Dear free knowledge friends,
Welcome to the end of 2025! I want to share a recap of what our Advocacy
Network has collectively accomplished this year.
As a reminder: At the start of the year (Feb!), members self-selected into
three working groups: policy positions; copyright; developing common
language. A round of virtual applause đź‘Ź to the deserving @Catalina Frigerio
<catalina.frigerio(a)wikimediachile.cl> (WM Chile) and @Olushola Olaniyan
<olaniyanshola15(a)gmail.com> (WM UG Nigeria) for their voluntary leadership
of two of them. We met quarterly
<https://meta.wikimedia.org/wiki/Wikimedia_Foundation/Legal/Global_Advocacy/…>
(see our notes
<https://etherpad.wikimedia.org/p/Agenda_%26_Notes,_Global_Advocacy_Conversa…>)
to share updates about the working group, learn about strategic litigation
work in the movement, as well as from WM Brazil's excellent copyright
campaign.
This was a pilot, a new way of working together. It didn't work perfectly,
which gives us plenty to build on in 2026. But it was still very useful!
Here's what we've done...
___
(1) POLICY POSITION PRIMERS
*Lead:* WMF
*Purpose: *This group will develop 3-5 pagers on Wikimedia's core policy
priorities, including why these topics matter for our movement, talking
points, examples of advocacy work on the topic, and further reading
resources. 🫡
*Outcomes:*
Four primers have been published and added to the "resources" section
<https://meta.wikimedia.org/wiki/Wikimedia_Foundation/Legal/Global_Advocacy/…>of
the Global Advocacy Meta-Wiki page as well as in our shared category on
Commons
<https://commons.wikimedia.org/wiki/Category:Free_Knowledge_Advocacy>.
They cover: why this policy issue is relevant for the Wikimedia movement,
Wikimedia's general position on the topic, core talking points, and further
reading material to understand the issue.
1. Intermediary Liability
<https://commons.wikimedia.org/wiki/File:WMF%20Policy%20Position%20Primer%20…>
2. Privacy, Anti-surveillance and User Data Requests
<https://commons.wikimedia.org/wiki/File:WMF_Policy_Position_Primer_Surveill…>
3. Information Integrity
<https://commons.wikimedia.org/wiki/File:WMF%20Policy%20Position%20Primer%20…>
4. Human Rights
<https://commons.wikimedia.org/wiki/File:WMF%20Policy%20Position%20Primer%20…>
5. Template
<https://commons.wikimedia.org/wiki/File:Policy%20Position%20Primer%20Templa…>to
create your own policy position
*Impact*
They've already helped @MarĂlia Rocha <marilia.rocha(a)wmnobrasil.org> (WM
Brazil 🇧🇷) share our unique approach to information integrity at one of
the three largest public universities in Brazil, and @Olushola Olaniyan
<olaniyanshola15(a)gmail.com> (WM UG Nigeria 🇳🇬) elevate our call for
multistakeholder internet governance on stage at IGF Nigeria.
The empty template was used during our Wikimania day zero event
<https://wikimania.wikimedia.org/wiki/2025:Wikimania/Day_Zero_Advocacy_Works…>
(before I got any of you sick!) in an activity that the copyright working
group organized. Teamwork 🤝!
(2) COPYRIGHT WORKING GROUP
*Lead:* Shola
*Purpose: *This group will work on a plan to raise awareness about how
Copyright rules impact Wikimedians' work across projects, while also
identifying specific legislation to push for/against at the national level.
*Outcomes*:
- This group faced a challenge that we all know well, especially with a
topic that interests so many: it can capture many people's interest but
lead to very little meaningful engagement from every single one of them.
- Co-organized and helped facilitate the Day Zero Copyright & AI workshop
<https://wikimania.wikimedia.org/wiki/2025:Wikimania/Day_Zero_Advocacy_Works…>
at
Wikimania.
- The group was able to identify areas of interest but did not make any
progress on them.
- Advocacy for shorter copyright terms.
- Exploring alternative copyright frameworks, such as Non-Commons
(NC) content for Wikimedia Commons.
- Collaboration on academic research into the history of Wikimedia
Commons.
- Promoting broader understanding and use of Creative Commons
licences.
- Investigating the scope of Freedom of Information (FOI) beyond
copyright.
- Leading conversations on Freedom of Panorama (FoP) restrictions and
appropriate advocacy models.
*Impact*
The day zero workshop produced a first set of draft positions that
volunteers are continuing to build on.
