Report March 2025

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Integrity of Services

Commitment 14

In order to limit impermissible manipulative behaviours and practices across their services, Relevant Signatories commit to put in place or further bolster policies to address both misinformation and disinformation across their services, and to agree on a cross-service understanding of manipulative behaviours, actors and practices not permitted on their services. Such behaviours and practices include: The creation and use of fake accounts, account takeovers and bot-driven amplification, Hack-and-leak operations, Impersonation, Malicious deep fakes, The purchase of fake engagements, Non-transparent paid messages or promotion by influencers, The creation and use of accounts that participate in coordinated inauthentic behaviour, User conduct aimed at artificially amplifying the reach or perceived public support for disinformation.

We signed up to the following measures of this commitment

Measure 14.3

In line with this commitment, did you deploy new implementation measures (e.g. changes to your terms of service, new tools, new policies, etc)?

If yes, list these implementation measures here

Do you plan to put further implementation measures in place in the next 6 months to substantially improve the maturity of the implementation of this commitment?

If yes, which further implementation measures do you plan to put in place in the next 6 months?

Measure 14.3

Relevant Signatories will convene via the Permanent Task-force to agree upon and publish a list and terminology of TTPs employed by malicious actors, which should be updated on an annual basis.

Logically Facts and Logically publish fact-checks and open-source intelligence (OSINT) investigations, respectively, to counter threat actors’ manipulative tactics, techniques and procedures (TTPs). As we do not conduct any policing actions, we do not have formal policies in place to address these. However, our publications can educate audiences on such TTPs, and equip stakeholders with the case studies needed to feed evidence-based policies.

Logically became a member of the Subgroup on the Integrity of Services in September 2023, and has subsequently attended and contributed to several meetings in the regular review of the list of TTPs.

QRE 14.3.1

Signatories will report on the list of TTPs agreed in the Permanent Task-force within 6 months of the signing of the Code and will update this list at least every year. They will also report about the common baseline elements, objectives and benchmarks for the policies and measures.

Examples of identified TTPs

Narrative control through messaging platforms and subsequent migration

In February 2023, we identified a French-language, cross-platform network targeting Africa being run by individuals affiliated with the Russian Government and uncovered “fringe actors” associated with the operation. In February 2024, we conducted further investigations into the network and found a particular member’s attempts to establish independence campaigns within the United States, with the backing of the Russian Government and PMC Wagner.

In September 2024, we conducted further investigations into the network. Logically assessed that the identified member, Andre Dembele, made a public Telegram channel private, detailing unprecedented levels of encrypted communications with individuals working in Russia and West Africa, members of PMC Wagner, and individuals affiliated with a bank operating an office in UK.

(For more details on migration tactics including the use of Telegram, please see the response to QRE 16.2.1 below)

Amplification of fringe sites for strategic objectives by hostile state actors

During the course of the violence in the United Kingdom in July and August 2024 that followed the tragic knife attack in Southport, Logically and Logically Facts published a number of reports assessing the spread of disinformation regarding the identity of the attacker. We identified a bogus news website, “Channel 3NOW” which published the supposed name of the attacker as part of an article that was then later cited by Russian state media as a source and amplified. The website’s details - such as its registrant being located in Lithuania while being based out of Pakistan and its regular cycling through another bogus news branding - and the flow of information in and out of the website resembles Russian approaches around information laundering and narrative dissemination. While it cannot be proven that “Channel 3NOW” was part of a larger foreign interference effort, its use by Russian state media to increase the circulation of disinformation that increased inter-ethnic tensions in the UK meant it functioned in a way advantageous to hostile states.

Non-transparent compensated messages or promotions by influencers

In March 2023, Logically carried out an investigation into the Russian “fact-checking” website “War on Fakes”. We were able to attribute the website to Timofey Vasiliev, a former Russian journalist who had not disclosed that he was a Russian state television presenter with widespread relationships to Russian influencers with over 1 million followers who promoted the page during its initial creation.
To conduct attribution, we reviewed changes that were made on the “WHOIS” registry of public available information about a given domain. The details on the site’s registration could be connected to War on Fakes, Vasiliev, and his ties to the Russian government and propagandist community. We made this connection by reviewing the name, phone number and email address of the corresponding accounts. A review of Vasiliev’s career dating back to 2011 also revealed several roles where Vasiliev was a known affiliate of groups associated with Russian propaganda e.g. the Russian propaganda outlet Ridus. We found information on his resume in the archive of his personal website, as well as through career histories available on the websites of organisations that Vasiliev has worked for.
Logically further identified two other initiatives that Vasiliev was actively engaged with at the time of our investigation - Klub5000 and SVO. The former sought to bring together monthly donors to vetted Russian military and civilian causes, and offered potential trips to the “Special Operation Zone”. The latter provided twice daily news updates of the biggest stories from the Russian government and the war in Ukraine. Given the lack of disclosure on the website about Vasiliev’s background, this can be considered a non-transparent promotion by an influencer.

