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 👏 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 @Marília 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
Hi everyone,
Many of you know that RightsCon, the world's largest digital rights
conference, is coming to Lusaka, Zambia in May 2026.
Travel scholarships (full details here
<https://www.rightscon.org/rc26-travel-support/>): The deadline to apply
for travel support is January 5, 2026 at 23:59 Pacific Standard Time, and
decisions will be communicated to applicants by the end of January 2026.
The email below contains more information about eligibility and the
application process.
*Why attend RightsCon: *Whether or not you submitted a session, I highly
encourage you to apply for a travel scholarship. RightsCon is a vibrant,
dynamic, and relaxed space for digital rights activists, researchers,
technologists, and journalists to connect and share their work. You can
read more about how Wikimedians have participated here
<https://diff.wikimedia.org/?s=rightscon>.
Best,
Ziski
---------- Forwarded message ---------
From: Daphne Ugarte, Access Now <rightscon(a)accessnow.org>
Date: Mon, Nov 3, 2025 at 5:01 PM
Subject: Start planning your RightsCon 2026 participation
To: <fputz(a)wikimedia.org>
[image: Start to plan your travel to Zambia]
<https://www.rightscon.org/plan-your-travel/>
Hi Franziska,
With registration launching later this week, it's time to start planning
your travel if you want to join us in person for *RightsCon 2026
<https://www.rightscon.org/> (May 5–8, Lusaka, Zambia, and online)*
We’re excited to launch the first phase of our *Plan Your Travel*
<https://www.rightscon.org/plan-your-travel/> page, your go-to resource for
everything you need to know to travel to Lusaka, including:
• Preliminary *visa information* and our key recommendations
• *Flights* and airport arrival details
• *Accommodations*
• *Safety* *guidance* for participants
• A timeline of *key dates* to remember
Visit the Plan Your Travel page
<https://www.rightscon.org/plan-your-travel/>
As part of this launch, we’re also opening *applications for travel support
<https://rightscon.secure-platform.com/a/solicitations/62/home> *through
our Community Support Fund, which helps ensure our summit remains
accessible to underrepresented voices in our community who might not
otherwise be able to participate.
While *our resources are limited as an NGO*, we’ll continue to prioritize
participants directly involved in the program, like *session organizers,
speakers, and facilitators*.
You can learn more about our approach to the Fund this year in our *blog
post* <https://www.rightscon.org/rc26-travel-support/>. For details on
*eligibility
requirements and the kinds of support we offer,* visit *our website*
<https://www.rightscon.org/plan-your-travel/#csf>.
Talk to you soon,
Daphne, Nikki, and the RightsCon team
[image: LinkedIn] <https://www.linkedin.com/company/rightscon> [image:
twitter] <https://twitter.com/rightscon> [image: Instagram]
<https://www.instagram.com/rightscon/>
Stay connected with the RightsCon <https://www.rightscon.org> community on
social media for all the latest updates.
[image: LinkedIn] <https://www.linkedin.com/company/access-now> [image:
Twitter] <https://twitter.com/accessnow> [image: Instagram]
<https://www.instagram.com/accessnow/>
Follow Access Now <https://www.accessnow.org/> for more opportunities to
join the fight for human rights in the digital age.
You are receiving this email because you have registered for updates about
RightsCon. If you do not wish to receive these emails, click here to
unsubscribe.
<https://act.accessnow.org/page/email/subscribe?campaignpageurl=https%3A%2F%…>
For
support on anything related to RightsCon, please contact us at
rightscon(a)accessnow.org. This newsletter is sourced globally and published
out of our U.S. location.
Proudly hosted by Access Now | We defend and extend the digital rights of
people and communities at risk
https://www.accessnow.org | Access Now, 180 E Prospect Ave #189,
Mamaroneck, NY 10543
[image: supporter]
Hi all,
This is just a reminder that tomorrow (4 November) there will be an *online
Child Safety Training for Wikimedians
<https://meta.wikimedia.org/wiki/Wikimedia_Europe/Advocacy/Child_Safety_Trai…>*.