(3) DEVELOPING A COMMON LANGUAGE
*Lead:* Catalina
*Purpose: *Develop shared terminology and conceptual framing to describe
the Wikimedia model in policy environments. Definition, differences and
implications of "Open", "Digital Public Goods" and "Commons", etc.
*Outcomes*:
- Published a movement-wide framing document (attached) identifying
Wikimedia projects as digital public goods, governed as commons, and
functioning as digital public infrastructure.
- Delivered a conference session at Wikimania 2025, introducing the
framework to a wider audience of Wikimedians and partners and gathering
feedback for future iterations.
*Impact*
A possible next phase would involve identifying and analyzing use cases
where this framing provides concrete advocacy value. For example:
- Explaining the role of Wikimedia in AI training, transparency, and
responsible data governance;
- Highlighting Wikimedia as an essential public digital infrastructure
in national digital transformation agendas;
- Connecting Wikimedia’s governance model with broader conversations
about digital commons, open science, and cultural heritage preservation.
___
Looking forward to exploring how we continue to work together in 2026! In
case you missed it, reflections on our movement's advocacy work are in my
email titled "*Read me | Last meeting of the year & 2026 strategy."*
Have a great end to the year,
Ziski
Franziska Putz (she/her)
Senior Movement Advocacy Manager
Global Advocacy, Wikimedia Foundation
Fputz(a)wikimedia.org
UTC Timezone
The conversation starter in Brussels this month has been: "What is the
plural of omnibus?" Omnibi, omnibuses and simply "two omnibus" have all
been used. Linguistics aside, November has been a big policy month. Two
omnibuses were presented. A GDPR simplification of record-keeping
obligations is proceeding through the parliament. Lastly, the long awaited
“Democracy Shield” was unveiled.
=== Two New Omnibuses ===
Last week the European Commission published two new omnibuses: One on the
AI Act
<https://digital-strategy.ec.europa.eu/en/library/digital-omnibus-ai-regulat…>,
and a general one
<https://digital-strategy.ec.europa.eu/en/library/digital-omnibus-regulation…>,
tacking a slate of digital rules. The stated intention is to simplify the
sometimes very complex EU rules. However, one major criticism is that the
proposals go further and fundamentally change the EU’s digital rulebook by
weakening long held principles like data protection.
—
The “general” omnibus is packed with amendments to the GDPR and to the
rules on re-use of open government data. The latter is currently spread
across various pieces of legislation (Data Governance Act, Data Act, Open
Data Directive). One suggested change is to move all relevant articles to
the Data Act.. Another change is to allow public sector bodies to charge
specifically very large enterprises to charge for data re-use. This is
politically not very surprising. The challenge is that, if implemented,
such specific licensing provisions would be incompatible with the open
definition and free licenses used by Wikimedia projects. The details will
be important here.
—
More consequential are the various changes proposed to the GDPR and the
ePrivacy Directive. The draft tries to tackle so-called “cookie banner
fatigue” by introducing several broad exceptions that will allow services
to gather and use device data without asking. It also prohibits services
from asking for consent a second time within six months, if they were
already denied by the user.
—
A seemingly positive idea is to introduce a so-called “privacy signal” to
browsers. Users would set privacy preferences in their browsers once and
these would then be communicated automatically when opening a web site,
signalling consent or denial. Another provision would require data breaches
to be notified only to the authority in the place of establishment.
Currently such breaches must be reported to several, sometimes even all,
authorities.
—
The most contentious parts of the GDPR proposals are about redefining the
definitions of personal and pseudonymised data. The changes would also make
the re-use of personal data for AI training easier by categorising it as
“legitimate interest”. Weirdly, this would lower the threshold for AI
training much lower than other everyday uses.
—
At Wikimedia Europe we are still analysing the texts and have the ambition
to share this analysis and a potential position in the coming weeks.
=== Democracy Shield ===
On November 12, the Commission published the European Democracy Shield
<https://commission.europa.eu/document/2539eb53-9485-4199-bfdc-97166893ff45_…>.
It is a non binding communication, identifying a whole range of measures
that should protect EU democracy, focusing on three main areas:
1) the safeguard of information space;
2) the strengthening of democratic institutions, free and fair elections
and free and independent media;
3) boosting societal resilience and citizens’ engagement.
—
Among the most relevant measures are the setting up of the European Centre
for Democratic resilience, the full implementation of the current
legislation (DSA, EMFA) as well as a revision of the anti-SLAPP
recommendation
<https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32022H0758>
from 2022. There is also an explicit mention of the review of the Copyright
Directive to address the challenges posed by generative AI.
