely through these less overt actors and practices that digital populists have more recently consolidated their propaganda through online platforms.Footnote 186 As a result, the existing EU rules do not grasp the more complex challenges related to the business model of online platforms, and the plurality of interests expressed therein by different members of the community. The loopholes left by EU rules with their selective focus on online platforms and specific types of conduct may be seen among the origins of and forces that facilitated digital populism.
The permissiveness towards several dynamics and entities that underpin digital populism emerges, for instance, when we consider the GDPR. The latter is a rights-based framework premised on the idea that the duties imposed on online platforms as processors and controllers correspond to rights for data subjects. This triangular relationship may seem straightforward; yet, it has limits in capturing the presence of different interests and practices driving digital populism.
To give but one example, let us consider two of the most prominent legal bases for lawful processing of personal data: consent and legitimate interests. Under consent, so long as the data subject has consented to the processing of their personal data, processors and controllers may lawfully process it,Footnote 187 while the legitimate interest legal basis provides ample leeway for processors to use personal data for economic and commercial reasons.Footnote 188 Both legal bases draw on a contractual understanding of data processing and assume a certain degree of equality among data subjects, processors and controllers. Yet, there is ample evidence that the GDPR reinforces the imbalances of the digital environment and does not facilitate users’ empowerment through its procedural governance, leaving the latter caught under the appearance of compliance by processors and controllers.Footnote 189 The position of dominance of online platforms and the actors that provide services thereon often leads users to passively accept the processing of their personal data,Footnote 190 overwhelmed by consent fatigue.Footnote 191 The dark side of the GDPR thus emerges: online entities participating in digital populism and interested in exploiting personal data produced on online platforms are emboldened, and exploitative practices driven by data online are enabled by the very rules included under the GDPR. The proposed Digital Omnibus Package’s objective to narrow the GDPR’s scopeFootnote 192 could only strengthen these dynamics and ultimately favour digital populism.
The missed opportunity to consider the complex ecosystem of digital populism further emerges when examining the limits of content moderation policies vis-à-vis digital populism.
2. The limited scope of EU policies to counter digital populism’s democratic challenges
Another critical limitation of the EU’s current measures lies in the insufficient attention paid to the systemic implications of digital populism and, thus, their limited scope compared to the complexity of this phenomenon. An example of the selective policy focus emerges when considering the attention given to content moderation and personal data protection as key areas to manage the challenges related to the digital environment. While digital populism clearly hinges upon online freedom of expression and the use of personal data, the effects of this phenomenon do not concern these two fundamental rights exclusively, but extend to issues such as disintermediation, radicalisation, and polarisation, among others.
The digital distortions of public discourse and sphere are not confined to the online environment but produce tangible effects in the analogue world. Populist narratives disseminated through social media systematically challenge the legitimacy of democratic actors, processes and the values underpinning them. In turn, the information spread on the Internet may contain details that could induce polarisation, radicalisation and, ultimately, division – undermining societal cohesiveness, public trust in institutions, and pluralism. By portraying institutions as proxies for a “corrupt elite,” digital populist leaders erode collective trust in democracy and in deliberative processes’ capacity to identify solutions to societal challenges.
As discussed in section IV, digital populist propaganda may undermine electoral rules governing campaign spending and the integrity of free and fair elections, as well as citizens’ rights to data protection. From the former perspective, the deployment of new digital propaganda tools can circumvent both electoral spending limits and transparency requirements applicable to political communication. These practices could also entail unlawful processing and exploitation of personal data, as the Cambridge Analytica scandal has demonstrated, or lead to significant distortions of electoral campaigns through the intervention of malicious actors, such as covertly hired micro-influencers, as demonstrated by the Romanian case.Footnote 193 In extreme cases, the combination of disinformation, algorithmic amplification, and opaque targeting practices may contribute to offline mobilisation and political violence, thereby affecting democratic processes beyond the digital sphere. This risk is illustrated by events such as the storming of the U.S. Capitol, where Congress was meeting to certify the results of the 2020 presidential election, and by the 2023 invasion of key federal institutions in Brazil, including the National Congress, the Supreme Federal Court and the Palácio do Planalto.