It will take place online, registrations
<https://docs.google.com/forms/d/e/1FAIpQLSegC5G8LNiq4lGQXmXy3aO6GlccRBDOZQH…>
are
still open.
It is mostly intended for project editors and users, with or without
extended rights. It will focus on the online experience, not on in-person
events. The basic idea is to provide necessary knowledge on specific
threats, assessing situations and deciding on reactions.
Best,
Dimi
--
Wikimedia Europe ivzw
Last month we slammed this list with a gigantic, long report. This month we
will try to focus on a few key developments: child protection (CSAM and
age-verification), the Franco-German Digital Summit and a minor DSA
update.
=== CSAM ===
Regular readers of this monitoring report will know about the proposed
Regulation to Prevent and Combat Child Sexual Abuse
<https://en.wikipedia.org/wiki/Regulation_to_Prevent_and_Combat_Child_Sexual…>
(and about the Wikimedia Foundation’s position
<https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1…>).
It has been stuck in Council for quite some time because Member States
can’t agree on an obligation on mandatory direct message scanning for
providers of interpersonal messaging services. The main criticism of this
is that it would essentially vanish end-to-end encryption.
—
There is a very recent development. One of the staunchest supporters of the
obligation, Denmark, which also currently holds the rotating Council
presidency, announced it is dropping this demand
<https://www.berlingske.dk/politik/dansk-forslag-om-digital-boernebeskyttels…>.
This could very well unblock the deadlock.
—
The European Parliament has a negotiating position since 2023 (without this
obligation), so if the Council now manages to agree on its own position, we
might see this legislation progress quickly.
—
There is also a looming deadline. Currently companies may scan for CSA
material voluntarily, based on a temporary exception
<https://www.europarl.europa.eu/news/en/press-room/20240408IPR20311/child-se…>
to the ePrivacy Directive, which will expire in April 2026.
—
Other articles of this regulation will establish a European centre in The
Hague, which will maintain a hash database with known and suspected
material that platforms will be obliged to scan for and, if found, report.
The scanning of content outside of “private chats” has not been
controversial in the deliberations.
=== Blatant Plug ===
On 4 November we are organising an Online Child Safety Training
<https://meta.wikimedia.org/wiki/Wikimedia_Europe/Advocacy/Child_Safety_Trai…>
for Wikimedians (esp. project editors and contributors). You may still
register
<https://docs.google.com/forms/d/e/1FAIpQLSegC5G8LNiq4lGQXmXy3aO6GlccRBDOZQH…>
.
=== Age-Verification ===
The other hot child protection topic is age-verification. 25 countries
signed the so-called Jutland Declaration
<https://www.euractiv.com/content/uploads/sites/2/2025/09/Euractiv_1252_001.…>,
vowing to increase both national and European efforts to protect children
online. Interestingly Belgium and Estonia abstained from signing.
—
Still, two fault-lines remain. First, EU countries can’t agree on the “age
of majority” and whether there should be a universal one across the bloc.
Second, should this be a hard age limit, or should parental consent be able
to “override it”?
—
The European Commission is sending very mixed signals. They don't seem too
keen to move, but are being forcefully pushed in different directions by
Member States, MEPs and stakeholders. They are now focused on assembling a
panel of experts
<https://www.euractiv.com/news/von-der-leyen-eyes-tougher-social-media-restr…>
on this. Which does sound like kicking the can down the road.
—
The European Parliament passed one own-initiative report
<https://www.europarl.europa.eu/news/fr/press-room/20251013IPR30892/nouvelle…>
(of many) on child protection. In it, the parliamentarians declare that
they want a university “digital majority” age of 16. Below this age access
to social media and AI assistants should be possible only with parental
consent. It also calls for the prohibition of dark patterns. Own-initiative
reports are non-binding.