=== AVMSD Review Consultation ===
The Audiovisual Media Services Directive regulates media services. However
the differences between traditional media services and online video-sharing
services are melting away and the EU is likely to update this piece of
legislation.
—
The Commission opened a call for evidence
<https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1…>
to kick off its revision process. The next step will be the launch of an
open consultation and the publication of the report by December 2026.
—
Relevant issues for us to monitor are which platforms get defined as video
sharing or streaming services. Currently Wikimedia Commons is not in scope.
Video sharing or streaming services have certain obligations , such as
carrying European content and age verification. All these will be
re-discussed.
=== GDPR Simplification ===
Since May a legislative proposal
<https://oeil.europarl.europa.eu/oeil/en/procedure-file?reference=2025/0130(…>
to reduce the record-keeping obligations on SMEs has been making its way
through the process. It includes changes to the GDPR. Most notably, the
European Commission suggests that organisations with fewer than 750
employees should have fewer obligations, as long as the processing is not
high risk. This would benefit the Wikimedia Foundation, which is currently
around 700.
—
The European Parliament committees now further voted to increase the
threshold to 1500 (see Amendment 3
<https://www.europarl.europa.eu/doceo/document/CJ58-PR-775772_EN.pdf>).
Another amendment (AM 4), specifies that the derogation is for a given
processing activity. Meaning that if an organisation performs both
high-risk processing and non-high-risk processing activities, the
derogation will still apply to the latter.
=== CSA ===
This week the Council finally agreed
<https://www.consilium.europa.eu/en/press/press-releases/2025/11/26/child-se…>
on a negotiating mandate
<https://data.consilium.europa.eu/doc/document/ST-15318-2025-INIT/en/pdf>
on the CSAM Regulation, three years after the original proposal.
—
The deadlock was broken by Denmark and other hawkish countries giving up on
forcing messaging services to scan for CSA material. A measure that would
break end-to-end encryption. The mandate, however, still allows services to
voluntarily scan messages. It also includes a review clause that mandates
the Commission to check in three years if the state of hash scanning
technology has developed and further changes are needed.
—
The Council must now negotiate with the European Parliament, whose own
position
<https://oeil.europarl.europa.eu/oeil/en/procedure-file?reference=2022/0155(…>
has also removed the mandatory chat scanning provision. They are expected
to reach a decision by April this year. Else the currently permitted
voluntary scanning will become illegal. It is now ensured by a stopgap law,
which expires in 2026.
== Franco-German Digital Summit ===
On 18 November Germany and France organised
<https://www.elysee.fr/en/emmanuel-macron/2025/11/18/summit-on-european-digi…>
a Summit on European Digital Sovereignty in Berlin. Politically it was an
effort for the two EU heavyweights to align on several ideas and drive the
continent forward. Germany is traditionally very cautious on “sovereignty”
issues, but that is shifting. France is currently in an extremely weak
position not being able to form stable governments.
—
Ahead of the summit an open letter
<https://wikimedia.brussels/open-letter-harnessing-open-source-ai-to-advance…>
with concrete demands regarding open source and public interested AI was
circulated. It was co-signed, among others, by WMFR, WMDE and WMEU.
Wikimedia Deutschland was also represented at the event.
—
The authors of this newsletter struggle to point to concrete and palpable
outputs.
== DSA Reports ===
Last week the European Commission released two interesting reports
regarding the Digital Services Act, Europe’s content moderation rulebook.
—
The first one looks at the overlaps
<https://digital-strategy.ec.europa.eu/en/library/report-application-article…>
between the DSA and other legislation. Elements of it will likely find
their way into a DSA evaluation that the Commission needs to finalise
before November 2027. It might also influence potential future legislative
(simplification) proposals.
—
The second report looks at the risk assessments, mitigation measures and
audits performed by Very Large Online Platforms
<https://digital-strategy.ec.europa.eu/en/news/digital-services-act-report-l…>
(including Wikipedia’s) and tries to provide something like a meta-analysis
for systemic risks in the EU.
== Child Protection INI ===
The European Parliament adopted a de facto resolution
<https://www.europarl.europa.eu/news/en/press-room/20251120IPR31496/children…>
(a non-binding own-initiative report) that calls for an age limit of 16
years for social media use. It also asks for the possibility for children
to access social media if parental consent is given. If this turns into an
actual legislative proposal by the Commission it would be crucial that
Wikimedia projects are not defined as social media.
--
Wikimedia Europe ivzw