Internal processes to better identify TTPs

As we reported in our Baseline Report of January 2023, we are also developing an end-to-end automated Coordinated Inauthentic Behaviour (CIB) identification system as part of our disinformation detection and reporting service, Logically Intelligence®, to assist human experts. The development of this system is progressing, and has been deployed to support OSINT experts delivering on commercial projects. Further plans to improve the CIB system’s efficacy through active learning are in progress.

We are also undertaking research on how to approach the detection of foreign information manipulation and interference via data science and machine learning. We aim to create a system that can be deployed alongside our expert teams. The deployment of this system would be governed by our ‘Human and Machine in the Loop Evaluation and Training’ (HAMLET) framework, which is intended to maximise machine-learning techniques by maintaining a human-in-the-loop capability.

Commitment 16

Relevant Signatories commit to operate channels of exchange between their relevant teams in order to proactively share information about cross-platform influence operations, foreign interference in information space and relevant incidents that emerge on their respective services, with the aim of preventing dissemination and resurgence on other services, in full compliance with privacy legislation and with due consideration for security and human rights risks.

We signed up to the following measures of this commitment

Measure 16.2

In line with this commitment, did you deploy new implementation measures (e.g. changes to your terms of service, new tools, new policies, etc)?

If yes, list these implementation measures here

Do you plan to put further implementation measures in place in the next 6 months to substantially improve the maturity of the implementation of this commitment?

If yes, which further implementation measures do you plan to put in place in the next 6 months?

Measure 16.2

Relevant Signatories will pay specific attention to and share information on the tactical migration of known actors of misinformation, disinformation and information manipulation across different platforms as a way to circumvent moderation policies, engage different audiences or coordinate action on platforms with less scrutiny and policy bandwidth.

Logically became a member of the Subgroup on the Integrity of Services in September 2023, and has subsequently attended and contributed to several meetings in the regular review of the list of TTPs.

QRE 16.2.1

As a result of the collaboration and information sharing between them, Relevant Signatories will share qualitative examples and case studies of migration tactics employed and advertised by such actors on their platforms as observed by their moderation team and/or external partners from Academia or fact-checking organisations engaged in such monitoring.

Misinformation actors adapt to moderation by shifting platforms, masking chatter - including the utilisation of written languages foreign to themselves, and exploiting policy gaps. This behavior is highly likely to persist as enforcement evolves and technologies shift. Key examples include:

Covid-19 Misinformation. Anti-vaccine groups, facing restrictions on Facebook and YouTube, almost certainly migrated to Telegram and Rumble, using coded language to bypass moderation.
QAnon Rebranding. Following their deplatforming in 2020, QAnon affiliates effectively rebranded as child protection advocates and moved to Gab, Parler, and Telegram.

4chan. The forum remains an attractive haven for hostile actors to migrate to once they have engaged with specific online communities. Boards such as /pol/ (politically incorrect) generate and refine extremist, conspiratorial, or harmful narratives, which become "ops" (operations), where users craft misleading or provocative messages, which then become memes, slogans, or fake news in order to make the narrative more shareable on mainstream social media.

State-Backed Disinformation. Russian actors highly likely shifted from Facebook to encrypted apps such as Telegram and fringe forums, using AI-generated personas. Cross-pollination has been observed between ok.ru, Telegram, and X.
Far-Right Extremism. After January 6th, groups such as the Proud Boys migrated to Rumble and Telegram, likely seeking to exploit weak moderation.
Climate Misinformation. Climate denialists likely moved to Substack and Medium, then used mainstream platforms to distribute misleading content.

Recommendations for the UK Government and Relevant Signatories

Cross-Partner Intelligence Sharing. UK agencies, tech firms, and fact-checkers should collaborate on tracking migration patterns, and share intelligence on threat actor TTPs in order to identify and disrupt narrative migration.
Behavioural Analysis. Encourage platforms to detect patterns of evasion, including coded language, proxy accounts, or inauthentic behaviours.
Public Awareness. Publish regular reports on hostile information campaign tactics to improve digital resilience, as well as run media literacy campaigns.
Stronger Platform Accountability. Encourage standardised moderation policies and transparent enforcement across traditional and social media platforms.
Policy Adjustments. Identify and close regulatory loopholes to ensure coverage of less-regulated platforms, or websites masquerading as local media sources.

