Having regard to the urgent need to counter the spread of disinformation in the information environment, the Council established by the Minister of Foreign Affairs puts forward the following recommendations, resulting from joint findings of social groups, academic circles, the industry, and public administration represented by members of the Council.

Recommendations

1. Swift implementation of the European Union’s regulations concerning digital and information security, in particular the Digital Services Act and the Artificial Intelligence Act. 
2. Stricter criminal law regulations with respect to entities engaged in disinformation activities.
3. Adoption by the Council of Ministers of a national strategy to counter international disinformation, elaborated in cooperation with the civic sector.
4. Review of competences of public administration authorities to optimise state activities in the area of countering disinformation.
5. Establishment of mechanisms of efficient exchange of information regarding countering disinformation among public administration authorities.
6. Support for independent and pluralist media in order to promote reliable and credible communication and to increase public debate transparency.
7. Increasing the influence of government administration authorities on very large online platforms to protect their users from disinformation.
8. Increasing government administration’s support for civil society organisations engaged in countering disinformation.
9. Government administration taking measures to stimulate the establishment of Polish entities developing domestic technologies for countering disinformation.
10. Support by government administration authorities of initiatives to build resilience to disinformation among vulnerable social groups and of fact-checking initiatives.
11. Inclusion of critical thinking and media literacy classes in school curricula.
12. Public administration providing the public with prompt and clear information on disinformation incidents.
13. Cooperation with NATO, the EU, and other foreign partners in the area of countering international disinformation.

Detailed recommendations

Systemic solutions

1. Swift implementation of the European Union’s regulations concerning digital and information security.

The Council recommends that competent state authorities take urgent legislative action to implement all EU regulations affecting the ability to counter international disinformation, including Regulation (EU) 2022/2065, the Digital Services Act (DSA), and Regulation (EU) 2024/1689, the Artificial Intelligence Act, into the Polish legal system. In the Council’s view, a full implementation of these regulations will provide public authorities and civil society representatives with instruments which are essential in order to counteract manipulation in the infosphere more effectively, both at a national and EU levels.

2. Stricter criminal law regulations.

Considering that the Digital Services Act, mentioned in item 1, with regard to countering disinformation applies mostly to illegal content, and that nowadays a vast majority of disinformation content remains legal in the light of the Polish law despite the real and long-term social damage it causes, the Council recommends that the Interministerial Group carry out an analysis of the existing criminal law regulations to assess the possibility of stricter criminal law regulations with respect to entities engaged in disinformation activities, including those that target the image, security, and interests of the Republic of Poland and its citizens.

In the Council’s view, it is key that the potential legislative changes be devised with full respect for the freedom of speech and in such a way as not to reinforce the narrative on the alleged “censorship” of the public debate.

3. Adoption by the Council of Ministers of a national strategy to counter international disinformation.

The Council recommends that the Interministerial Group for Counteracting Foreign Information Interference and Manipulation, later referred to as the “Interministerial Group”, urgently take actions aimed at adopting a national strategy to counteract international disinformation.

The document should in particular: 

• identify main sources, mechanisms, and techniques of foreign disinformation and the potential social consequences of manipulation within the information environment;
• comprise a comprehensive catalogue of actions to be taken by the state and non-public entities which are necessary to counter disinformation and its consequences;
• include a recommendation on the advisability of establishing an independent organisational unit within the Chancellery of the Prime Minister, responsible for initiating and coordinating state activities in the area of countering manipulation of the information environment.

In the opinion of the Council, adopting the strategy would boost the efficiency and help better coordinate actions of the state and non-public entities in the area of countering international disinformation. 

4. Review of competences and resources of public authorities in terms of their effectiveness in counteracting disinformation and elaboration of a proposal of systemic solutions. 

Bearing in mind that public (government and local government) bodies and the entities of the broadly understood third sector (NGOs, higher education institutions, the expert community, the media, and the private sector) nowadays have significant competences, tools, and know-how to fight international disinformation, the Council recommends that the Interministerial Group review

• the organisational structure of public authorities tasked with countering international disinformation as well as
• the relevant competencies and resources at the disposal of the state and the non-governmental sector.

