The Internal-External Dimension of the EU’s International Digital Strategy in Three Acts

On 5 June 2025, the Fee and the HR/VP collectively launched the EU’s Worldwide Digital Technique (IDS). Endorsed by the Council on 20 November 2025, the doc displays the EU’s purpose to advertise and shield its digital pursuits, with a robust emphasis on supporting the EU’s tech business, enhancing cybersecurity, and decreasing dependences on third international locations. Logically, inner threats arising from Overseas Data Manipulation and Interference (FIMI) are usually not addressed; as a substitute, some consideration is dedicated to their exterior facets. In coverage phrases, the IDS calls EU establishments to assist the alignment of EU accession international locations with Regulation (EU) 2022/2025 (Digital Companies Act, hereafter ‘DSA’) and Regulation (EU) 2022/1925 (Digital Markets Act; see the Annex to the Joint Communication right here). Fairly tellingly, the phrase ‘disinformation’ seems solely as soon as in the complete doc.

This publish discusses three latest developments suggesting that the doc’s modest method to the extraordinary dangers arising from the enlargement of the American ‘Digital Empire’ (to borrow Anu Bradford’s felicitous terminology) shouldn’t be totally aligned with actuality. Particularly, it’s argued that the present geopolitical state of affairs – the place the EU’s ‘greatest ally’ interferes with its democratic processes and seeks to overturn its digital laws – makes it needed to precise readiness to make use of the prevailing exterior motion instruments to guard the EU’s digital acquis and the worth decisions mirrored therein. In contrast to extra ‘conventional’ cases of EU exterior motion, this proposition is superior not simply as a matter of coherence however as an existential name the defend the effectiveness of the EU’s authorized order.  

1.     First Act: the US Nationwide Safety Technique

The place to begin is the latest launch of the US Nationwide Safety Technique (NSS), a 33-page doc outlining the worldview and priorities of the Trump II administration. A lot has been stated about this doc’s implications for the EU’s world agenda, given its intensive listing of regarding overseas coverage priorities. A very hanging ingredient is the US dedication to ‘restor[e] Europe’s civilizational self-confidence and Western id’. The NSS describes Europe as a continent within the technique of ‘civilizational erasure’, criticising ‘actions of the European Union and different transnational our bodies’ (i.e., the Council of Europe) as ‘undermin[ing] political liberty and sovereignty’, with migration insurance policies that ‘are remodeling the continent and creating strife, censorship of free speech and suppression of political opposition’. Tackling these issues would require American diplomacy to:

‘get up for real democracy, freedom of expression, and unapologetic celebrations of European nations’ particular person character and historical past America encourages its political allies in Europe to advertise this revival of spirit, and the rising affect of patriotic European events certainly offers trigger for nice optimism.’

As has been famous (see right here and right here), this coverage prescription basically advocates for regime change throughout EU Member States. Arguably for the primary time since WWII, the US is formalising an indiscriminate criticism of ‘Europe’ as a ‘area’ missing ‘real democracy’, notably as a consequence of an alleged failure to guard lack of safety of the liberty of expression (for a extra nuanced view on this alleged deficiency, see right here). Thus, the NSS commits to intervening within the electoral processes of each the EU and its Member States. On this respect, the NSS seems extra principled towards Europe than towards different areas, which it approaches in purely transactional phrases. One ought to, nonetheless, not lose sight of the apparent financial pursuits behind this coverage assertion, as mirrored in makes an attempt to stress the EU to decontrol its digital sphere, with the aim – utilizing the NSS’ euphemistic phrases – of ‘[o]pening European markets to U.S. items and companies and guaranteeing truthful therapy of U.S. staff and enterprise’.

2.     Second Act: Fee’s Advantageous towards X

At this level, a second growth (curiously introduced on the identical date because the NSS) comes into play: the Fee’s issuance of a €120 million towards X for breaching its transparency obligations beneath the Digital Companies Act (‘DSA’). That is the primary non-compliance determination beneath this Regulation. Though formally concluding a two-year inquiry into X’s verification system, advert repository mechanism, and restrictions on information entry for researchers, the choice doesn’t finish the Fee’s scrutiny, because it types a part of a broader, ongoing investigation into X’s systemic threat administration and content-moderation practices.

