How Big Tech Shaped the EU’s Fight Against Disinformation: A Process-Tracing of Structural Asymmetries in EU Digital Policy

This article addresses the EU’s prolific regulatory activity in the digital sphere in order to explain the regulatory outcomes to tackle disinformation, mostly anchored in ‘co-regulation’. While the prominence of Big Tech lobbyists in EU digital governance is widely acknowledged, the precise mechanisms through which these companies’ lobbyists influence policy remain insufficiently understood. This paper asks: how the adoption of a mostly co-regulatory outcome relates to the involvement of external actors in the policymaking process 2018-2024. Through a process-tracing design supported by evidence from a multi-method design – framing and network analysis and QCA - we argue that the early agenda-setting stage was decisively shaped by the work of the 2018 High-Level Expert Group (HLEG) and the first Code of Practice on Disinformation. These institutional venues facilitated the entrenchment of platform-friendly narratives while marginalising more critical perspectives. Our analysis shows how initial framing choices created an ideational and institutional context that structured the entire policy process, making it difficult for alternative or more transformative demands to gain traction. We examine how secondary actors adapted their strategies in response, often moderating their claims to fit within the dominant framework. Ultimately, EU regulatory outcomes reflect the cumulative effect of Big Tech’s framing power within a contested but asymmetrical policy field.