Defending Democracy: Sanctions on Disinformation

Tackling Russia’s continued attempts to undermine Western democracies requires resilience against disinformation. Russian propaganda has been targeting Western countries by aiming to discredit events such as the Paris Olympics and influence electoral processes, including those of Romania and Moldova, as a recent discussion at RUSI’s Centre for Finance and Security highlighted.

The EU sanctions against the Kremlin’s war propaganda show that democracies do have the tools to defend themselves. The European External Action Service recently published its Third Report on Foreign Information Manipulation and Interference Threats (FIMI), which also highlights sanctions as part of the EU’s toolbox to combat disinformation.

While sanctions against disinformation remain a contentious issue from a freedom of speech perspective, they can be used as legitimate tools to counter harmful propaganda – but implementation and enforcement, as well as a lack of similar tools against domestic disinformation, remain key challenges.

An Expanding List of Sanctioned Propaganda Channels

From the start of the full-scale invasion in February 2022, the EU has imposed a raft of economic and trade sanctions against Russia. However, the EU also introduced new measures against Russian war propaganda in the third sanctions package on 1 March 2022. The swift adoption of these measures underlined the Council of the EU’s political will to step up efforts against foreign disinformation.

The initial sanctions targeted the English, French, German, and Spanish-language editions of Russian news outlets Russia Today (RT) and Sputnik. Later, the list was expanded by subsequent sanctions packages, and now encompasses 32 outlets, including the news agency RIA Novosti, TV channels Rossiya 24 and Rossiya 1, and the Rossiyskaya Gazeta and Izvestia newspapers. Despite the expanding list, not all Russian channels and media outlets are sanctioned. Several remain fully accessible in the EU, including the state-owned news agency TASS and the daily newspapers Kommersant and Vedomosti.

However, certain member states, including Lithuania and Estonia went beyond the scope of EU sanctions and banned Russian media outlets that are not listed by the Council Regulation. Elsewhere, European Free Trade Association members Norway and Switzerland, while aligning with virtually all EU sanctions against Russia, decided not to adopt the sanctions on disinformation outlets.

The sanctions ban the broadcasting of the listed outlets’ content within the EU, through all possible channels: TV, radio, internet, and mobile phone applications. However, this measure is not a ‘blanket’ sanction against disinformation actors, as it does not prevent the listed outlets from carrying out activities other than broadcasting, such as research and interviews in the EU. These exceptions were highlighted by the Council of the EU as being ‘consistent with the fundamental rights and freedoms recognised in the Charter of Fundamental Rights’ of the EU.

A Curtailing of Freedom of Speech?

The reasoning behind the sanctions gained further importance in the context of the sanctions’ criticism by experts and journalists’ associations, including the International Press Institute and the European Federation of Journalists as curtailing the freedom of speech. In its justification of the sanctions, the Council of the EU underlines that the listed media outlets are ‘under the permanent direct or indirect control of the leadership of the Russian Federation’ and were used to ‘channel propaganda action’, which constitutes ‘a significant and direct threat to the Union’s public order and security.’ Furthermore, the Council also refers to the ‘essential and instrumental’ role of the listed disinformation outlets in the aggression against Ukraine and the destabilisation of neighbouring countries.

The sanctions against disinformation and propaganda outlets were not only criticised, but also legally challenged by RT France. It claimed that the EU had no legal basis for the sanctions and that the sanctions infringed upon the freedom of expression and information. The Court of Justice of the EU upheld the sanctions, highlighting that an interference with freedom of expression can indeed be legal if it respects four conditions: having an EU legal basis, respecting the essence of freedom of expression, meeting an objective of general interest, and posing a proportional limitation.

The court’s reasoning drew attention to the fact that the sanctions are reversible if certain conditions set out by the Council Regulation are met, notably if the Russian aggression against Ukraine ends and the listed outlets ‘cease to conduct propaganda actions against the Union and its Member States’. The Court also underlined the fact that the sanctions do not ban the listed companies from pursuing activities other than broadcasting within the EU.

Implementation Challenges

While adopted on an EU level, the broadcasting ban is implemented by the EU member states’ national audiovisual regulators, who need to monitor not only TV and radio channels, but also online content across websites, social media platforms, and video-sharing apps. However, the sanctions have consequences reaching beyond the listed channels themselves. According to the European Commission’s ‘Frequently Asked Questions’, any media outlet or journalist that aims at broadcasting the sanctioned media outlets’ content to the public or ‘have that effect’, for example by republishing the content of RT verbatim and creating ‘mirror websites’, commits a breach of sanctions.

In Switzerland, where EU sanctions on disinformation were not adopted, the weekly Die Weltwoche published a verbatim translation of a RT article on 3 April 2025, spreading disinformation about the Russian war crimes committed in Bucha. The article was removed just a few hours after its publication. The case was recently discussed by the Frankfurter Allgemeine Zeitung, which argued that Die Weltwoche’s decision to republish an RT article was in violation of EU sanctions, as Die Weltwoche sees itself as a media outlet for German-speaking audiences in general (not just in Switzerland) and also runs a website with a German domain name, weltwoche.de.

This exemplifies the serious implementation challenges faced by European regulators. One challenge is uncovering and fining ‘mirror websites’ of sanctioned Russian outlets. Online tools such as the Information Laundromat can help monitor such behaviour. However, it is up to the member states’ authorities to enforce the sanctions against these actors.

Reports have shown that national audio-visual and internet regulators face difficulties in managing the bureaucratic layers of enforcing bans and keeping up with Russian disinformation actors’ circumvention techniques, leading to patchy implementation. Experts also noted that an EU-level harmonisation of sanctions implementation on disinformation actors could help address this challenge.

The Way Forward: Improving Enforcement and Tackling the Domestic Front

The circumvention challenge further demonstrates that beyond foreign actors, domestic disinformation channels also pose a threat of spreading war propaganda and disinformation. The European Parliament’s Special Committee on Foreign Interference (INGE)’s report on foreign interference and disinformation also highlighted that ‘foreign actors’ use of domestic proxies and cooperation with domestic allies blurs the line between foreign and domestic interference’.

Domestic disinformation actors are seen as often more numerous and better-embedded than foreign actors. While the regulation of domestic media actors remains largely a competence of the member states, the European Commission has taken some steps, including by integrating the Code of Practice on Disinformation into the EU’s Digital Services Act (DSA) earlier this year. However, EU member states need to continue working towards a harmonised approach to tackling harmful disinformation that can have consequences reverberating across the Union. The effectiveness of the EU sanctions against disinformation should also be monitored, allowing the EU to adapt its approach if needed.

At the same time, democracies need to balance restrictive measures with considerations for the freedom of speech and invest in societal resilience as well as media literacy. The EU’s reasoning in the case of sanctions against Russian war propaganda demonstrates that it is possible to find an approach that justifies measures and sets out conditions for lifting them, while taking decisive steps against foreign propaganda.

A more effective enforcement of sanctions against foreign disinformation and stronger action against domestic disinformation channels remain key challenges for the EU. Coordinated action is needed at a time when malign actors aim to sow discord and weaken democracies. It’s time to invest in self-defence against disinformation threats.

© RUSI, 2025.

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