Lengthy gone are the times when this was EU inner market enforcement as typical. Leaving apart X’s symbolic gesture of disabling a Fee promoting account, in addition to X’s CEO’s barbs towards the EU following the choice, it’s to be anticipated that the US (together with a few of its tech giants) will redouble stress on the EU to dismantle at the least key components of, inter alia, the DSA. In the meanwhile, and to at least one’s aid, such a response doesn’t appear to be a part of the Fee’s ‘digital omnibus’ simplification agenda.

On this creator’s view, resisting the US pull is as existential to the EU as saving the Euro was within the early 2010s. Bending to the US agenda would betray three core foundations of EU ‘internal-external’ policymaking within the digital sphere. First, and opposite to the guarantees of the IDS, it could abandon the EU’s most vital affect instrument in a key subject, specifically its skill to ‘regulate the worldwide digital economic system in ways in which the US and China are usually not in a position to do’ (Bradford, p. 340). Second, it could totally upset the stability set by the EU legislator between the liberty of expression and the intense dangers arising from the use and abuse of social media in a democratic society. Third, and particularly concerning content material moderation, it could redistribute the DSA-established allocation of the social prices of content material moderation amongst people, suppliers of digital companies and public authorities (Husovec, p. 200), leaving EU residents on the mercy of service suppliers.  

At this juncture, one should recall the apparent proposition that the DSA is the product of the EU’s authentic law-making course of (and certainly stays a lot according to residents’ perceptions about such dangers; as mirrored within the lastavailable Eurobarometer). The DSA is sort of deferential towards Member States’ decisions concerning the definition of hate speech, whereas on the identical time calling for the appliance of the Constitution of Basic Rights within the relations between residents and companies (right here vital questions stay open, such because the scope of the DSA’s attribution of jurisdiction to the CJEU to find out ‘the outer limits of what’s ‘legitimately’ unlawful content material on the nationwide stage’ primarily based on Article 3 thereof (Husovec, p. 215 and Novović, pp. 43-46).

The transatlantic divide concerning the boundaries of the liberty of expression has much less to do with democratic decision-making processes than with historical past and constitutional tradition; on this respect, it’s notably illustrative that Meta’s Oversight Board has utilized a surrogate for the ECtHR’s ‘margin of appreciation’ doctrine to the evaluation of sure content material removing selections originating from Europe and the US, reaching seemingly contradictory outcomes.

3.     Third Act: The European Democracy Protect

The ‘external-internal’ dimension of the EU’s digital agenda can also be mirrored within the third ‘act’ commented right here: the EU’s launch of the European Democracy Protect (EDS), the most recent flagship initiative designed to guard and strengthen democracy throughout the Union. Launched on 12 November along with the EU Technique for Civil Society, it goals to ‘enhance [the EU’s] capability to counter data manipulation and disinformation and strengthen our resilience by a whole-of-society method’.

The EDS brings collectively regulatory measures, monitoring mechanisms, and assist instruments for civil society and impartial media. Its core thought is that democratic resilience within the EU can now not be assured by institutional safeguards alone; it requires coordinated safety of the informational house, broader societal engagement, and sustained reinforcement of the situations through which democratic participation can flourish. Particular measures to this finish embody the creation of a brand new European Middle for Democratic Resilience, which can pool EU and Member State experience and sources by linking current networks and constructions such because the Speedy Alert System run by the EEAS. The EDS may even reinforce the work of the European Cooperation Community on Elections and replace the Digital Companies Act Elections Toolkit, and additional assist civil society organizations.

The EDS displays a robust sense of urgency in a world the place ‘[a]uthoritarian regimes see democracies as a menace and deploy more and more aggressive techniques’ (Joint Communication by the Fee and the Excessive Consultant). This zeitgeist is barely strengthened by the publication of the NSS. Democratic erosion is a hybrid, transnational phenomenon formed by FIMI and disinformation, and financial pressures on journalism. Each phenomena have a number of inner and exterior sources, components and actors, which collectively – collectively and chaotically, like in one among Bruegel the Elder’s work – work to tear down the edificie of European democracy.

When positioned on this context, it’s tempting to dismiss the EDS, as one MEP has finished, as a ‘European neighbourhood watch group chat’. Specifically, the doc lacks a single ‘spectacular’ measure that matches the gravity of the menace posed by FIMI, together with now from the EU’s ‘greatest ally’.