—
Two countries where the debate is already underway, and based on actual
legislative proposals that are being negotiated, are Italy and Romania. In
both countries Wikimedia affiliates are engaging. In Italy an amendment
<https://www.senato.it/show-doc?leg=19&tipodoc=EMENDC&id=1476126&idoggetto=1…>
aims to clarify the definition of “social network” (thereby excluding
non-commercial educational, scientific and encyclopedic projects). In
Romania there are three (3!) separate age-verification proposals in the
legislature. WMROMD <https://romd.wikimedia.org/wiki/Pagina_principal%C4%83>
is working on public and direct communication, based on the notion of
“protecting
and empowering children online
<https://wikimedia.brussels/protecting-and-empowering-children-online-a-wiki…>
”
== Franco-German Digital Summit ===
Germany and France are preparing a high-level, politically very symbolic
Franco-German Digital Summit
<https://dig.watch/event/summit-on-european-digital-sovereignty> on 18
November. There will be many sessions on digital sovereignty, as one might
expect.
—
Ahead of the summit the German government has signalled it wants the AI
Act’s obligations to be delayed and to be clarified so it makes the lives
of entrepreneurs and enterprises easier. Germany is also eyeing another
simplification of the GDPR.
—
France is mostly pushing for age verification and “making big tech pay”.
However the French position can be considered a bit weaker, seeing the
inability to show off a stable government, budget or parliamentary
majority.
—
Wikimedia Deutschland will be present and Wikimedia will join a call to
advance open-source, public interest AI, including specific ideas how to do
so. Watch this space.
== DSA Data Access ===
A delegated act
<https://digital-strategy.ec.europa.eu/en/library/delegated-act-data-access-…>
on how researchers should be given access to Very Large Online Platforms
(VLOPs) to study systemic risks came into force.
—
It specifies that researchers must file requests for data to the national
authorities first, which then decide whether to pass on their petitions to
VLOPs. Researchers must provide information about their funding and
research questions.
—
It is not the most important development in the world right now, but still
important to note. Data about Wikimedia projects is mostly open by default.
Still, some requests might add considerable workload on the Wikimedia
Foundation or raise questions about which information could potentially
harm volunteers if disclosed.
—
Recommended read: A deep-dive
<https://verfassungsblog.de/dsa-platforms-digital-services-act/> on
studying platform by using DSA provisions by Daphne Keller.
*=== END ===*
--
Wikimedia Europe ivzw
This time we have a heavyweight report for you. EVERYTHING is going on.
In Denmark your face and voice will soon be protected by copyright.
Meanwhile in Brussels, all levels of the EU are hotly discussing child
protection, its brewing. Oh yes, and simplification is also very hot right
now. The EU is under pressure to simplify its rulebooks.
Welcome to a busy rentrée, brought to you by WMEU :)
=== Denmark Copyrights Faces ===
Denmark’s parliament is expected to pass a bill that extends copyright
protections to personal characteristics, such as voices and faces. It will
include a protection against the sharing of realistic digitally generated
imitations of people’s personal characteristics. In parallel, there will be
a second protection for performers and artists against the sharing of
realistic digitally generated imitations of their performances. There will
be a solid majority in parliament for this and we expect it to become law
by the end of the year.
—
Wikimedia Denmark has participated in the public consultation
<https://dk.wikimedia.org/wiki/H%C3%B8ring/H%C3%B8ring_over_forslag_til_lov_…>,
pointing out that the exceptions and limitations foreseen in the draft
proposal would be insufficient to protect all current users on Wikimedia
projects.
—
Apart from this, the Communia Association
<https://communia-association.org/2025/08/21/communias-submission-to-the-dan…>
for the Public Domain and Professor Bernt Hugenholtz
<https://communia-association.org/2025/08/21/communias-submission-to-the-dan…>
from the University of Amsterdam, have additionally questioned the wisdom
of using copyright to achieve this otherwise laudable policy goal.
—
At a Copyright & AI conference
<https://danish-presidency.consilium.europa.eu/en/events/conference-on-copyr…>
in Copenhagen organised by the Danish Council Presidency, that Dimi
attended, the Danish Minister of Culture was quite proud of the project.
Ministry officials admit that it might not be the perfect solution, but
also doubt that a perfect solution exists. Their reasoning for using
copyright is that it already has an existing framework for content
moderation that includes notices, liability rules, exceptions, and free
speech protections.
