Policy recommendations on civic accountability mechanisms

Purpose and scope

This deliverable presents the final policy recommendations of the DIACOMET project, an EU funded research initiative examining civic accountability and dialogic communication in digital public spheres. The recommendations are grounded in extensive cross-country empirical research and are intended to support EU and national policymakers, regulators, media organisations, digital platforms, civil society actors, and educators in strengthening democratic communication, transparency, participation, and trust.

This Executive Summary synthesises DIACOMET’s core findings, outlines the main policy challenges, and presents headline recommendations at the EU and national levels. It also highlights DIACOMET’s policy-relevant outputs as practical instruments for implementation.

Key policy problem

DIACOMET’s research shows that democratic public communication across Europe is increasingly undermined by structural and cumulative dynamics rather than by isolated legal violations. Platformisation, algorithmic governance, the economic fragility of journalism, and political polarisation interact to produce participation-chilling effects, accountability gaps, and declining trust. Many of the most consequential harms, such as harassment-driven self censorship, the marginalisation of low-visibility voices, opaque algorithmic content ranking on social media platforms, and lawful-but-harmful content moderation practices, are not sufficiently addressed by existing regulatory frameworks alone.

These challenges are particularly pronounced in smaller European countries, where media systems often face specific economic constraints, language barriers, and heightened dependence on regulatory and public funding frameworks. At the same time, such contexts may also offer greater institutional flexibility and policy innovation, enabling rapid and
effective responses.

Evidence base

The recommendations are informed by a mixed-methods research design combining analysis of 429 ethical codes and normative guidelines for public communication, 87 focus groups involving more than 500 participants from diverse professional and social backgrounds, a three-round Delphi study with over 175 experts in media, education, technology, and policymaking, Q-sorting exercises capturing normative orientations and ethical priorities, and comparative analysis across eight European countries: Austria, Estonia, Finland, Hungary, Lithuania, the Netherlands, Slovenia, and Switzerland. These findings are complemented by EU-level policy analysis.

Key policy directions

Based on this evidence base, DIACOMET identifies five cross-cutting policy directions: (1) strengthening civic resilience and communication security; (2) improving transparency in public communication; (3) expanding inclusive civic participation in policymaking processes; (4) ensuring access to public dialogue for marginalised and low-visibility groups; and (5) fostering constructive engagement between media professionals and the public.

These directions guide the formulation of EU-level and national policy recommendations across four policy domains: data privacy and surveillance; information and content governance; artificial intelligence and algorithms; and markets, pluralism, and competition.

EU-level recommendations

At the EU level, DIACOMET recommends integrating participation-related harms into DSA systemic risk governance, strengthening privacy-by-design and protection against online harassment, safeguarding journalism and public-interest media through EMFA implementation and stable funding, expanding media literacy to include media regulation and digital governance literacy, ensuring civic contestability, auditability, and participatory oversight of AI-driven communication systems, and aligning competition and media policy instruments to protect pluralism and due prominence.

National-level implementation implications

National governments, regulators, and other policy stakeholders play a crucial role in translating EU frameworks into effective practice. DIACOMET’s recommendations, therefore, call for improved accessibility and usability of accountability and redress mechanisms, stronger support for public-interest media and community-based dialogue initiatives, greater investment in media, digital regulation, and AI literacy, and the piloting of inclusive accountability infrastructures adapted to national contexts, including through the Inclusive Accountability Toolbox.

Hence, a collection of country reports translates the overarching policy recommendations to the level of the countries involved in the DIACOMET project and contextualises them in light of the prevailing conditions within each national media system.

DIACOMET’s policy-relevant outputs

DIACOMET contributes a set of concrete policy instruments to support implementation. These include the Principles for Dialogue-Supportive Communication (PDC) as an operational ethical framework and accountability benchmark; the Inclusive Accountability Toolbox, conceived as a prototype of a civic accountability mechanism bridging regulation
and lived experience; the “Dialogue Lab” as a training and implementation tool for ethical governance; the Discussion Forum as a dialogic and participatory governance infrastructure; and the European NGO Network as a coordination and support mechanism.

Together, these instruments enable policymakers and stakeholders to complement regulation with inclusive, dialogic, and learning-oriented approaches to democratic communication.