CFG’s response to the European Democracy Shield 

Introductory remarks

This response from the Centre for Future Generations (CFG) is our contribution  to the call for evidence for the European Democracy Shield (Ref. Ares(2025)2555098) launched on 31 March 2025. CFG welcomes the European Commission’s objective established by the European Democracy Shield (EUDS) to address the most severe risks to democracy in the EU and restore public trust in democratic institutions and processes.

The EUDS arrives at a pivotal moment as the global outlook for democracy grows increasingly bleak^[1]. Major democracies are facing significant erosion, particularly through disinformation and political interference – threats the EUDS rightly aims to tackle. As a roadmap for the 2024-2029 Commission, the EUDS also aims to adopt a broader lens, including strengthening of societal resilience, preparedness, and active citizen participation, all of which are essential elements in reinvigorating democracy.

While vigilance toward foreign information manipulation is essential, an overemphasis on external threats alone risks overlooking deep, internal imbalances of power, accountability, and democratic agency that have steadily corroded public trust and left Europeans increasingly susceptible to undue influence in the first place.

To be effective, the EUDS must confront vulnerabilities on both fronts: foreign disinformation campaigns and election interference as well as the internal decline of democracy itself, evident through a marked authoritarian drift, unchecked corporate capture, and a widening gap between institutions and the people they serve.

Although Europe still remains the most democratic region in the world, citizen confidence in its democratic institutions is waning driven by a combination of political, social, and technological factors – demonstrating that the globally notable democracy decay is leaving a mark within the EU as well^[2]. Addressing this decline is a necessary and an urgent objective of EUDS. We recommend the following to be addressed through the EUDS framework:

1. Reversing the impact of powerful, unaccountable tech companies on democratic institutions.
2. Leveraging EUDS to integrate democratic conditionalities across EU frameworks.
3. Broadening EUDS’ whole-of-society approach to include future generations.
4. Futureproofing cognitive integrity in light of emerging technologies.

Securing long-term democratic resilience by fixing faultlines

Lasting democratic resilience will require fixing the deeper, structural flaws weakening the EU from within – cracks increasingly visible in the digital policy sphere. As an organisation working on the governance of emerging technologies in the best interest of humanity, CFG proposes the below strategic shifts grounded in identified fractures in the EU’s democratic infrastructure. Concrete solutions we propose to address these fractures within the EUDS framework are:

1. Reverse the impact of powerful, unaccountable tech companies  on democratic institutions.

American digital tech giants are amongst the dominant incumbents who have exploited the label of ‘innovation’ to systematically consolidate power, shifting control away from democratic institutions and onto themselves – otherwise labelled The Tech Coup^[3]. Recent geopolitical developments, in particular, have exposed our reliance on these increasingly unreliable  actors when it comes to core technologies^[4] and critical digital infrastructure.

It is widely reported that big tech’s political capture is already impacting the EU’s digital toolbox in the form of weakened public interest safeguards in the AI Code of Practice^[5] and mounting threats to GDPR protections as part of the fourth Omnibus package^[6]. These impacts  test Europe’s resolve to effectively enforce its digital and data laws^[7], politicising Europe’s already-fragmented enforcement efforts, and stalling the EU’s regulatory momentum, ultimately threatening the EU’s global leadership as a democratic standard-setter in the digital space ^[8].

Beyond these specific policy impacts, the broader process surrounding the Omnibus Package has been labelled as “rushed, opaque, and undemocratic” by co-legislators and civil society alike^[9], effectively risking further damage to public trust in democratic processes and institutions.

The above risk is amplified when regulatory simplification efforts – though not inherently harmful to democracy in and of themselves – are paired with a crackdown on civil society^[10] from within the EU institutions, compounding the threat to inclusive and accountable governance. Efforts to defund civil society^[11], albeit not tech NGOs so far, under unsubstantiated claims of lobbying undermine democratic pluralism and weaken civil society at a time when corporate influence, especially by big tech, is growing. The EU’s tech rulebook is one of the biggest targets of lobbying action^[12] and big tech players are amongst the top spenders on corporate lobbying in the EU^[13].