Empowering Users

Commitment 17

In light of the European Commission's initiatives in the area of media literacy, including the new Digital Education Action Plan, Relevant Signatories commit to continue and strengthen their efforts in the area of media literacy and critical thinking, also with the aim to include vulnerable groups.

We signed up to the following measures of this commitment

Measure 17.2 Measure 17.3

In line with this commitment, did you deploy new implementation measures (e.g. changes to your terms of service, new tools, new policies, etc)?

If yes, list these implementation measures here

Do you plan to put further implementation measures in place in the next 6 months to substantially improve the maturity of the implementation of this commitment?

If yes, which further implementation measures do you plan to put in place in the next 6 months?

Measure 17.2

Relevant Signatories will develop, promote and/or support or continue to run activities to improve media literacy and critical thinking such as campaigns to raise awareness about Disinformation, as well as the TTPs that are being used by malicious actors, among the general public across the European Union, also considering the involvement of vulnerable communities.

QRE 17.2.1

Relevant Signatories will describe the activities they launch or support and the Member States they target and reach. Relevant signatories will further report on actions taken to promote the campaigns to their user base per Member States targeted.

Logically Facts partnered with TikTok to feature media literacy videos on their EU election hubs for Ireland, Sweden, Finland, Denmark, Cyprus, Slovenia, Estonia, Malta and Latvia, in order to better prepare users to identify misinformation during the European elections. Redirection to these hubs was triggered by keyword searches related to the elections. Once triggered, users’ interface would point them to credible sources of information, as well as media literacy videos produced by Logically Facts. Crucially, these videos corresponded to the relevant EU language(s) for each of the aforementioned Member States. The Danish example can be found here.

Logically Facts also partnered with TikTok to feature media literacy videos in the UK for the local elections in May and the general elections in July to help users on how to spot and counter misinformation. More info here for the general election hub and for the local election here

In 2024, Logically Facts’ fact-checkers led some courses on how to verify information online organised by the Swedish media institute Fojo:

A course called "Go Verify! How to become a professional fact-checker" with Fojo Media Institute for the Swedish section of Yle in Helsinki, Finland. The course, conducted between March 4 and 6, 2024, taught participants how to do fact-checks, how to use digital verification tools, and how disinformation is spread.

In April 2024, we held a training workshop about TikTok for the Swedish anti-racism magazine EXPO in Stockholm, Sweden. We covered security, how the app works and its features, how we can use the algorithm to our advantage, and specifically, how you can do investigations on the app.

A fact-checker from Logically Facts conducted a three-day fact-checking course with Fojo Media Institute in Kalmar, Sweden, between September 3 and 5, 2024, titled “Verify this—How to become a professional fact checker."

In November, our Swedish fact-checkers were in Kalmar at the Swefactcheck conference "Media, power, and manipulation in a time of Generative AI," organized by the Fojo Media Institute. They led a session called "Fact-checking the Super election year: Our experiences and conclusions."

The head of Editorial Operations in UK and Europe was invited as a guest lecturer at City University in London in November to talk about how to use social media platforms as news gathering sources and how to fact-check the content online.

The Editorial team of Logically Facts has contributed to a series of ethical journalism training programs that Impress, an independent press regulator in the UK, is putting together for the public. We have been interviewed for the topics on mis and disinformation, fake news and social media, disability and principles of ethical reporting.

Measure 17.3

For both of the above Measures, and in order to build on the expertise of media literacy experts in the design, implementation, and impact measurement of tools, relevant Signatories will partner or consult with media literacy experts in the EU, including for instance the Commission's Media Literacy Expert Group, ERGA's Media Literacy Action Group, EDMO, its country-specific branches, or relevant Member State universities or organisations that have relevant expertise.

QRE 17.3.1

Relevant Signatories will describe how they involved and partnered with media literacy experts for the purposes of all Measures in this Commitment.

Logically Facts has worked very closely with the Fojo Media Institute in Sweden to conduct courses to help journalists fact-check content online.

Permanent Task-Force

Commitment 37

Signatories commit to participate in the permanent Task-force. The Task-force includes the Signatories of the Code and representatives from EDMO and ERGA. It is chaired by the European Commission, and includes representatives of the European External Action Service (EEAS). The Task-force can also invite relevant experts as observers to support its work. Decisions of the Task-force are made by consensus.