Moreover, although a direct causal link between digital populist propaganda and electoral outcomes has yet to be conclusively demonstrated, it may reasonably be suggested that the growing erosion of trust in institutions advanced by populist agendas encourages voters to support actors who seek to challenge or destabilise the status quo. Democratic values such as pluralism and diversity are likewise under strain: the radicalisation and polarisation associated with digital populism tend to marginalise alternative worldviews, fostering a “dictatorship of the will of the people” as interpreted by populist leaders. The implications of these dynamics are far-reaching.
On the one hand, diminished trust in institutions could lead to an increasing level of non-compliance with the law, thereby precipitating chaos and unrest. On the other hand, weakened pluralism and diversity would hinder protection for minorities, with ensuing forms of discrimination and inequalities. Above all, a major externality of digital populism has been the empowerment of populist leaders, who, once elected, can introduce reforms that potentially pursue agendas of “ungoverning,” which could lead to democratic backsliding.Footnote 194 Several studies have demonstrated that populism can manipulate and instrumentalise democratic values to rule “by cheating.”Footnote 195 The adverse impact of digital populism on constitutional orders based on liberal-democratic values thus emerges powerfully.
Digital populism accordingly weakens liberal democracy through destabilisation, leaving space for the emergence of authoritarian power and dynamics, being at odds with systems of democratic checks and balances. Against this account, it is eminently clear that regulatory responses that target online platforms from the angles of content moderation or personal data inevitably tackle only partially the challenges of digital populism.
3. Under-enforcement as a reality of content moderation policies
Thanks to the large audiences on online platforms, the spread of online content is rapid and harmful, and illegal or harmful content is difficult to deal with. In turn, the rapid, incremental distribution of populist narratives through the Internet creates systemic issues that undermine both online and offline democracy. Due to the significant number of users on the Internet and social platforms, and the speed at which information can travel online, ensuring the effective enforcement, for instance, of fact-checking and content moderation is laborious. It is a hard reality that existing EU digital rules do not effectively counter the widespread dissemination of information by populist leaders and their supporters, particularly in the form of disinformation. While they focus on patrolling content shared online, they devote less attention to the mechanisms of the exponential diffusion of harmful information used by digital populist actors.
For example, decisions to remove or flag information under the DSA should be made within very stringent timeframes to ensure that disinformation or harmful content does not circulate on the Internet. The DSA and the 2022 Code of Practice on Disinformation move in the right direction by imposing stricter duties, time limits and designating specific actors to flag illegal content. But swift enforcement may not be possible in most cases, and several are the risks linked to over-removal.Footnote 196 Hence, the under-enforcement or partial application of measures to prevent the dissemination of information created by digital populist leaders that may be incorrect, unlawful (such as hate speech), or damaging to individuals and the collective are part of the status quo.
4. Co-regulation as a weak regulatory mechanism in times of turbulent digital geopolitics
Co-regulation, based on the combination of legislation and self-regulation, is central to EU digital frameworks such as the GDPRFootnote 197 and the DSA.Footnote 198 As discussed in section V, it may slowly but progressively bring public values into an environment.Footnote 199 The deployment of co-regulation is posited on bona fide cooperation between private actors (such as online platforms) and regulators, and premised on the idea that digital platforms are the gatekeepers of the digital space. Accordingly, the latter should open the door to regulatory bodies to supervise the online environment and cooperate with public authorities to ensure good online governance.
However, the geopolitics of digital regulation and pressure from external actorsFootnote 200 are crucially undermining the effectiveness of this regulatory approach by weakening collaboration between public and private entities under existing EU rules. Tech players have proven reluctant to comply with EU rules, and are likely to be emboldened by the US Government’s efforts against EU regulation.Footnote 201
Let us consider, for example, the EMFA provisions on “structured dialogue” among platforms, civil society and media actors. These rules have yet to be tested, but one thing is certain: their effectiveness depends heavily on the willingness of digital platforms to implement new ways of operating their services.Footnote 202 The DSA’s co-regulation approach employs Codes of Conduct.Footnote 203 Yet the effectiveness of those codes in ensuring a safer online environment is diminished by their often-voluntary nature,Footnote 204 with online platforms not being consistently subject to the same standards. While there are consequences for non-compliance,Footnote 205 the question is whether those will be sufficient to guarantee the effectiveness of the DSA framework.