Civil society’s role in the EU’s democratic policymaking process is not only enshrined in the Treaty of the European Union, but civil society also acts as a countervailing force to corporate power by surfacing community needs that might otherwise be sidelined by powerful profit-driven interests. To preserve democratic balance, the EU civil society strategy that will accompany the EUDS must protect civic actors and ensure they have equal access to decision-making.

Moreover, to safeguard democratic integrity amid rising pressures to simplify EU governance and boost competitiveness, the EUDS should also include a European Code of Conduct for Partnerships to guide and streamline stakeholder engagement under the EU’s simplification agenda. 

Modelled on the partnership principle in cohesion policy^[14], a Code of Conduct on Partnerships would ensure that civil society, social partners, local authorities and all affected stakeholders, including marginalised communities, have a formal, protected role in shaping policies related to the institutions’ new priorities. It would embed rights, inclusion, participation, and rule of law at the heart of these processes, acting as a democratic guardrail against shrinking civic space and outsized corporate influence.

In the long-term, we propose establishing a European Civic Fund as part of the EUDS framework, allocating 1% of the forthcoming Multiannual Financial Framework (MFF) to support civil society organisations across the EU. This fund should represent a strategic investment in the democratic architecture of the EU. Under shared management with DG JUST, such a fund should complement the MFF’s CERV programme by providing sustained structural funding beyond project-based support to protect civic space and ensure democratic resilience in the long-term.

Such a European Civic Fund should be coupled with major investment in European digital infrastructure that is democratic by design. This can be done through, for example, the creation of an EU-wide Digital Sovereignty Fund^[15]. Together, these measures can ensure Europe’s digital toolbox and infrastructure support each other in the public’s interest.

2. Leverage EUDS to integrate democratic conditionalities across EU frameworks.

The Omnibus process and proposal reflects a broader disconnect between defending democracy in principle and EU lawmaking in practice where democratic values are routinely disregarded, only to be invoked during moments of foreign interference or around election periods – a trap that the EUDS should avoid. A telling illustration of this gap is the limited attention to democracy in the recent AI Continent Plan^[16], despite several other strengths^[17].

This  gap is especially pressing given that AI not only increases the risk of mis- and disinformation, it is also poised to reshape power dynamics and economic structures^[18] in ways that may erode democratic stability. AI is being used to automate surveillance and enforcement capabilities in authoritarian regimes, raising the longer-term risk of more durable and repressive state control^[19] – a risk from which the EU is not exempt^[20] .

The AI Continent Plan overlooks both the danger that AI poses to democracy but also the opportunity to support it. The sole mention of democracy is  in relation to international partnerships, while the potential of AI applications to enable citizen participation is not extensively addressed. When meaningfully designed and deployed, AI technologies can enhance collective deliberation, support fact-checking, and help people find common ground^[21] – factors that could significantly strengthen societal resilience and democratic preparedness. EUDS offers a strategic tool to bridge this gap.

Building on the rule of law conditionality to EU funding, democratic conditionalities like participation, transparency and rights-based governance should be core to all EU frameworks. As the Commission’s democratic compass, EUDS should be a vehicle to embed and institutionalise these principles through clear guidelines that ensure democratic standards are systematically upheld. These should be aligned with the above proposed Code of Conduct on Partnerships and coordinated  through a special EUDS Envoy in each DG, modelled on similar initiatives such as the Pact for European Social Dialogue^[22].

Beyond democratic conditionalities,  EUDS should also focus on innovative processes of democratic participation, informed by the experience of the European Citizens Panels. Evidence from recent experiments^[23] in Ireland, France, and EU-level citizens’ panels shows that randomly selected citizen bodies can enhance collective intelligence, increase trust, and counteract polarisation^[24]. At the same time, democratic renewal in the digital age also requires investment in open-source technologies that expand participation, such as platforms for large-scale deliberation, such as Pol.is^[25], participatory fact-checking, and inclusive online forums. When supported by digital inclusion strategies, these tools can reach wider, more diverse audiences and help embed democratic values in the very infrastructure of digital life. EUDS should actively support both domains – strengthening and scaling in-person participation while fostering a vibrant ecosystem of democracy-enhancing technologies – to ensure that innovation deepens democratic agency, not just institutional efficiency.