We signed up to the following measures of this commitment

Measure 37.1 Measure 37.3 Measure 37.4 Measure 37.5 Measure 37.6

In line with this commitment, did you deploy new implementation measures (e.g. changes to your terms of service, new tools, new policies, etc)?

If yes, list these implementation measures here

Do you plan to put further implementation measures in place in the next 6 months to substantially improve the maturity of the implementation of this commitment?

If yes, which further implementation measures do you plan to put in place in the next 6 months?

Measure 37.6

Signatories agree to notify the rest of the Task-force when a Commitment or Measure would benefit from changes over time as their practices and approaches evolve, in view of technological, societal, market, and legislative developments. Having discussed the changes required, the Relevant Signatories will update their subscription document accordingly and report on the changes in their next report.

QRE 37.6.1

Signatories will describe how they engage in the work of the Task-force in the reporting period, including the sub-groups they engaged with.

We joined the Working Group on Elections, represented by our Head of UK/EU Fact-Checking. This

involved:

Attending our Working Group Meetings from January to December 2024.
Contributing to the review of the template for reporting on elections and the Rapid Response System (RRS).
Attending RRS election meetings.

We continued to be part of the Subgroup on the Integrity of Services, represented by our Director of AI Research and

Solutions. This involved:

Attending Subgroup meetings;
Monitoring for new tactics, techniques and procedures (TTPs) that should be accounted for in
the obligations set out in Commitment 14.

We continued to be part of the Subgroup on the Empowerment of Fact-Checkers, represented by Logically’s

Vice-President of Fact-Checking, who is also Managing Director of Logically Facts. This involved:

Attending Subgroup meetings;
Contributing to discussions on the governance side of the proposed repository of fact-checking content.

We had also been part of the Subgroup on Generative AI as a co-chair, represented by our Senior Government Affairs Manager for the EU and UK.

Monitoring of the Code

Commitment 38

The Signatories commit to dedicate adequate financial and human resources and put in place appropriate internal processes to ensure the implementation of their commitments under the Code.

We signed up to the following measures of this commitment

Measure 38.1

In line with this commitment, did you deploy new implementation measures (e.g. changes to your terms of service, new tools, new policies, etc)?

Yes

If yes, list these implementation measures here

Logically Facts has also adopted by-laws to cement its editorial independence from other parts of the organisation, and enforce its non-partisanship policy (these can be found at the end of the Ethics and Transparency page here).

Do you plan to put further implementation measures in place in the next 6 months to substantially improve the maturity of the implementation of this commitment?

If yes, which further implementation measures do you plan to put in place in the next 6 months?

Measure 38.1

Relevant Signatories will outline the teams and internal processes they have in place, per service, to comply with the Code in order to achieve full coverage across the Member States and the languages of the EU.

QRE 38.1.1

We have maintained the number of team members co-authoring this report and overseeing Logically’s overall compliance with the Code since the publication of our previous report. The designated staff with these

responsibilities have been:

The Senior Government Affairs Manager (EU/UK)
The Senior Corporate Affairs Manager (Global)
The Director of AI Research and Solutions
The Head of UK/EU Fact-Checking
The Global Head of Fact-Checking
The Vice-President of Fact-Checking

Our internal processes to ensure compliance with the Code included:

Verification of documentation on the company’s communal Google Drive and Confluence workspaces (particularly the folders relating to our applications to and status as a verified signatory of the International Fact-Checking Network (IFCN)) to ascertain existing compliance;
Organising meetings with the European Commission to confirm our understanding of how to contribute to the work of relevant Subgroups;
Integrated systematic collaboration between the Corporate Affairs team and Logically Facts via monthly coordination meetings;
Liaising with Logically’s OSINT investigators and Logically Facts’ editorial teams to obtain the research methodologies and outcomes required to fulfil Commitments 14, 16 and 29;
Updating the company’s ethics and transparency policies and implementing new by-laws for Logically Facts;
Maintaining compliance with the IFCN Code of Principles, which is compatible with the requirements of Commitment 33. All Logically staff are trained in our ethics and transparency policies upon commencing their employment, and all ethics and transparency processes are documented on the company’s shared online workspace.

Commitment 39

Signatories commit to provide to the European Commission, within 1 month after the end of the implementation period (6 months after this Code’s signature) the baseline reports as set out in the Preamble.

We signed up to the following measures of this commitment

In line with this commitment, did you deploy new implementation measures (e.g. changes to your terms of service, new tools, new policies, etc)?

If yes, list these implementation measures here

Do you plan to put further implementation measures in place in the next 6 months to substantially improve the maturity of the implementation of this commitment?

If yes, which further implementation measures do you plan to put in place in the next 6 months?