=== More Copyright & AI ===
Speaking of copyright and AI, there is a parliamentary own-initiative
report
<https://oeil.secure.europarl.europa.eu/oeil/en/procedure-file?reference=202…>in
the works, penned by MEP Axel Voss (EPP DE) as rapporteur. It is
non-legislative, so it will be essentially a document with a list of
statements that a majority can agree on. Voss himself is suggesting that AI
generated content should be public domain. There is also plenty of talk
about how smaller organisations can negotiate their rights vis-à-vis
operators of large language models, with collective licensing agreements
being floated.
—
Currently amendments are being analysed and discussed in commission. They
are expected to be considered on 13 October, a committee vote is scheduled
for early December. The plenary vote is expected in January.
== Child Protection ===
In the Council, the Danish Council Presidency is working on a declaration
on online safety. From what we have seen it will include language asking
for age verification for "social media and all other relevant digital
services that pose a significant risk to minors". The open question here is
which platforms exactly are meant by this. Declarations are non-binding in
nature, but are often used to build political momentum ahead of legislative
proposals.
—
In the Parliament, there is an own-initiative report on child protection
online, led by digital powerhouse lawmaker Christel Schaldemose (S&D DK).
It is currently in the drafting phase with compromises being negotiated.
The rapporteur is suggesting that the report demands age verification
mechanisms, not just age assurance, for social media and video-sharing
platforms. It also demands harmonisation, including on age limits. We will
see which of these demands get a majority, as criticism is pouring in from
both left and right, albeit for different reasons: privacy, national
competence and parental prerogatives. Such reports are non-legislative and
non-binding, but serve to test majorities.
—
The largest political group in the parliament, and the one holding almost
all important positions of power, the EPP, is working on its “digital
position paper”. It is expected to demand age verification for online
gambling and pornography. It also calls for a harmonised minimum age of 16
for the use of social media and video-sharing sites, in the absence of
parental consent. The latter, according to the draft, could be achieved
with age assurance measures. We will wait to see the final product.
—
The President of the European Commission, Ursula von der Leyen, included
child protection in her annual speech to the parliament. She
name-checked Australia’s
social media restriction for users under 16 based on age as a positive
example and shared that she plans to commission a panel of experts to show
the way forward.
=== CSAM Regulation ===
We have written about the proposal on fighting Child Sexual Abuse Material
online
<https://en.wikipedia.org/wiki/Regulation_to_Prevent_and_Combat_Child_Sexual…>
many times in this newsletter (and about the WMF position
<https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1…>).
The European Parliament has a good negotiating mandate
<https://www.europarl.europa.eu/news/en/press-room/20231110IPR10118/child-se…>,
defending privacy by not mandating the scanning of all direct messages on
all messaging services. The Council’s position is still not agreed upon,
which is why the file is still stuck.
—
The development is that in mid-October there will be a vote of the
Justice/Home Affairs Ministers. The Danish Council Presidency wants to
remove the deadlock with a new compromise text
<https://data.consilium.europa.eu/doc/document/ST-10131-2025-INIT/en/pd>.
The text has attracted significant criticism, mainly for fears that this
proposal would break end-to-end encryption. If the Council manages to agree
on a position, they will start negotiations with the European Parliament.
=== Simplification ===
The European Commission is looking for new targets to propose
simplification, i.e. to cut bureaucracy or reduce regulatory burden. After
the GDPR burden reduction proposal, which will reduce record keeping
obligations for organisations smaller than 750 staff and which the WMF
welcomes
<https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1…>,
they have now turned their attention to the so-called digital omnibus. It
is with a focus on data, cybersecurity and artificial intelligence and
the public
consultation is ongoing
<https://digital-strategy.ec.europa.eu/en/news/commission-collects-feedback-…>
.
—
Simultaneously, the Commission is also reviewing how the Digital Services
Act interacts and overlaps with other laws and rules. It is also taking a
second look at VLOP-specific rules, such as designation and calculation of
thresholds. This could be of interest to Wikipedia, which is a VLOP under
the DSA.