3. Broaden the whole-of-society approach to include future generations.

EUDS  rightly notes that effective democracy protection requires both a whole-of-society approach and continuous innovation in responding to external threats. However, a whole-of-society approach has not yet included unborn voices, rendering future generations the EU’s democratic blindspot^[26]. This is particularly true in times of geopolitical instability, when short-termism dominates. For democracy to thrive, it must be reimagined for every generation, ensuring that its protection is not only about the present, but also about those yet to come – a spirit EUDS should embody.

Adopting an intergenerational fairness lens would enable the EUDS to extend the whole-of-society approach to include the needs, rights, and voices of future generations alongside those of current citizens. This shift would promote inclusive, long-term policymaking  designed to benefit all segments of society across time. Embedding “more-than-human”^[27] governance processes^[28]  – including representation of unborn generations – into democratic decision-making, in line with the EU’s 2025 Intergenerational Fairness Strategy, would  reinforce democratic legitimacy and strengthen societal resilience and preparedness for future challenges.

To this end, DG Just and DG EAC should jointly establish a working group on representing future generations within the framework of EUDS to explore mechanisms that ensure their interests are considered  in democratic processes, building on the 2025 Intergenerational Fairness Strategy. Findings from this group should also inform updates to the European Code of Conduct on Partnerships, ensuring that these democratic innovations are integrated across EU policymaking.

4. Futureproof cognitive integrity in light of emerging technologies.

EUDS rightly places much-needed emphasis on online manipulation and safeguarding democratic discourse. Building on this foundation, there is an opportunity to broaden the scope of the initiative. This should include consideration of emerging technologies such as general-purpose AI and neurotechnology. These technologies are likely to shape future challenges to democratic resilience. In particular, they risk diminishing civic capacities by enabling more advanced and personalised forms of profiling, targeting, and election interference.

Although designed to enhance productivity and insight across workplaces, education, and personal life, AI tools may inadvertently erode citizens’ capacity for  critical thinking^[29] – a skill that is essential for free and informed decision-making, and meaningful participation in democratic discourse. Early evidence shows a relationship between AI tools and reduced critical thinking and information verification,^[30] particularly among younger and less educated users of AI through a phenomenon known as “cognitive offloading.”^[31]

These cognitive risks are likely to be amplified by the rise of brain-sensing technologies – a rapidly emerging consumer wellness market^[32]. Promising to support productivity, mitigate burnout, and improve brain health^[33], these tools may, in theory, strengthen cognitive resilience and enhance democratic capacities. However, the widespread collection of brain data outside of lab settings by direct-to-consumer companies opens new vulnerabilities for profiling and content tailoring via “neuromarketing.”^[34] At the most extreme, consumer-grade brain-sensing devices have been shown to allow AI systems to adapt content in real time to users’ mental states^[35] – raising profound concerns about intensified algorithmic manipulation, especially as these devices move toward mainstream adoption (as indicated by market trends).^[36]

To address this, EUDS should propose a move towards explicitly recognising a right to cognitive integrity, drawing inspiration from a recently proposed bill in Switzerland^[37]. Such a right would provide stronger legal and political grounding to explicitly protect and foster the cognitive skills required for democratic participation. A practical mechanism for institutionalising this right would be the Declaration on Digital Rights and Principles^[38], which currently affirms freedom of choice but not cognitive integrity or mental health.  In parallel, the EUDS should build on the ethical guidance and principles by OECD, UNESCO, and the Spanish Council Presidency for responsible neurotechnology – particularly prohibiting profiling and manipulation using brain data – and ensure these are properly enshrined and enforced in EU law^[39].

Our commitment moving forward

In conclusion, CFG strongly supports the EUDS’s ambition and stands ready to contribute our expertise, networks, and policy insights to help translate its vision into lasting impact.

Please contact n.kambli@cfg.eu at Centre for Future Generations with any questions or to request a further briefing.

Endnotes