The above should aim at devising organisational, legal, and financial solutions to:

• harmonise the competencies of public institutions and the information flow between them and the third sector. In the Council’s opinion, it is of key for the Interministerial Group to present their stance on the advisability of establishing an independent organisational unit within the Chancellery of the Prime Minister, responsible for initiating and coordinating state activities in the area of counteracting disinformation, as referred to in item 2.
• rationally use resources held by third sector entities within the framework of state action as regards fighting international disinformation.

In addition, the Council recommends that the Interdepartmental Group take steps to establish a process for continuously modelling the state's resilience to disruption caused by disinformation and designate a public institution to manage this process.

5. Mechanisms of efficient exchange of information on countering disinformation.

The Council recommends that the Interministerial Group draw up a map of the competencies of public institutions in the field of countering international disinformation (organigram), present a proposal for an authority tasked with regularly updating the map and making it available to all public administration authorities (central and local government). In addition, the Council proposes that the Interministerial Group formulate recommendations for improving the flow of information between public institutions (by means of an ICT ecosystem, for example).

The above measures would help overcome the silo effect and improve the effectiveness of public institutions in counteracting hostile interventions in the information environment.

6. Supporting professional, independent, and pluralist media in order to promote reliable and credible message and increase public debate transparency.

Considering media one of key elements of the defence system against international disinformation, the Council recommends increasing financial support from public funds for independent and pluralist media—especially the professional ones—in the form of funds and grants. Such instruments should comprise grants for investigative journalists and independent reporter teams. The solutions adopted in recent years by other European countries (including Estonia and France) might serve as point of reference. In the Council’s opinion, the above will result in a more transparent public debate and will mitigate foreign disinformation’s impact on the public.

Very large online platforms

7. Increasing government administration influence on very large online platforms (VLOP) to protect their users from disinformation.

In the Council’s opinion, legal instruments are the most effective way for the government administration bodies to influence very large online platforms in this regard. To that effect, it is essential to incorporate the DSA into Polish legal order and to increase penalties on disinformation actors, as referred to in Recommendations no. 1 and 2.

It is also necessary to make the platforms effectively meet their commitments under the EU Code of Conduct on Disinformation, including eliminating their revenue from advertisement of misleading accounts and websites.

The Council recommends developing cooperation between public institutions, fact-checking organisations, online platforms, and media outlets based on transparency, including, in particular, sharing data necessary to analyse threats and respond to them. Such activities could be undertaken by an independent organisational unit responsible for initiating and coordinating state activities in the area of counteracting disinformation, as referred to in Recommendation no. 3.

State support for the third sector

8. Increased support for civil society organisations countering disinformation.

Recognising the activities of non-governmental organisations—including in the areas of prebunking, fact-checking, and monitoring disinformation—as one of the key elements of the system for countering international disinformation, the Council recommends that the state administration increase their support, including financial support. In order to precisely identify the areas and scope of necessary support, the Council recommends that the Interministerial Group prepare, in cooperation with representatives of the non-governmental sector, a report specifying the needs of these entities. The document should in particular identify the NGOs’ needs regarding the expansion of expert networks, technical infrastructure, and know-how.

The government institutions’ offer to cooperate and support should also be addressed to Polish entrepreneurs, professional organisations, local governments, and secondary schools and universities. The report should serve as starting point for the competent state institutions to take specific action, including the provision of appropriate funding.

At the same time, the Council encourages the central and local government authorities to delegate—to a greater extent than before—public tasks in the field of countering disinformation and building social resilience (e.g. training, educational activities, and neutralising the impact of disinformation) to the third sector entities, under agreements referred to in Article 19 of the Civil Protection and Civil Defense Act of 5 December 2024 (Journal of Laws 2024, item 1907).

9. Government administration’s measures to stimulate the establishment of Polish companies and non-governmental organisations developing domestic technologies for counteracting disinformation.

