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This article was first published by Truthmeter.mk (North Macedonia), within the framework of Western Balkans Anti-Disinformation Project.

Fighting disinformation through legal sanctions is possible but risky. A much broader, comprehensive approach is needed, in which the institutional framework requires the involvement of the civil society sector and the harmonization of European and domestic regulations. This was shown by research among experts and stakeholders on the possibility of successfully combating all types of harmful information and manipulation through sanctions, including so-called FIMI

Author: Teofil Blazhevski

An analysis of several issues related to citizens’ opinions on the danger of disinformation, the channels through which it spreads, and who should address it and how, based on the latest research by Metamorphosis, can be summed up in several conclusions:

• Legally sanctioning disinformation, as many citizens believe, could be a dangerous approach, due to the potential for it to be misused against freedom of speech and end up in censorship.
• There are differing opinions on the need for a new national strategy exclusively focused on disinformation. While experts point to shortcomings and overlaps in the existing strategies and call for their active implementation with appropriate budgeting, officials from the Ministry of Digital Transformation say that “it is justified to consider” a new strategic document.
• Some experts and stakeholders recommend that addressing the problem of disinformation at an acceptable level that will not pose a threat to the democratic processes in the country can only be done through a coordinated, comprehensive institutional approach in which representatives of the civil society sector would be actively involved and could make a serious contribution. The need to implement European legislation at the national level, particularly in the field of media and the regulation of social networks, is also emphasized.
• Wider implementation of media literacy activities is recommended, including the dangers of artificial intelligence, as well as support for self-regulation in the media sphere, which is also recognized by the state.

Context

Some of the questions in Metamorphosis’ latest research* related to the dangers of disinformation and how and who should deal with it showed the following results:

The majority of respondents (67%) partially or fully agree that disinformation is very harmful and should be sanctioned by law.

A large majority (74%) of citizens believe that the Government should take measures to deal with disinformation.

Social media/networks (87%) rank first as the channel through which disinformation is spread.

Are the current strategic documents sufficient?

The state, through the executive branch, began activities to combat disinformation in 2019, continuing in 2021, but the last two main active documents are the National Security Strategy of the Republic of Macedonia 2024-2029, as well as the Cybersecurity Strategy 2025-2028.

In the first document, disinformation is placed under Hybrid Threats, specifically in the section Foreign malign impact (p. 12), and the approach to countering it is described in the section Counter Disinformation… (p. 30), where, among other things, it is stated:

“Establishment of a central government coordination body consisted of communicators from: the Office of the Prime Minister” and several other ministries…

This body should develop: effective partnership with other bodies (such as the Council for Ethics in the Media, the Union of Media Workers, etc.) and the civil sector in the direction of
joint definition of the problem with disinformation and the ways in which each actor should act in his department; helping and enabling the self-regulation of the media; promotion of media literacy; promotion of the principles of free, objective information through respect for journalistic standards and ethical codes and strengthening of professional journalism.

It is not possible to effectively combat disinformation without the active participation of all stakeholders in the media–the Strategy says.

An active and valid document is the Cybersecurity Strategy 2025-2028 with an Action Plan, where in addition to the general goal–creating an aware and resilient society, plans for the education of students in primary and secondary education are also listed, and the ICT Development Strategy:SMART/MK 2030, is also active, in which a small part mentions that “it is necessary to implement educational and promotional programs and content intended for the general population.”  However, is a national strategy needed exclusively for dealing with disinformation, given that in all three documents it is only a small part?

We posed this question to some experts and stakeholders, including the competent Ministry for Digital Transformation (MDT). The aim was to see whether citizens’ perception of a more proactive role for the state and legal sanctions is actually needed or whether another, more comprehensive strategic approach is missing.

MDT: Thinking about a comprehensive national document is justified

When asked whether the two strategies mentioned above are sufficient or whether a new one dedicated exclusively to disinformation is needed, the competent ministry (MDT) stated that existing documents recognize the problem, and especially emphasize the Cybersecurity Strategy, which also addresses the aspect of building a resilient society, which is a priority goal. Therefore, “…it can be concluded that the state already has a basic strategic framework that allows for the initiation of activities for prevention, education, and strengthening of social resilience to disinformation.” However, the authorities add:

“In order to ensure clearer institutional coordination, defined bearers, success indicators, timeframes and appropriate budgeting, we believe that it is justified to consider the development of a separate National document that will focus exclusively on dealing with disinformation. It could be: ” a National Strategy for Countering Disinformation, or “a specific National Action Plan, as a sub-document that will emerge from the existing strategies,” said MDT.

“This would enable a more detailed elaboration of measures, clearer institutional roles, stronger multi-sectoral coordination, integration of educational, media, and security policies, and harmonization with European standards and practices in combating disinformation,” the response states.

