EU policy/Transparency

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Transparent Policy Work

In line with our movement's values, Wikimedia is committed to full transparency when it comes to our public policy activities. The money we spend on our EU advocacy efforts is sourced from our European chapters. This page provides information about the current year's budget, plans and how we intend to make sure that money is well spent. For historical funding overviews, please take a look at 2015, 2016, 2017, 2018, 2019, 2020 and 2021.

Annual Priorities Plan 2022


I. Public Policy Goals

  • Digital Services Act: The flagship legislation of this legislative term, this will become the EU’s overarching content moderation law, covering all platforms and almost all types of content. Wikimedia has two priorities in it:
    • To ensure that WMF lawyers are not obliged to enforce community rules. The proposal currently doesn’t clearly distinguish between service provider’s and community rules.
    • To ensure that the proposed notice and action system takes into account that most notices we get are not about illegal content. The proposal seems to assume that every notice a hosting provider gets is proof of illegal content.
  • Digital Markets Act: The proposal targets so-called gatekeepers that offer core platform services and that have an entrenched position on the market. Suggested financial thresholds put Wikimedia out of the scope of the regulation. Still there are many provisions that benefit users and that we want to support, because they contribute to a better online ecosystem: interoperability of services, limits on combining data for behavioral profiling, a right to uninstall apps, to name a few.
  • Data Governance Act: The Data Governance Act aims at encouraging data sharing between governments and businesses, between businesses themselves and introduces the concept of data altruism. It shouldn’t be something that directly targets our projects, but the definition of “data intermediary” could be understood as Wikidata needing to register with European authorities. This risk seems to be mitigated in both the European Parliament and the Council, but we are following it closely still.
  • E-Privacy & E-Evidence: The E-Evidence Regulation will set clear rules for how a prosecutor in one EU country can request electronic evidence (e.g. edit log, messages, user data) from a service provider in another EU country. As the WMF already has a representative in Ireland for GDPR related requests, it is not unthinkable that at some point there will be a EU representative for other legal requests. We are thus working on keeping safeguards, such as what data can be requested without a court order and what types of data need a judge’s decision. We have so far been effective in moving so-called “traffic data” (i.e. which IP opened which article and when) to the latter category.

We were following developments in the ePrivacy regulation proposal mainly through the work of EDRi. Our direct interest is targeted at provisions on direct marketing and nonprofits. We want to make sure that we can contact members of our community / individual donors regarding new ways to support our organisations in compliance with data protection but without unnecessary prohibitions. The proposal is ambiguous whether nonprofits will be able to follow up with their supporters on new campaigns.

  • AI Act: The Artificial Intelligence Act is an extremely disorderly proposal to establish some rules for AI and Machine Learning tools. We are advocating for open source requirements for algorithms and open datasets (as much as possible), especially within the public sector. We also would like for the public to be able to test AI tools used by the public sector. As Wikimedia is a maker and user of AI tools and our data is widely used for training AI systems, we are trying to gain ground as a go-to expert. In this regard, we are publishing a series of articles on the type of tools we use and the challenges we experience.

II. Strategic Goals


“Wikimedia shapes crucial conversations on legislation that concerns our movement.”

  1. “We are the voice of "good tech" and self-governing communities.”

It seems that most legislation coming out of the European Commission is still written with only major industries and for-profit platforms in mind. Yet, commons based platforms and self-governing communities could be a necessary ingredient for how a constructive, collaborative and safe internet works. We want to make sure these groups and projects are known and heard.

  1. “We bring expertise based on evidence to keep internet open."

There seems to be a lack of research on how self-governing internet communities and commons based projects work. Lawmakers are asking themselves whether some of our practices could be used in one way or another to solve issues across platforms. Frankly, we have little hard data to point to and we will aim at closing this gap.

Proposed Budget 2022


FKAGEU 2022 planned budget

Budget Contributions 2022 (in €)

  • WMAT - 7000
  • WMCH - 8700
  • WMFR - 9000
  • WMIT - 5000
  • WMNL - 8000
  • WMNO - 2800
  • WMSE - 5000
  • WMUK - 1200
  • WMCZ - 800
  • WMPL - tbc
  • Amical - 600
  • WMBE - IT infra
  • WMDE - ca. 85% of staff cost

NB All Wikimedia chapters and thematic oragnisatons are contributing only own funds sourced in Europe, such as membership fees and local donations.

Indicators 2022

  • Wikimedia is part of the platform liability, artificial intelligence & data sharing discussions and has made constructive proposals that help keeping information technology open, safe and impartial. (10 inputs such as position papers, consultation responses, events, background conversations, interviews, information material presentation).
  • Wikimedia worked on the national transposition of the Copyright in the Digital Single Market Directive in at least 5 Member States. This includes: drafting national legislation proposals, contacting national policy makers and setting up national coalitions.
  • Wikimedia has secured additional third-party funding for digital civil society organisations across Europe.
  • Wikimedia is increasingly being seen as a "good tech" organisation and one that represents self-governing communities. We provided input and were invited to debates to present our experiences with running a platform and ensuring credibility and accuracy of content (20 times).
  • Wikimedia's communications activities in and around Brussels have increased (15 x brochures, studies, events, presentations, op-eds, mentions).