In order to achieve a technological breakthrough and develop a new generation of tools that will enable Poland to respond adequately to international disinformation, the Council recommends a significant increase in public funding to stimulate the creation and development of highly specialised domestic companies and non-governmental organisations developing suitable domestic technologies.

Building social resilience

10. Support for the building of resilience to disinformation in vulnerable social groups.

The Council recommends that competent government administration institutions adopt solutions favouring those NGOs which implement projects whose goal is to build resilience to disinformation among the most vulnerable social groups (especially seniors), in particular in terms of granting public funding. These solutions could be part of the national strategy to counter international disinformation referred to in Recommendation no. 3.

11. Developing society’s critical thinking skills and media literacy education.

The Council recommends that the competent government authorities take urgent measures towards including classes in critical thinking and disinformation spotting as well as in media literacy in the preschool through secondary school curricula. As the first step in that direction, the Interministerial Group should cooperate with representatives of the third sector to come up with tangible proposals in that regard.

At the same time, the Council finds it necessary that countering disinformation be included in the teacher and preschool instructor training programmes and that the state provide sufficient funds for that purpose.

Also, the Council recommends that competent public authorities work with the third sector on coherent prebunking campaigns (or programmes) and that prebunking be implemented in public institutions, schools, and media outlets.

12. Informing the society about disinformation campaigns and incidents.

For official communication to gain in credibility, competent public authorities in cooperation with reliable NGOs must inform the society fast and clear about the most dangerous disinformation campaigns and incidents. The Council recommends that the Interministerial Group draft a proposal for a clear-cut division of tasks among the public institutions in that regard, with sufficient funds earmarked for the public authorities and NGOs to carry out the said tasks. The Council stresses that the third sector organisations play a key role in getting official communication through to a wide range of recipients for whom more credibility often lies in disinformation narratives.

The Council emphasises that the rapidity of state response to disinformation is pivotal in building social resilience to manipulation in the infosphere; the designated actors should prime the society about disinformation incidents ahead of the often disinformative narratives transmitted through the social media.

International cooperation

13. Cooperation with foreign partners in the area of combatting disinformation.

The Council prioritises cooperation with the EU and NATO. Nonetheless, the scale of threats generated by foreign manipulation in the infosphere calls for the public institutions to remain open to balanced and diversified cooperation with other foreign partners, such as international organisations, domestic institutions in other states established to counter disinformation, and the NGOs.

Members of the Council for Resilience:

Tomasz Chłoń, MFA, Chair of the Council

Katarzyna Szaran, Deputy Chair of the Council

Anna Chipczyńska, Czulent Jewish Association

Paweł Czajkowski, Agora S.A.

Karolina Czwarno-Kos, Polish Confederation Lewiatan

Witold Drożdż, Polish Confederation Lewiatan

Andrzej Dulka, Polish Chamber of Information Technology and Telecommunications

Wojciech Dzięgiel, Casimir Pulaski Foundation

Agnieszka Jankowska, National Chamber of Commerce for Electronics and Telecommunications

Marcel Kiełtyka, Demagog Association

Maciej Kossowski, Digital Publishers Employers’ Association

Paweł Kotla, Temida Arts & Business Foundation

Krzysztof Malesa, Polish Confederation Lewiatan

Michał Marek, Center for Research on the Contemporary Security Environment (CBWŚB) Foundation

Arkadiusz Modrzejewski, University of Gdańsk

Justyna Olędzka, University of Białystok

Agnieszka Ostrowska, Centre for International Relations Foundation

Paweł Prus, Zamenhof Institute

Grzegorz Rzeczkowski, Łukasiewicz Research Network—PORT Polish Center for Technology Development

Anna Rzepa, Polish Academy of Sciences, Gdańsk Branch

Kamila Sierzputowska, Kazimierz Wielki University

Maksym Sijer, INFO OPS Poland Foundation

Martyna Wilk, SWPS University

Małgorzata Zakrzewska, Polish Confederation Lewiatan

Mariusz Żabiński, Institute of Socio-Political Technologies “Kybernetes”