Experts see shortcomings in strategic documents

Snezhana Trpevska from the RESIS Institute, an expert on media policy, believes that there is no need for new strategies, at least in relation to disinformation as part of hybrid threats from outside, the so-called FIMI. She emphasizes that the problem is complex, and that analysts and researchers often make mistakes, the main one being that “the terms ‘disinformation’ and ‘fake news’ are used with the same meaning, as content or information that inaccurately represents reality.” Trpevska says about the indicated strategies:

Based on what the European Commission recommends, I think that our country already has a developed strategic approach to combat hybrid threats and FIMI. The two current strategies cover these forms of threats and require a coordinated approach. Given that in reality it is often difficult to distinguish these forms of threats and disinformation from other types (such as misinformation, fake news, rumors, etc.), the existing Security Strategy envisages a coordinated approach and recommends a partnership of government bodies with the civil sector and other actors.

Trpevska points out the need to deal with other harmful information as well:

“What our country needs, and which is not covered by the two aforementioned strategies, is a coordinated and strategic approach to dealing with various other harmful content that is spreading on social networks. This includes not only disinformation, but also hate speech, threats to physical safety, content harmful to minors, online stalking and other types of harmful content and threats to the safety of users,” says Trpevska (the full response can be read HERE).

Dragan Sekulovski, Executive Director of AJM, regarding the current strategic frameworks and the possible need for a new one, believes that the problem lies in the implementation, the language used, and the necessary cooperation with the civil society sector:

“In a democratic society, institutions are not the ones who should define the truth. They can help to a certain extent in the process of dealing with disinformation, but this should be in cooperation with the civil society sector. A national strategy would mean that the final decision rests with the institution that operates on the basis of respect for the law… A primary challenge in developing these strategies is balancing the need to combat harmful disinformation with the protection of fundamental human rights, such as freedom of expression and an independent press. To mitigate the risks of overstepping government power or censorship, the strategy should use precise language that delegates implementation to independent, accountable bodies. In addition, education should be introduced within the affected institutions to ensure that the above does not happen in the context of the risk,” Sekulovski says (the full answer can be read HERE).

Biljana Georgievska, Director of the Executive Office of the Council for Media Ethics in Macedonia (SEMM), notes that there is overlap in the two strategic documents and advocates for a unified approach, emphasizing the urgency and seriousness of the problem:

“The gravity of the problem of hybrid warfare and the vulnerability of our society require the broadest possible scope, a national front. In the (first – ed.) two documents you mentioned, regarding disinformation as a threat to democracy, there is overlap. Logic suggests that a single, well-coordinated approach, involving all stakeholders in partnership, would provide a more focused and efficient response. Finally, the experience of the past three decades shows that there have been plenty of documents, but their implementation has consistently fallen short,” says Georgievska, highlighting the need for a serious and comprehensive approach, “for the sake of building the resilience of the entire society.”

She adds that the main activities of the civil society sector must not be overlooked and should certainly be included. Although SEMM was invited and participated in several institutional events, it did not receive any specific information regarding activities under North Macedonia’s Security Strategy 2024-2029, which also foresees SEMM’s involvement:

“It would be irresponsible to continue to deal with the problem of disinformation by only a few non-governmental organizations, with modest capacities and uncertainty about their long-term survival,” Georgievska says. (The full response can be read HERE).

Sanctioning disinformation by law carries the risk of censorship

Regarding the question of whether it is possible to fight disinformation effectively by legally sanctioning it, Sekulovski from AJM emphasizes that it is possible, but that it carries a danger:

“It is possible to fight disinformation with legal sanctions, but this carries significant risks for freedom of speech. In such cases, the effect is not always positive, especially if judicial authorities are not prepared for this type of challenge. Most of the problems occur in the online space, on social platforms. If we start from this point, the risk of failure is much greater because we cannot exercise constant control over the internet,” says Sekulovski.

Marina Tuneva, Associate Professor at ICS and an expert in strategic communications, with extensive experience in self-regulation in this context (the balance between legal sanctions and preserving freedom of speech), emphasizes that the most effective solutions lie in transparency, but warns that caution is needed when seeking a balance:

“The most effective solutions in the world are not based on censorship, but on transparency. Reducing the reach of proven false content, marking manipulative posts, referring to verified sources and clear standards for political advertising are instruments that protect the public interest without stifling debate. A culture of accountability is also important here, for example, if a citizen has content removed, they must know why, have the right to appeal and not be left at the mercy or displeasure of a technological algorithm.”

She adds that “neither platforms nor the state should be the sole arbiters of truth.”

“Self-regulatory bodies, fact-checkers, media organizations and academia have an essential role in maintaining balance. This is especially important in polarized societies like ours, where citizens trust journalists and experts more than political institutions,” Tuneva states.

