Download "Platform regulation, disinformation and FIMI in Ukraine" 

It's now four  years since the beginning of the Russian war of agression against Ukraine. So how is Ukraine defending itself against disinformation and interference? The European Audiovisual Observatory, part of the Council of Europe in Strasbourg, has published a new legal report, Platform regulation, disinformation and FIMI in Ukraine, offering a comprehensive analysis of Ukraine’s evolving media landscape under the extraordinary pressures of war and digital transformation. This is an in-depth analysis of foreign information manipulation and interference (FIMI) in Ukraine and also marks the accession of Ukraine as a member state of the European Audiovisual Observatory in June 2025. The report is authored by Ukrainian experts Roman Horbyk, Tetiana Avdieieva, Dariia Opryshko, Oleksandr Monastyrskyi and Igor Rozkladaj.

At a time when information integrity, platform governance and media resilience are at the centre of policy debates across Europe, this report provides a timely, in-depth examination of how Ukraine’s media system has adapted to sustained FIMI, particularly in the context of Russia’s war of aggression.

A report anchored in Ukraine’s unique media trajectory

Chapter One, authored by Roman Horbyk, explores the structure and dynamics of Ukraine’s media sector, tracing its historical development from independence in 1991 through the Euromaidan period and into the wartime environment following the 2022 full-scale invasion. This chapter explains key concepts such as “mediatisation”, communication sovereignty and information sovereignty. The author also analyses how Ukraine’s media ecosystem has been transformed under military, economic and technological strains and highlights the challenges posed by infrastructure attacks, market disruption and the need to balance freedom of expression with national security.

Chapter Two, authored by Tetiana Avdieieva, provides a detailed analysis of Ukrainian media legislation, focusing on reforms introduced in recent years, including the Ukrainian Media Law (UML). It examines innovations such as the formal recognition of online media and platform regulation, the reform of the National Broadcasting Council, and the development of co-regulatory mechanisms. This chapter also reports on restrictions linked to the aggressor state, alignment with European audiovisual standards, and Ukraine’s commitments to implement major EU legislative instruments, including the European Media Freedom Act (EMFA) and Anti-SLAPP measures.

Addressing disinformation in wartime

Chapter Three, authored by Dariia Opryshko, analyses the legal and regulatory tools used to counter disinformation, with particular attention to Ukraine’s wartime legal framework. The author describes special measures adopted to respond to information threats, including sanctions, regulatory decisions and administrative actions. The chapter further explores Ukraine’s approach to core platform regulation and political advertising online, weighing up the degree of convergence with emerging EU standards and identifying both achievements and unresolved tensions.

Understanding FIMI as a systemic challenge

Chapter Four, by Oleksandr Monastyrskyi, turns specifically to FIMI, examining the main players in Ukraine, along with the narratives and techniques involved in hostile information operations. It examines how digital platforms are used and misused in the Ukrainian information environment, and how national authorities respond under the UML and related legislation. This chapter also considers the broader alignment of Ukraine’s regulatory framework with EU norms, underlining the country’s dual challenge: defending information space during war while preparing for long-term European integration.

Platform regulation in a European context

In Chapter Five Igor Rozkladaj offers a comprehensive overview of platform regulation in Ukraine, charting its legislative evolution and current challenges. It reviews the constitutional foundations and baseline legal framework applicable to online platforms. The author also zooms in on sector-specific laws on information, advertising, media and elections. This chapter discusses key draft laws, Ukraine’s obligations under the Association Agreement with the EU, and alignment requirements stemming from EU accession negotiations, notably the Digital Services Act (DSA), EMFA and other European regulatory instruments. It also reflects on relevant Council of Europe recommendations and legal opinions.

Insights for policymakers, regulators and researchers

Drawing on the expertise of leading Ukrainian scholars and legal specialists, this report delivers valuable insights for policymakers, regulators, media professionals and researchers across Europe. It sheds light on how a media system under existential threat navigates issues of FIMI, pluralism, state intervention, platform accountability and information security.

About the publication

Platform regulation: Disinformation and FIMI in Ukraine is edited by Maja Cappello, Sophie Valais and Diego de la Vega and authored by Tetiana Avdieieva, Roman Horbyk, Dariia Opryshko, Oleksandr Monastyrskyi and Igor Rozkladaj. It is published by the European Audiovisual Observatory (Council of Europe) as part of the IRIS series.