As a result, the foundations on which the analysed EU measures are built may, in fact, be rather shaky. If online platforms headquartered outside the EU resisted enforcement,Footnote 206 digital populism and its protagonists would be free to operate undisturbed.
In conclusion, the analysed regulatory initiatives and strategies contribute to the management of the systemic challenges arising from digital populism by focusing on selected actors, processes and dynamics of digital populism, mainly linked to abuses of free speech or violations of personal data protection on online platforms. Nonetheless, they do not comprehensively solve the mechanisms of the advancement of populist agendas and political propaganda. Indeed, digital populism is fuelled by a plurality of players and forces hosted by digital platforms, which produce damaging behaviours for public liberal-democratic values and are not fully governed under current EU frameworks. Only by engaging in a deeper analysis of digital populism’s actors, processes, and dynamics may it be possible to rethink effective regulation to counter this phenomenon. An ecosystem perspective allows us to do so.
VII. Digital populism: an ecosystem perspective
As discussed in the previous sections, digital populism is distinctive from offline populism due to four dynamics: the accumulation and use of a large volume of data by social media; the personalisation and targeting of users with digital populist content; the affinity bias of online echo chambers; and the broad reach and spread of content online. These practices underpin a series of systemic challenges for liberal-democratic values: disintermediation from epistemic communities, polarisation, radicalisation, disinformation and the modalities through which digital populism’s promotion operates.
Thus far, existing EU regulatory measures have primarily focused on selected protections, entities and activities carried out online, imposing a series of duties on digital platforms and data controllers, and granting users rights. The emphasis on the duties of selected actors, such as online platforms and advertisers, under a content moderation and data protection perspective, misses the broader context and implications of digital populism. Indeed, the ecosystem of digital populism is multifaceted and complex, advancing a range of varied interests. The unpacking of these forces and entities populating online platforms and feeding digital populism permits us to rethink the regulation of the responses to digital populism and the digital environment more broadly. A more holistic perspective on actors, processes and dynamics at play in the context of digital populism, that is, its ecosystem, is of the essence in identifying effective regulatory measures to counter this phenomenon.
Ecosystem thinking sheds light on the interactions among actors, processes and dynamics within organic networks,Footnote 207 like social media platforms. Actors and the ways in which they interact create processes leading to systemic dynamics, including forms of competition, predation, parasitism, adaptation and destruction of the whole system or selected members thereof.Footnote 208 Every member of the ecosystem has a role to play, whether major or minor. The study of the interplay among various actors and the processes that support interactions within the ecosystem helps shed light on the dynamics of organic systems, which can be corrected through regulation. Digital platforms act as yet another forum or organic network that impacts the public and political spheres, their actors and their interactions. The framing of online platforms as ecosystems is not novel;Footnote 209 the innovation introduced by this article is applying the ecosystem perspective to digital populism to rethink regulatory approaches in this area. The unpacking of the actors, processes and dynamics fuelling digital populism can further shed light on the limits of EU digital regulation discussed above, and favour more targeted measures that better cover the complexity of digital populism, address the current under-enforcement of the EU digital toolkit, and correct the partially effective co-regulation mechanisms underpinning EU digital regulation.
As visualised in Figure 1, the ecosystem of digital populism is rich and multilayered. Figure 1 captures some of the main multifaceted actors, processes and dynamics operating on online platforms. The figure shows that social media platforms play a central role in facilitating digital populism. They may be understood as the epicentre of the ecosystem of digital populism, insofar as they provide the environment for populist actors to spread their propaganda. Nonetheless, other actors should also be considered and studied as an integral part of digital populism’s ecosystem.