—
The work on simplification is accelerated by very strong language from
national capitals, including Germany
<https://www.politico.eu/article/friedrich-merz-vows-stick-in-the-wheels-of-…>
and Sweden
<https://www.linkedin.com/posts/luca-bertuzzi-186729130_in-july-swedens-prim…>
most recently, to focus on competitiveness and re-start the economy.
=== Do Paço ===
If you read the public policy list, the César do Paço saga will not have
escaped you. The Wikimedia Foundation is now going to the European Court of
Human Rights to contest the decision by the Portuguese court to hand over
user data and remove some content. Jacob Rogers from WMF Legal has written
up an excellent explanation
<https://medium.com/wikimedia-policy/what-happened-in-the-c%C3%A9sar-do-pa%C…>
of the entire, multi-year development.
=== Data Retention for Criminal Proceedings ===
There is currently no harmonised EU regime with regards to criminal
proceedings that specifies which metadata service providers should keep and
for how long. The Commission has run a public consultation
<https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1…>
on this and the Wikimedia Foundation, as a service provider, provided
feedback
<https://drive.google.com/file/d/1ywq0eb14s-3j9m8omIVz4mMGw6ZbW7_P/view?usp=…>.
Broadly speaking, the position is that data retention affects human rights
and the public interest and that broader and longer data retention
obligations would risk harming these. The WMF also cites its experience in
this area, including cases such as the above (Do Paço).
=== European Research Act ===
The European Commission is running, yet another, public consultation
on the European
Research Area Act
<https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1…>.
Wikimedia Sverige stepped in
<https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1…>
and provided public feedback. The key arguments made are that open access
to research results is crucial for the dissemination of accurate
information to the public, including through Wikimedia projects. It also
outlines how researchers are often hindered by significant legal and
technical barriers and makes the case for a broad research exception.
=== Civil Society Engagement ===
Not to be outpaced, Wikimedia Deutschland also provided feedback at the EU
level recently. There was a consultation on the EU’s Civil Society Strategy
<https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1…>
and how to address the shrinking civic space for civil society. In its
feedback
<https://docs.google.com/document/d/1qGKN1Lw2Y7Dula3kDOaNEwR8ptVOhu1g/edit?u…>
WMDE emphasises the role of volunteers and the need to protect their
rights, as well as to support community based models.
=== European Competitiveness Fund ===
The EU is discussing
<https://www.consilium.europa.eu/en/meetings/compet/2025/09/29/?utm_id=3318>
its 2028-2034 long-term budget (a.k.a. the multiannual financial framework,
MFF). Perhaps the main instrument in it is the European Competitiveness
Fund (€409 billion are proposed).
—
The trick with such gigantic funds is that in the end no one really knows
what exactly to do with the money. They have all these keywords written
into their regulation, but what exactly are projects that could deliver? In
the case of the ECF
<https://data.consilium.europa.eu/doc/document/ST-11770-2025-INIT/en/pdf>
we can find terms like open-source, digital public infrastructure,
sovereignty, competitiveness, and simplification.
—
Instead of arguing about five billion more here or there, and about whether
to use the term “digital public good” instead of “digital public
infrastructure” (just a made up example), it might be refreshing to skip
the meta-level and to concretise the conversation a little with concrete
examples of past funded projects that worked and such that didn’t. Just an
idea.
=== END ===
--
Wikimedia Europe ivzw
Hi all,
The Wikimedia Foundation’s Legal department has published draft proposals
<https://meta.wikimedia.org/wiki/Wikimedia_Foundation/Legal/Update_to_banner…>
for policies related to the use of banners and logo changes for advocacy
purposes. The policy proposals are informed by research conducted earlier
this year
<https://diff.wikimedia.org/2025/01/24/help-us-collect-examples-of-community…>
in collaboration with Wikimedia communities, collecting examples of past
decisions to run banners or change logos in response to external topics.
The draft policies aim to avoid interfering as much as possible with the
most common uses of banners and logo changes, address some edge cases, and
create more standardized processes for reviewing, approving, and
implementing proposed actions.
