FIMI as part of Russian war machine: Ukraine’s fight

A key aspect of Ukraine’s situation is the need to combat hostile narratives and misinformation while maximizing the effectiveness of strategic communication tools.

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Ukraine presents a distinctive case in countering Foreign Information Manipulation and Interference (FIMI), where addressing information threats is integral to countering Russia’s open military aggression. A key aspect of Ukraine’s situation is the need to combat hostile narratives and misinformation while maximizing the effectiveness of strategic communication tools. The success of these efforts heavily relies on support from international partners across political, diplomatic, military, and financial spheres. To survive, Ukraine must engage effectively with four target audiences: the population in government-controlled territory, Ukrainians in occupied areas, and communication with international partners and non-Western countries.

 
Authors:
  • Hennadiy Maksak, Executive Director, Foreign Policy Council “Ukrainian Prism”
  • Olga Chyzhova, Head of Brussels Office, Foreign Policy Council “Ukrainian Prism”

 

This report has been prepared with support from IRI’s Beacon Project. The opinions expressed are solely those of the author and do not reflect those of IRI.Content

 

  • Executive Summary
  • Recommendations to fill the gaps in countering FIMI
  • Introduction to the topic of countering FIMI on national level
  • Ensuring sovereignty of Ukrainian information space before the full-scale war
  • Ukraine’s institutional setup for countering and analyzing
  • Parliament’s role in dealing FIMI: division of functions
  • Legislative framework for countering information threats
  • Evolution and dynamics of analyzing, reporting on and countering FIMI
  • Key hostile narratives employed by Russia against Ukraine and the West
  • Gaps used by the hostile actors
  • Countering Russian proxies inside Ukraine
  • Outlook for future risks and responses
  • New battlefields of the war of narratives
  • Addressing sore spots
  • Is AI a game-changer: opportunity or a threat?
  • Uniting efforts: Ukraine and the EU against FIMI
  • In search of better orchestrated response
  • Coalitions matter
  • MPs at the forefront of the fight against FIMI
  • Conclusions and recommendations
  • Recommendation for Ukraine
  • Recommendations for the EU

 

 

Executive Summary 

Ukraine presents a distinctive case in countering Foreign Information Manipulation and Interference (FIMI), where addressing information threats is integral to countering Russia’s open military aggression. A key aspect of Ukraine’s situation is the need to combat hostile narratives and misinformation while maximizing the effectiveness of strategic communication tools. The success of these efforts heavily relies on support from international partners across political, diplomatic, military, and financial spheres. To survive, Ukraine must engage effectively with four target audiences: the population in government-controlled territory, Ukrainians in occupied areas, and communication with international partners and non-Western countries.

The primary malign narratives that Ukraine faces from Russian information aggression predominantly focus on undermining support for the kinetic war. These campaigns aim to challenge Western military and financial assistance, instill fear in Ukrainians, provoke distrust for public authorities, and question partners’ ability to maintain support. These issues will remain prominent in the foreseeable future, especially in the context of a protracted war of attrition.

The strategy for winning the information war was established before the onset of full-scale aggression, with establishment of the main institutional framework and strategic documents regarding information security and cybersecurity. A significant achievement was Ukraine’s separation from the Russian information space prior to the war, creating a barrier against the direct dissemination of Kremlin narratives through Russian media. This was accomplished through various restrictive measures, including banning Russian TV channels, prohibiting Russian films, blocking access to Russian social networks and internet services, and shutting down three Ukrainian channels linked to Moscow. Simultaneous introduction of quotas for Ukrainian content on television and radio also played a crucial role.

The year 2021 was pivotal with the establishment of two specialized agencies: the Center for Countering Disinformation under the National Security and Defense Council, and the Center for Strategic Communications and Information Security under the Ministry of Information Policy.

The full-scale aggression has demonstrated Ukraine’s resilience to hostile information influences and highlighted the maturity of civil society in collaborating with the state. Businesses have also been proactive, providing government specialists with leading software for monitoring the information landscape and identifying threats at no cost.

However, the prolonged nature of the war has exposed weaknesses in Ukraine’s infrastructure for countering informational influences. The focus shifted to informal practices of coordinating a strategic communication network with the leading role of the President’s Office at the level of advisors. These advisors have no formalized functions, no responsibility and no accountability.

Since February 2022, the Ukrainian Parliament has had to respond swiftly to the rising scale of information threats by laying the legal basis for countering FIMI. Measures included protecting the information space through new regulations and identifying Russism (or  Russian fascism, ideology and policies of the Russian state under Vladimir Putin, based on three pillars: Russian imperialism and chauvinism, the traditions of the communist regime of the USSR, and National Socialism, which was condemned by the Nuremberg Tribunal) and Russian propaganda as core prerequisites for aggression and war crimes. Special attention has also been devoted to increasing accountability for crimes in the information domain.