Digital populism’s ecosystem.
1. Actors
To begin with, social media platforms have become a venue for mutually beneficial relationships between digital populist actors, in the strict sense (i.e., politicians using online accounts), and a diverse range of fringe players. Through sponsorship, the online accounts of populist politicians can disseminate propaganda by engaging other users with economic interests, thus exploiting social media’s advertising model. As a result, the category of digital populist actors is multi-dimensional. In fact, it includes political accounts created to voice the ideas of selected politicians or parties, accounts that spread their propaganda against payment for advertisement or sponsorship services, and other less legitimate channels, such as astroturfers, micro-influencers, and bots designed to disseminate populist messaging.Footnote 210
A wide-ranging category of actors assisting the spread of digital populism is that of advertisers using social platforms. Advertisers, often taking the form of influencers,Footnote 211 sell products or services to the users of the platforms. The large number of followers cultivated by influencers makes those accounts attractive for digital populists to utilise to disseminate ideas. In so doing, digital populists and the accounts they sponsor support the engagement (and, thus, economic) goals of online platforms by sharing content and creating online mobilisation, while also benefitting from reaching a broader audience through the communication channels offered by social media platforms. Therefore, from an ecosystem perspective, digital populists, strictly speaking and the other multifaceted players acting on online platforms mutually strengthen one another.
Such forms of collaboration are a peculiar dynamic that EU measures such as the DSA, the Codes of Practice on Disinformation, the Strengthened Code, the GDPR and the TTPARFootnote 212 do not fully address. The latter instrument uses a similar toolkit compared to the DSA and requires advertisers to clearly label advertising as political.Footnote 213 Yet advertisers enjoy a broad discretion around labelling, which, in turn, risks under-enforcement.Footnote 214 EU guidelines on this matter have further requested that influencers identify the types of online content they share, distinguishing between advertisements and other content.Footnote 215 Nonetheless, such a distinction may not necessarily produce the desired effect of identifying and filtering populist material: the boundaries between “electoral” content and individual freedom of expression are blurred, above all when it is difficult to prove that micro-influencers have been paid to spread political content. Proving the existence of “sponsorship” relationships between politicians and online accounts is challenging. For instance, in the case of the Romanian presidential elections in 2024, the use of micro-influencers on TikTok was precisely used to circumvent the rules established by the DSA.Footnote 216 Higher transparency requirements would be necessary for sponsorship agreements, alongside the prohibition or at least regulation of such practices.
In addition to the digital populist actors, mention must be made of the “average users” of online platforms and their services. They may become targets of digital populist agendas through microtargeting. The GDPR may offer protection from the perspective of accessing personal data and information on how it is used by other actors on the platforms. The TTPAR introduces rules on transparency that require political targeting to be disclosed, so that users can revoke their consent for the targeting if they so desire.Footnote 217 However, average users may not be familiar with the GDPR rules and procedures and may decide not to exercise their personal data protection rights in any case. As a result, the GDPR’s protections may be underutilised in practice and offer limited relief against the abuses of digital populist actors.
This overview confirms that regulatory measures seeking to effectively counter digital populism should primarily consider the plurality of actors, as well as their interests, vulnerabilities and incentives, involved in exploiting the structures of digital platforms. This regulatory need becomes even more pressing when considering the processes underpinning the digital populism ecosystem.
2. Processes
Next, we should consider the means by which digital populist actors, broadly identified above, operate, that is, the processes underpinning the interactions within digital populism. In particular, there are three core processes.
First, digital populist actors target individual users with content. As mentioned, a strength of digital populism is the exploitation of the personalisation algorithms of online platforms and the ensuing affinity bias – dynamics that yet again are not fully addressed by the DSA and the Code of Practice on Disinformation.
Second, the messaging spread on online platforms contributes to influencing public opinion and voters’ behaviours.Footnote 218 The sharing of online content is another essential component of digital populism’s ecosystem: by spreading their propaganda, including information that may be manipulated or partially incorrect, digital populists aim to shape the worldviews of online users.
