Persistent incentives and vulnerabilities: the FIMI landscape is shaped by:

• Poland’s geopolitical stance against Russia, making it a prime target for destabilisation.
• Exploitation of public support for Ukraine and its refugees to sow internal division.
• Weaponisation of the Belarusian border crisis to amplify migration tensions and political pressure.
• Leveraging domestic economic uncertainty and inflation to erode public trust in governance.
• Deep-seated domestic political polarisation, providing fertile ground for divisive narratives.
• Existing EU scepticism within segments of Polish society, targeted to undermine European integration.
• Critical absence of a permanent Digital Services Coordinator, creating a regulatory vacuum.

High-Impact Narrative Amplification:

• Anti-Ukrainian narratives aim to degrade public support for Ukraine in the context of Russia’s war of aggression and Ukrainian refugees’ influx, fostering social fragmentation.
• Anti-EU narratives seek to erode trust in European institutions and Polish membership, threatening foreign policy cohesion.
• Anti-Establishment narratives are designed to delegitimise democratic governance, including the incumbent government as well as public institutions, fostering political instability and public distrust.

Sophisticated FIMI Operations and information manipulation:

• Coordinated operations – Doppelganger, Operation Overload, the Pravda Network, and the sanctioned Radio Belarus actively disseminated misleading narratives and amplified ideologically aligned candidates.
• Foreign aligned operations – Lega Artis, Citizen GO, and Ordo Iuris further amplified polarising content.
• Unattributed or unaffiliated operations, such as covert ad campaigns (unaffiliated), a coordinated inauthentic behaviour network seemingly manipulating TikTok’s algorithm (unattributed), a Nigerian clickbait website (unaffiliated), and murky accounts were also observed engaging in information manipulation. Their objectives included promoting specific candidates, demoting oppositional candidates, and increasing political polarisation.

Unfair Political Actor Conduct: domestic political figures, particularly from the far-right and conservative-nationalist spectrum, were significantly associated with information manipulation. This included the fabrication of personas for self-promotion, the involvement of pro-Russian domestic actors, and the dissemination of false information about election procedures.

Exploited Systemic Platform Risks:

• X (formerly Twitter) lacks adequate checks on account creation, enabling large-scale coordinated inauthentic behaviour networks.
• Meta demonstrates weak ‘Know Your Customer’ (KYC) checks in its ad system.
• TikTok exhibits weak and inconsistent enforcement of its political campaigning policy, allowing circumvention, impersonation, and deceptive campaigns.

Read the full report here.

Policy Implications and Recommendations

The 2025 elections revealed a troubling discrepancy between identified FIMI threats and the adequacy of institutional and platform responses. Bridging this enforcement lag requires immediate and sustained policy action. Only through sustained engagement, robust institutional frameworks, and an empowered, collaborative civil society can Poland effectively safeguard its democratic processes from evolving digital threats and ensure the integrity of its information environment.

Strengthen institutional oversight:

• Establish a permanent and well-resourced Digital Services Coordinator (DSC) for Poland: this is paramount for ensuring effective DSA implementation, robust oversight of platforms, and seamless cross-sector coordination in threat response.
• Enhance inter-institutional and cross-sector coordination: develop a permanent incident escalation system to facilitate real-time communication and intervention between government agencies, civil society, and platforms, extending beyond electoral cycles. This includes support for and coordination of initiatives such as the Polish Resilience Council, the Central European Digital Media Observatory (CEDMO), the Counter Disinformation Network, and the FIMI Information Sharing and Analysis Centre (FIMI-ISAC).

Enforce platform accountability and transparency:

1. Mandate robust systemic risk mitigation: hold platforms strictly accountable for assessing and mitigating systemic risks (per DSA Articles 34 & 35) to prevent interference.
2. Ensure ad transparency and verification: compel platforms to implement stringent advertiser identity verification (KYC) and immediately halt revenue streams to malign actors (per DSA Article 26 and Political Advertising Regulation).
3. Address platform vulnerabilities: mandate that platforms patch vulnerabilities like easy account creation for throw-away profiles and ensure consistent enforcement of political campaigning policies, with punitive measures for non-compliance.
4. Strengthen researcher data access: fully enforce DSA Article 40 to ensure transparent and rigorous data access for qualified researchers; crucial for analysing algorithmic behaviours and content virality.

Build national resilience:

1. Invest in comprehensive media and digital literacy: implement targeted, age-appropriate programmes to equip Polish citizens with critical thinking skills, fostering informed media consumption and addressing distrust in public institutions.
2. Sustain civil society funding: provide stable, long-term funding mechanisms for Polish civil society organisations to build capacity and institutional knowledge, ensuring their continued ability to counter systemic threats beyond electoral cycles.
3. Implement targeted accountability for domestic FIMI amplifiers: develop mechanisms for public attribution and other targeted responses to address domestic figures who knowingly disseminate or echo manipulative narratives, clarifying the line between legitimate political discourse and deliberate deception.

Notes:

1.  Contributors are researchers who have submitted alerts to the project but have not participated in the writing of this report. The report does not necessarily reflect the opinions of the contributors.
2. Info Ops Poland Foundation contributed with an alert on the murky ad campaign outlined on page 81, and the report on Russian narratives discrediting political candidates on page 20. Their researchers wish to remain anonymous.