It have to be famous, nonetheless, that the Fee’s proposal adequately mirrors the aims initially set for this extensively supported initiative: to ‘reinforc[e] scenario consciousness and assist response capability’, to ‘energy[en] democratic establishments, free and truthful elections and free and impartial media’, and to ‘boos[t] societal resilience and residents’ engagement’. Specifically, the creation of the European Centre for Democratic Resilience was a much-needed measure to streamline efforts to counter FIMI by interoperable detection strategies whereas avoiding duplicating current constructions.  If one is trying to find spectacular measures, consideration ought to be directed elsewhere – specifically in direction of enforcement mechanisms which, as defined above with respect to the DSA, have simply begun to be utilized.

This isn’t to say that the Fee’s proposal is with out flaws. As argued right here, the EDS’s essential leverage ought to be monetary whether it is to match the gargantuan process of underpinning the European democracy edifice by adequately supporting civil society efforts to counter FIMI/disinformation and to maintain impartial journalism. On this regard, the EDS pledges a ‘vital enhance’ in assist for civil society organisations and media, but it refers solely to the Fee’s proposal for the brand new MFF to allocate €9 billion foreseen ‘for the AgoraEU programme alone’, whereas promising extra measures to ‘facilitate entry to completely different funding sources’. This still-hypothetical monetary dedication – comprehensible given the timing of the proposal – makes it tough, at this stage, to establish whether or not the Fee will be capable to muster the sources needed to fulfill its said aims.

4.     Trying Ahead: Defending the Effectiveness of the EU’s Authorized Order

Returning now to the place to begin – the IDS – it ought to now be clear that developments mentioned above, and notably the discharge of the NSS, entrench the worldwide dimension of EU digital devices that had been initially adopted for ‘inner’ market regulation functions. This could speed up the ‘re-bordering’ processes at the moment expertise by the EU and its Member States (Petti, pp. 1-38, notably at 5).

In coverage phrases, this pertains to the safety of the EU’s strategic autonomy and ‘technological sovereignty’. In authorized phrases, efficiently tackling these challenges is actually a matter of coherence in EU exterior motion, whether or not one defines this time period in ‘damaging’ or ‘optimistic’ phrases (specifically, as requiring related actors in EU exterior relations both to keep away from ‘contradict[ing] one another’ or to ‘complement and reinforce one another’ (Estrada Cañamares, p. 252). Extra decisively, the menace is existential to the EU’s authorized order, because it issues the effectiveness of its regulation of the digital house, setting a stability between the liberty of expression and the safety of different authentic societal pursuits. In different phrases, and borrowing from Azoulai’s terminology, the present scenario not solely entails the ‘development’ of the EU ‘as a reputable and efficient actor’, however reasonably the very effectiveness of the EU ‘as a substantive order’ (Azoulai, p. 33). This strikes the dialogue from ‘mere’ exterior projection phrases to authorized resilience.

Towards this backdrop, it’s submitted that extra EU exterior motion is required to defend the core facets of the EU’s inner digital agenda, in parallel with the enforcement of related market devices. This contains an express expression on the highest political stage of readiness to make use of ‘exhausting’ coverage devices to guard that agenda. On this respect, the anti-coercion mechanism beneath Regulation 2023/2675 (with its distinctive decision-making process that so completely blends the safety of internal-external pursuits) stands out as notably enough. To recall, Article 2(1) of the Regulation situations the appliance of that mechanism to a discovering {that a} third nation ‘applies or threatens to use’ financial coercion. Such coercion is outlined as ‘a third-country measure affecting commerce or funding with a view to forestall or acquire the cessation, modification or adoption of a specific act by the Union or a Member State, thereby interfering within the authentic sovereign decisions of the Union or a Member State.’

As has been argued elsewhere, ‘this new type of energy [applied by the US Administration and its tech giants] necessitates the repurposing of mechanisms –from sanctions to overseas interference measures – or adopting complementary devices, akin to anti-coercion instruments particularly designed to sort out these threats’, given the ‘promiscuous merger between the US administration and its financial champions and political donors’. Admittedly, the NSS doesn’t formulate any particular menace (financial or in any other case) in case the US ‘expectations’ are usually not met. Nonetheless, that risk is now not distant or summary. With its concentrate on supporting the EU’s tech business and cybersecurity, the IDS doesn’t deal with this tough actuality and should subsequently be complemented by different means.

Dr. Asier Garrido-Muñoz is a senior Lecturer in Worldwide and EU Regulation (The Hague College of Utilized Sciences). This publish was ready as a part of the analysis undertaking PID2022-140194NB-100 (MCIN/AEI/10.13039/1100011033/FEDER, UE) and is a part of the actions of the Jean Monnet Module ‘EULaw Dinsinformation’ (2022-2025).