Third, both the previous processes can amplify the populist message by making it “viral,” that is, exponentially shared online. For content and posts to become “viral,” two elements seem to play a role: the type of content, with sensational information receiving more attention and engagement, and high volumes of individual users diffusing the content.Footnote 219 Hence, the content-sharing processes of online platforms are distinctive and not comparable to practices in the analogue world, such as hiring individuals to attend a rally in order to create the impression of broad public support. The sharing mechanism of social media and the malicious involvement of astroturfers, bots and (secretly) paid micro-influencers spreading content are thus crucial in the process of making content “viral.”
“Average” users, who have no specific political or monetary interests when using online platforms, risk becoming “digital populist” militants and beginning to support these narratives by spreading digital populist agendas online. This process should be singled out. Unlike the analogue world, the personalisation practices of online platforms trigger competition for gaining algorithmic engagement and visibility – that is, a clear advantage – on social media. The consistent targeting with populist material based on personalisation algorithms ultimately creates echo chambers that exclude the positions of political opponents. Average users can become trapped in populist propaganda bubbles. These dynamics inevitably impact the openness of the online environment and the ability to participate effectively in online democratic discourse.Footnote 220 Moreover, a crucial difference from the regulation of political activities in the offline world is that, in an offline context, those activities may be subject to greater scrutiny due to disclosure requirements.Footnote 221 These protections are partially missing under current EU digital rules.
For example, the GDPR’s protections do not seem to hold. As mentioned, the legal bases for data-processing of legitimate interest and consent offer social media platforms and accounts broad leeway to process personal data and thus target users based on their preferences and behaviours, thereby creating echo chambers that appear to form part of those platforms’ business models.Footnote 222 In parallel, EU institutions have sought to reduce the potential for content personalisation and targeting, by regulating, for instance, cookies.Footnote 223 Those safeguards are nonetheless not entirely effective, as they rely on privately driven consent mechanisms that, as extensively discussed in the literature, are not a strong foundation for greater control in the online environment.Footnote 224 The demonetisation of online advertisements linked to disinformation mentioned in both the 2022 Code of Disinformation and the TTPAR could progressively erode online platforms’ business model. Yet demonetisation is not envisaged for radicalising content, which tends to be part of the digital populist playbook.
Regulating online content or personal data alone will not redirect the business model or alter the engagement mechanisms of digital platforms, nor will it prevent their exploitation by populist actors. Accordingly, we submit that, in addition to content, other practices to target through regulation are precisely the processes of personalisation algorithms that create echo chambers, and the digital dissemination of content. In this context, the targeting activities, as well as the “viral sharing” practices and the economic incentives offered by social media platforms’ business model should be addressed. As a matter of fact, the nature of online content alone could not strengthen digital populism unless it was widely shared or went “viral.”
For instance, the phenomenon of echo chambers should be addressed through mechanisms to de-personalise content and ensure that all users are exposed to a variety of content. Regulatory measures should also aim to limit the ease with which content can be widely shared online through platforms’ mechanisms, thereby reducing its virality. In this respect, the covert use of micro-influencers, astroturfers and bots used to amplify messages should more clearly be the focus of regulatory initiatives.
Based on this discussion, at least four dynamics of digital populism’s ecosystem, in addition to the actors and processes analysed above, currently not covered by the EU regulatory frameworks, can be identified. They should be scrupulously considered by EU institutions intending to counter digital populism.
3. Dynamics
The first dynamic concerns the “synergy” between online platforms and digital populist actors, strictly speaking. As mentioned, digital populist politicians benefit from social media by exploiting their communication channels and engagement algorithms, thereby increasing their audience and facilitating the dissemination of their agenda. In parallel, thanks to the high engagement engendered by radicalised and polarised digital populist content, social media platforms increase their traffic and financial gains. Such a dynamic creates perverse incentives for cooperation between digital platforms and digital populist actors that should be broken down through regulation.