You can review the draft policies and provide feedback on Meta-Wiki:
https://meta.wikimedia.org/wiki/Wikimedia_Foundation/Legal/Update_to_banner…
We have also posted about the proposals on Diff:
https://diff.wikimedia.org/2025/09/11/proposed-policies-related-to-the-use-…
I'd be interested to hear what you all think about the draft policies, and
how you expect they might affect public policy advocacy on the projects.
You're welcome to write to me directly with your feedback, if you'd rather
not share it on the talk page.
Thanks,
Chuck
==
Charles M. Roslof
Principal Legal Counsel
Wikimedia Foundation
Pronouns: they / he
NOTICE: This message might have confidential or legally privileged
information in it. If you have received this message by accident, please
delete it and let us know about the mistake. As an attorney for the
Wikimedia Foundation, for legal/ethical reasons I cannot give legal advice
to, or serve as a lawyer for, community members, volunteers, or staff
members in their personal capacity. For more on what this means, please see
our legal disclaimer
<https://meta.wikimedia.org/wiki/Wikimedia_Legal_Disclaimer>.
Dear all,
The date and time for our next quarterly call has been set; thank you all
for filling out the Doodle poll.
The call will take place on Thursday, *September 18th @ 16:00 - 17:30
UTC *(check
your local time <https://zonestamp.toolforge.org/1758211200>). The specific
agenda will be set collaboratively ahead of time. It will take place on
Zoom. This call will feature @Marília Rocha <marilia.rocha(a)wmnobrasil.org> from
Wikimedia Brasil, who will be presenting their exciting copyright campaign
<https://diff.wikimedia.org/pt/2025/05/28/conhecimento-e-direito-a-campanha-…>
.
👉 Register for the call (and receive a calendar hold):
https://wikimedia.zoom.us/meeting/register/KfJ40yVyT8i0eV-F7ZnO8g
<https://wikimedia.zoom.us/meeting/register/KfJ40yVyT8i0eV-F7ZnO8g>
See you there!
Ziski
___
**Call details:** The purpose of these calls is to collaborate on
priorities for the year, and to ensure that members of our movement can
share learnings and hone our outreach, advocacy, and impact on policy
efforts. The specific agenda will be set collaboratively ahead of time.
Our 2025 working groups are currently the following:
- Copyright
- Shared definitions of key terms and concept
- Policy Position Primers
Franziska Putz (she/her)
Senior Movement Advocacy Manager
Global Advocacy, Wikimedia Foundation
Fputz(a)wikimedia.org
UTC Timezone
Hi everyone,
Happy Friday, I hope you have nice weekends ahead. I'm writing to share an
update on the long saga that has been the UK Online Safety Act.
First, a quick recap of what's happened over the summer since many of us
are just getting back to our inboxes.
- In July the High Court of Justice in London heard the Wikimedia
Foundation’s legal challenge
<https://medium.com/wikimedia-policy/wikipedias-nonprofit-host-brings-legal-…>
to
the Categorisation Regulations
<https://www.legislation.gov.uk/uksi/2025/226/regulation/3/made> of the
UK OSA.
- In August, the High Court of Justice dismissed the challenge. Silver
lining: The Court’s ruling emphasized the responsibility of Ofcom
<https://www.ofcom.org.uk/> and the UK government to ensure Wikipedia is
protected as the OSA is implemented.
- 👉 *[We are here]* The September update: We have decided that we will
not appeal the UK High Court’s decision to dismiss our challenge. However,
we will continue to monitor how the Court’s guidance is followed, and
how Wikipedia is protected as the OSA moves forward. There's never a dull
moment in UK politics so who knows what the future holds!
We do know what our future holds: The quarterly advocacy network call next
week! Sept. 18th @ 16:00- 17:30 UTC. Register here
<https://wikimedia.zoom.us/meeting/register/KfJ40yVyT8i0eV-F7ZnO8g>.
Have a lovely weekend,
Ziski
Franziska Putz (she/her)
Senior Movement Advocacy Manager
Global Advocacy, Wikimedia Foundation
Fputz(a)wikimedia.org
UTC Timezone