Report September 2025
Submitted
The Code of Conduct on Disinformation (CoCD) serves as a benchmark for evaluating DSA compliance, especially regarding articles 34 and 35. Disinformation poses a persistent systemic risk to electoral integrity, individual and public health, and civic discourse. With the conversion of the Code into a Code of Conduct under the DSA, the European Fact-Checking Standards Network (EFCSN) believes it is essential to monitor and evaluate how platform-signatories are implementing the Code’s measures. Although the submission of this report was not strictly required, the EFCSN has chosen to do so in recognition of the Code’s pivotal role in ensuring that Very Large Online Platforms and Search Engines (VLOPSEs) adopt the “reasonable, proportionate and effective mitigation measures” that are required.
The CoCD remains fit for purpose: it was crafted through an unprecedented consensus that included major platforms, the European Commission, civil society, academics, and fact-checkers, and it still represents the most comprehensive action plan available to platforms for fulfilling their obligations under the DSA. Yet, recent developments—such as platforms unsubscribing from key commitments—demonstrate the fragility of this progress (for details, see also the recent EFCSN report “The Moment of Truth for the Code of Conduct on Disinformation”). Emblematic of this trend is Google’s quiet announcement to kill the fact-checking snippet in search results in June 2025. To our knowledge, Google did not inform the Code of Conduct Permanent Task Force about it. This feature alone had enabled over 120 million fact-check impressions every six months in the EU, according to Google’s own reports, and its removal threatens to undermine one of the most successful anti-disinformation interventions deployed on a VLOPSE. Such retrenchment jeopardizes the relevance of the Code at the very moment when its implementation is most crucial.
To provide more prompt contextual information, the EFCSN prepared a survey and circulated it among verified members focused on agreements between fact-checkers and online services, integration of fact-checks and proper access to information. A total of 40 organisations based in 27 different countries in Europe shared their data and impressions. The analysis of the answers to the survey was combined with information of the work conducted by the EFCSN and reflected within this report.
About the EFCSN
The European Fact-Checking Standards Network (EFCSN) is the representative of independent fact-checking organisations operating in Europe. In comparison to the previous report, the EFCSN has added two more members to its network. Therefore, the EFCSN is currently formed by 62 organisations, 41 of which are based in EU member states and 21 in other Council of Europe countries and Kosovo. Together, the EFCSN member organisations cover most official languages in the EU.
Each one of them has committed to the highest ethical, methodological and transparency standards as outlined in the European Code of Standards for Independent Fact-Checking Organisations, and has agreed to be evaluated for compliance by two independent assessors and the EFCSN Governance Body. The commitment of verified members with independent and quality fact-checking activities as well as the belief that promoting standards and collaboration is key in the fight against disinformation.
Collaboration is not only promoted among verified members of the EFCSN but with other Signatories of the Code of Practice on Disinformation. The Empowerment of Fact-Checkers Sub group within the permanent task-force, chaired by the EFCSN, is one of the meeting points where we are in contact with other organisations and exchange relevant insights, including with representatives of VLOPs and VLOSEs. In addition, we evaluate reports submitted by major online services and make suggestions on actions under commitments on fact-checking that we hope lead to future improvements. Additionally, the EFCSN advocates for the integrity of information spaces and holds influential actors to account.
As the EFCSN submitted its last transparency report in March 2025, covering the reporting period July 1 to December 31, 2024, this report covers the period from January 1 to June 30, 2025.
The CoCD remains fit for purpose: it was crafted through an unprecedented consensus that included major platforms, the European Commission, civil society, academics, and fact-checkers, and it still represents the most comprehensive action plan available to platforms for fulfilling their obligations under the DSA. Yet, recent developments—such as platforms unsubscribing from key commitments—demonstrate the fragility of this progress (for details, see also the recent EFCSN report “The Moment of Truth for the Code of Conduct on Disinformation”). Emblematic of this trend is Google’s quiet announcement to kill the fact-checking snippet in search results in June 2025. To our knowledge, Google did not inform the Code of Conduct Permanent Task Force about it. This feature alone had enabled over 120 million fact-check impressions every six months in the EU, according to Google’s own reports, and its removal threatens to undermine one of the most successful anti-disinformation interventions deployed on a VLOPSE. Such retrenchment jeopardizes the relevance of the Code at the very moment when its implementation is most crucial.
To provide more prompt contextual information, the EFCSN prepared a survey and circulated it among verified members focused on agreements between fact-checkers and online services, integration of fact-checks and proper access to information. A total of 40 organisations based in 27 different countries in Europe shared their data and impressions. The analysis of the answers to the survey was combined with information of the work conducted by the EFCSN and reflected within this report.
About the EFCSN
The European Fact-Checking Standards Network (EFCSN) is the representative of independent fact-checking organisations operating in Europe. In comparison to the previous report, the EFCSN has added two more members to its network. Therefore, the EFCSN is currently formed by 62 organisations, 41 of which are based in EU member states and 21 in other Council of Europe countries and Kosovo. Together, the EFCSN member organisations cover most official languages in the EU.
Each one of them has committed to the highest ethical, methodological and transparency standards as outlined in the European Code of Standards for Independent Fact-Checking Organisations, and has agreed to be evaluated for compliance by two independent assessors and the EFCSN Governance Body. The commitment of verified members with independent and quality fact-checking activities as well as the belief that promoting standards and collaboration is key in the fight against disinformation.
Collaboration is not only promoted among verified members of the EFCSN but with other Signatories of the Code of Practice on Disinformation. The Empowerment of Fact-Checkers Sub group within the permanent task-force, chaired by the EFCSN, is one of the meeting points where we are in contact with other organisations and exchange relevant insights, including with representatives of VLOPs and VLOSEs. In addition, we evaluate reports submitted by major online services and make suggestions on actions under commitments on fact-checking that we hope lead to future improvements. Additionally, the EFCSN advocates for the integrity of information spaces and holds influential actors to account.
As the EFCSN submitted its last transparency report in March 2025, covering the reporting period July 1 to December 31, 2024, this report covers the period from January 1 to June 30, 2025.