The second dynamic regards the cooperation among social media advertisers, influencers, the broader category of digital actors exploiting the economic incentives of online platforms, such as astroturfers, bots and micro-influencers, and digital populist actors, strictly understood. Also in this case, there are mutual benefits: the digital populist actor can further audience growth through the support of the advertisers and influencers; the advertisers and influencers, in turn, receive sponsorships from digital populist actors while increasing sales. This is another ecosystem dynamic that needs to be addressed through regulation if digital populism is to be countered effectively.
A third dynamic to consider is the significant influence on public opinion of digital populist content through the online sharing of viral content, which may be based on disinformation or designed to trigger anger and other more extreme emotional reactions. The increasing exposure of users to digital populist content, resulting from pre-selected personalisation and the difficulty of escaping populist echo chambers once engaged, may transform them into militant populists, that is, committed supporters of populist agendas. As a result, digital populists expand their public support and diffuse their ideas at exponential rates via online platforms. This dynamic stems directly from the business model of online platforms and the ease with which they can share content, enabling them to reach broad audiences. In turn, users may then become “trapped” in digital populist echo chambers that limit their exposure to pluralistic viewpoints.
A final dynamic concerns the operation of malicious actors, such as astroturfers or bots, to amplify and disseminate digital populist narratives widely. Those actors can also be instrumentalised by external entities seeking to destabilise liberal democracy from within.Footnote 225
The intricacy of digital populism’s ecosystem is now evident. Such an ecosystem is the result of a combination of economic and political factors that have facilitated a financially and economically driven way of doing politics, relying on the opacity and inequalities of the digital environment. The enriched understanding of digital populism, its actors, practices and dynamics emboldens EU regulators to rethink the scope and the enforcement mechanisms of EU digital regulation. The renewed perspective on the challenges posed by digital populism could prompt the adoption of initiatives and measures to address the underenforcement of the EU digital toolkit, as well as its historical regulatory stance based on (ineffective) co-regulation. The unveiled complexity should not signal the impossibility of regulating digital populism’s democratic challenges; rather, a shift in perspective from EU regulators, as advocated for by this article, is all that is needed to identify more complete and effective initiatives in this field.
Building on the above ecosystem analysis, the following section outlines a series of recommendations for policy objectives to pursue if digital populism is to be regulated more effectively.
VIII. Recommendations and regulatory proposals
Section VII has illustrated the ecosystem of digital populism by revealing its actors, processes and dynamics. The picture is complex, and the existing EU measures in the digital environment only partially address the challenges posed by this phenomenon. The introduction of regulatory measures to counter the democratic challenges posed by digital populism is essential to protect liberal-democratic values and the pillars of democratic societies.
This section outlines recommendations and regulatory proposals in the form of objectives for initiatives that could address precisely these threats. The goal is not to provide a full list of new, comprehensive policies or replace the existing EU measures; rather, we argue that pursuing the proposed policy objectives could complement and strengthen EU rules while facilitating the fight against digital populism. Moreover, in considering how to achieve these goals, and in light of the shortcomings of co-regulation, caution should be exercised when deciding which regulatory model to deploy. If co-regulation is to be chosen, the risk of non-compliance or under-enforcement must be managed. Some of these proposals may not fall fully within the EU competences,Footnote 226 and would therefore require forms of cooperation from the Member States.
A first proposal concerns the scope of regulatory measures that seek to effectively address digital populism. Their effectiveness is premised on a much broader scope ratione materiae and personae, which should comprehensively target the specific actors, processes, and dynamics that facilitate this phenomenon. Only by addressing the plurality of entities and interests pursued through online platforms and underpinning digital populism, may it be possible to break the current collaboration between political and financial incentives, making digital populism both evanescent and powerful.
Several actors are not captured by existing rules, notwithstanding their crucial role in emboldening digital populism. The list includes, among others, astroturfers, advertisers receiving micro-payments or non-official forms of sponsorship and bots.