The Digital Services Act can help

If social networks are the main channel for disinformation transmission, the question arises whether this problem could be addressed successfully through the Digital Services Act (DSA) that should be adopted by the competent ministry. The MDT’s response to this question states, among other things:

MDT, in cooperation with the EU Delegation, prepared a project in the period September/October 2024 that will provide expert support for the harmonization of national legislation with the Digital Services Act and the European Media Freedom Act. The project envisages a fully transparent and inclusive procedure, analysis of good practices, as well as a significant focus on a realistic assessment of the impact of the regulation and possible solutions…

The kick-off meeting was held on November 21, and the project has a duration of 20 months and includes several components. We are awaiting the draft detailed work plan, which should more precisely define the timeframe for the results to be delivered – states the response from the Cabinet of Minister Stefan Andonovski.

Trpevska, in this context, clarifies what the EU Digital Services Act (DSA) means in relation to disinformation:

“The DSA also provides for the so-called Crisis Response Mechanism, in times of war, pandemic, elections, etc. With the DSA, the European Commission has the authority to require platforms to: rapidly remove harmful content and networks, strengthen content moderation, and other measures against coordinated disinformation campaigns. All of this means that the DSA does not prohibit “disinformation” as content, but creates systemic mechanisms of transparency, accountability, and oversight that can significantly limit its spread. In practice, this means that platforms must behave responsibly, reduce risks to democracy, and allow oversight of their algorithms and practices. “

She also clarifies what the harmonization of our legislation with European legislation under the DSA entails, which helps explain why the process of adopting the DSA is progressing slowly:

“In the process of harmonization with EU legislation, our country will soon need to incorporate the package of regulations related to the digital space, including the DSA. This includes, among other things, the appointment of a national coordinator for digital services.”

National Digital Services Coordinators with full legal powers are key to the implementation of the DSA, as they enable users in their country to submit reports of illegal content on platforms and are responsible for implementing the procedure for granting trusted flagger status at the national level. In most countries, the role of digital services coordinator is played by communications regulators or media regulators, so it is advisable to assign this role to one of these bodies in our country. Given that the jurisdiction of most large online platforms is located in Ireland, where the digital coordinator is Ireland’s media regulator, cooperation between regulatory bodies, i.e. digital services coordinators, through the European Regulators Group and the competent bodies of the European Commission is of crucial importance for the implementation of the DSA obligations,” says Trpevska.

The role of self-regulation in combating disinformation

The comprehensive approach that experts are talking about also includes self-regulation of the media as a way to deal with disinformation, and this has been foreseen by the state with one of the strategies (p. 30), explained above.

The current director of SEMM, Georgievska, says that this body has a proactive role:

“In the absence of a broad and networked front, SEMM carries out its own activities, depending on the capacity and support from donors, to promote media literacy, especially among young people in the country, but also to train journalists to recognize, not spread and expose disinformation through the media. Last year, we approached over 350 high school students and students in Skopje, Shtip, and Tetovo, to exchange experiences with young people about manipulative content, mainly online, but also about methods for recognizing and the importance of not spreading created texts, photos and videos whose aim is to create a false image in society about sensitive topics,” says Georgievska.

Marina Tuneva, who was also the long-time director of SEMM, agrees and emphasizes that self-regulation can play a very big role in tackling disinformation in traditional and online media:

“Self-regulation is the most democratic mechanism for protecting the public interest in the media, especially in the fight against disinformation. It works precisely because it does not come from the state, but from the professional community–journalists, editorial offices, editors. The essence of its role is that it creates standards and norms, and then provides a fair and independent process for their observance.”

In the context of disinformation, self-regulation should be not only a corrective, but also a proactive mechanism. This means that the media themselves should have clear internal editorial rules for online work, i.e. checking sources, handling content from social networks, transparency about ownership and interests. Moreover, standards should be developed for working with automated tools and artificial intelligence, because they are precisely the new vulnerability,” says Tuneva.

Media literacy, including its more comprehensive integration into education (see here, here, and here), was also among the experts’ recommendations.

Metamorphosis has been advocating for a comprehensive approach for years

The way to deal with disinformation resulting from foreign information manipulation and interference (FIMI), as well as building societal resilience, has been a focus of interest for years at the Metamorphosis Foundation. The results of most of the research conducted on this topic have been addressed both as initiatives, of which the DSA was accepted to be included in the Government Program for 2025, and as recommendations, not only to the executive authorities, but also to civil society, the media, the business community, etc.

The initiatives and recommendations come after numerous research and analyses, including research on citizens’ perceptions of disinformation in 2022 and 2023, while a similar study was conducted this year, which should be published soon.

One of Metamorphosis’s latest activities was the presentation of the report “Enablers and Incentives of Election-Related Foreign Information Manipulation and Interference in North Macedonia,”  which Metamorphosis promoted within the framework of the Media Literacy Days.

*Indago’s research on citizens’ perceptions of disinformation, for the needs of Metamorphosis, will be published in a few days.