Similarly, the processes supporting digital populism should be regulated. Rules should be adopted to monitor how content is presented and shared, while limiting the use of bots, astroturfers and secretly hired micro-influencers. True, the line between abuses and uses of these oversight rules is thin and could lead to unwarranted forms of censorship and monitoring. These provisions could be instrumentalised by incumbent political actors to defeat the opposition, for instance. At the same time, there is a clear need to strengthen public accountability for politicians who disseminate ideas and content that undermine liberal-democratic values. Such accountability can only be achieved by pursuing strategies that fight digital populism.
To ensure the bindingness of any regulatory measure, hard law should be preferred over soft law; for instance, introducing bans on abusive practices could empower a fight against the manipulation of public opinion through social media by digital populist actors. Similarly, content de-personalisation mechanisms should be introduced, with a view to fostering pluralism and ensuring exposure to diverse political viewpoints. The current opacity of some online practices of political actors has already engendered serious challenges for countries such as Romania, where elections were annulled in 2024 amid external influence over national politics and the spread of disinformation.Footnote 227
Regarding the dynamics of digital populism, the forms of cooperation among actors of digital populism, as well as their influence on the public digital sphere, should be targeted by EU frameworks. The identified dynamics are (a) the “synergy” between online platforms and digital populist actors, (b) the cooperation between social media advertisers, influencers and other atypical economically motivated users, such as micro-influencers and astroturfers, and digital populist actors, (c) the significant influence of digital populist actors over public opinion through the use of online harmful content that can often become viral, and (d) the very reliance of digital populist actors on malicious actors such as astroturfers and bots.
The response from the institution should concentrate on eradicating incentives for digital populist actors to engage with these various entities on social media, and vice versa. The business model of online platforms should be rethought and governed with a view to reducing, if not eliminating, the current technological incentives for perverse forms of “collaboration” on digital platforms that currently foster the position of digital populist entities.
This would include, for instance, the adoption of measures aimed at limiting the algorithmic engagement and personalisation used by social media as the basis of their business model, thereby enhancing pluralism and enabling users to “escape” echo chambers. Examples could include the introduction of mechanisms of de-personalisation of content, whereby users would be exposed to views and content that are classified as opposed or at least not aligned, or the implementation of rules on addictive design.Footnote 228 Similarly, the vulnerabilities of the “average users” who may not have the means to trigger specific enforcement mechanisms should be given a central importance. Protective measures should not disempower users, but should also educate them about the risks of information manipulation and digital populism more broadly.
A second recommendation regards the dominantly political dimension of digital populism: regulatory measures tackling this phenomenon should adapt the rules for offline public discourse to the digital environment to ensure the presence of accurate news and a plurality of viewpoints, above all, during electoral periods.
It is for democratic regulators to protect the foundations of democracy, including the guarantees of pluralism and access to diverse media. In this spirit, regulation should address the issue of non-transparent campaign financing practices, such as the use of bots, micro-influencers and astroturfers to increase the algorithmic visibility of populist actors’ messages. At the same time, regulatory frameworks should strengthen fact-checking practices during electoral periods and enhance the prominence of authoritative sources of information. Learning from recent political developments in the EU and beyond, where the role of online platforms was crucial in determining electoral outcomes, regulators should stimulate civic virtues around democratic participation and ensure that individuals engaging with the online world have sufficient knowledge to critically examine and reflect on the information they consume online.
An essential aim of those interventions should be to strengthen public trust in regulated, democratic institutions. This could be achieved by reinforcing the trustworthiness of institutions and regulators, while also spreading crucial information on the risks of eroding democracy by stealth through practices adopted by digital populists. From a competence perspective, initiatives in the field of accountability for politicians are likely to be achieved by a mix of EU and national rules.
Third, and consequently, oversight should be exercised over politicians and the agendas they spread online, directly or indirectly, which may serve as the engine of digital populism. A stronger public oversight would overcome the limits linked to the underenforcement and the (ineffective) co-regulatory mechanisms that are characteristic of EU digital rules.
An argument could be made that political actors should also be subject to heightened scrutiny on online platforms. For instance, the imposition of a duty of honesty and competence to politicians acting online towards their own constituents could be a measure in this direction. Similarly, political accounts and those directly or indirectly linked, either through paid sponsorship or as voluntary support, should be subject to a duty of truthfulness and integrity towards the public. Accordingly, the diffusion, by direct or indirect means, of online illegal content that is, for instance, polarising or radicalising should bring with it consequences for political actors who supported this practice. Public independent oversight should be exercised on online platforms, and sanctions should be introduced for political parties and candidates who engage in illegal conduct such as hate speech or violation of electoral rules on spending – for instance, through the reduction of public funding and reimbursements.Footnote 229 As for the previous objective, Member States may be better placed than the EU to pursue some of these policies.
In summary, the EU measures adopted, analysed in sections V and VI, give some visibility and redress to the challenges for liberal-democratic values entailed by digital populism, and create legal tools and institutional structures to deal with them. At the same time, it is only through a more holistic approach and a better understanding of the ecosystem of digital populism that negative impacts on liberal democracy could be prevented, and digital populism progressively reduced in its force and reach. The recommendations outlined in this piece are intended to open the policy debate and regulatory discussion on how to tackle the complexity of digital populism. In order to ensure the continued effectiveness of regulatory measures, it is necessary to further study the phenomenon and to update regulatory tools – particularly in light of gaps such as the lack of coverage of the secret hiring of micro-influencers under the TTPAR – as well as to guarantee effective enforcement of the regulatory framework and efficient cooperation between EU and national institutions.
IX. Conclusion
The article had a twofold objective: shedding light on digital populism and its ecosystem, and advancing critical reflections on existing EU measures and proposals on policy objectives for effective regulation of this phenomenon. To do so, the analysis began with an exploration of populism and its digital version, highlighting the distinctive features of the latter as well as its systemic challenges to liberal democracy. Those include radicalisation, polarisation, disintermediation, disinformation and the modalities through which digital populism’s promotion operates. Subsequently, the piece has reflected on the effectiveness of the recently adopted EU measures on digital platforms and their governance. The discussion revealed their partial effectiveness in addressing digital populism: the focus of these frameworks on selected actors (e.g. online platforms) and policies (e.g., content moderation), which shape the chosen enforcement structures (e.g., procedural rights) and regulatory techniques (i.e., co-regulation), tackles only some of the problematic dimensions driving digital populism.
The analysis then proceeded to unpack the ecosystem of digital populism, namely, its actors, processes and dynamics. The impression deriving from digital populism’s ecosystem is one of complexity and opacity, behind which failures of accountability and exploitation of the digital environment’s structures can be more easily hidden. The article has illustrated the ways in which the business model of those platforms, as well as the features of social media, including their personalisation algorithms and ability to easily share content, contribute towards emboldening digital populism by relying on a plurality of entities. While social media platforms remain the centrepiece of digital populism, various types of collaboration and synergies were identified, for instance, among online platforms, online accounts of populist politicians, and advertisers.
Based on the identified dynamics and drawbacks of existing EU measures concerning the digital environment and digital platforms, we have advanced a series of recommendations and proposals to regulators on policy objectives to pursue to tackle digital populism, adopting an ecosystem perspective.
First, regulatory measures should target more comprehensively the actors, processes and dynamics of the digital populism’s ecosystem. Second, regulatory measures should adapt the rules for offline public discourse to the digital environment to ensure the presence of accurate news and a plurality of viewpoints, above all, during electoral periods. Third, oversight should be exercised over politicians and the agendas they spread online, which may serve as the engine of digital populism. The recommended goals outlined in this piece are intended to open the policy debate and regulatory discussion on how to tackle the complexity of digital populism, without an aspiration of completeness. Yet we argue that the combination of initiatives in this direction would constitute a first promising step towards governing of digital populism, while reducing the underenforcement and weak regulatory mechanisms characteristic of the EU digital toolkit.
We conclude this article by inviting regulators and stakeholders to consider the ecosystem of digital populism as a theoretical underpinning to build and structure the strategy to counteract the challenges affecting online platforms and democracy. It is a matter of protecting our democracies and constitutional values, after all.
Financial support
This article is part of the Horizon project EXPRESS2 under the grant agreement No 101132426.
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