Building on Ukraine’s integration track, an essential part of the legislative framework, the Law on Media, was adopted in the fall of 2023. This law introduced standards aligned with the Digital Services Act and strengthened the regulatory framework for countering FIMI stemming from Russia.

A continuing challenge that requires legislative attention is the uncontrolled use of the Russian social platform Telegram. Its anonymized content and direct access to Russian propaganda and disinformation pose a serious threat to national security, especially since over 70% of Ukrainians rely on Telegram as their primary news source. The sensitivity of the issue is also connected to the fact that many state and local institutions, politicians and media own official and anonymous Telegram channels. First steps to mitigate the threat was taken by the National Coordination Centre for Cybersecurity (NCCC), a key body for coordination and control in the field of cybersecurity. On 19 September the NCCC has decided to restrict the use of Telegram in government agencies, military formations, and critical infrastructure facilities. 

On the other hand, to effectively disrupt Russian information influence, responsible agencies need legislative changes that will define key terminology related to FIMI and facilitate the precise qualification of related crimes.

Despite some gaps in developing the system for countering information threats, Ukraine demonstrates remarkable resilience and an intersectoral approach to the issue. However, both on the battlefield and in the information space, Ukraine requires stable and effective support from international partners. Significant progress has been made in cybersecurity and establishing coordination with EU and NATO Stratcom teams. Information security is also part of the bilateral security agreements Ukraine concludes with partners. While examining the Ramstein format in military cooperation (the Ukraine Defense Contact Group, also known as the Ramstein Group, is an alliance of over 50 states supporting the defense of Ukraine by sending military equipment in response to the 2022 Russian invasion), Ukrainian counterparts propose more ambitious initiatives to coordinate a joint approach to countering Russia’s FIMI by pooling and sharing expertise, best practices, and developing joint early warning and assessment mechanisms.

At the same time, the role of the EU in supporting Ukraine and shaping relevant legislation is invaluable. Ukraine is already adopting EU norms to create a secure information environment. Some initiatives may involve multilateral or regional formats that may include candidate states from Eastern Europe and the South Caucasus.

Recommendations to fill the gaps in countering FIMI

  • Legislative work in Ukraine must result in the creation of a comprehensive institutional and regulatory environment to counter FIMI. The positive effects of the Law on Media and the Law on Advertising demonstrate the need for a specific legislative act that includes legal definitions of FIMI terminology and rules and procedures to deal with social platforms.
  • While the Ukrainian secret services are well-placed to tackle disinformation and counter Russian narratives, the government must do more to create and support a One Voice policy, unified position in communication of state institutions and civil society. A hierarchy of procedures for strategic communication must be established, while preserving the of-the-society approach to countering the malign information activity of Russia. 
  • The EU is the benchmark for crafting a regulatory environment for the information space. Brussels must take a firm stance on sharing the EU’s toolkit for candidate states, including Ukraine, Moldova and eventually Georgia.
  • The EU must reconsider its approach to regulating artificial intelligence in light of lessons learned from the battlefield in Ukraine. Self-limitation in utilizing AI in areas of defense and security, including in information space, will eventually lead to the dominance of Russia, China and other autocratic and hostile actors.

 

Introduction to the topic of countering FIMI on national level

 

Ensuring sovereignty of Ukrainian information space before the full-scale war

The occupation of Crimea and the onset of the Russo-Ukrainian war in 2014 starkly highlighted the vulnerabilities in Ukraine’s information space, prompting Kyiv to implement immediate and practical restrictive measures in response to Russia’s blatant information aggression.

By March 2014, Ukraine began temporarily banning the broadcasts of Russian TV channels. The legal foundation for these initial restrictions stemmed from decisions made by the Kyiv District Administrative Court, following claims from the National Council on Television and Radio Broadcasting. These channels were accused of crimes against the state, including the promotion of war and incitement of separatism and ethnic hatred. Subsequently, the National Council started publishing lists of stations that violated Ukrainian law and the European Convention on Transfrontier Television, which were to be banned from broadcasting in Ukraine. By 2017, this list included 77 Russian channels restricted from cable networks.

In February 2015, amendments to the Law of Ukraine on Cinematography were introduced, prohibiting the screening of all films produced in Russia and released after January 1, 2014. Additionally, new legislation banned the distribution and screening of films that promoted institutions of the aggressor state (which, in Ukraine, solely refers to Russia) as well as Soviet security institutions (like the Cheka, OGPU, NKVD, KGB, etc.).

Concurrent with these efforts, measures were implemented to promote the use of the state language in media. In 2013, Ukrainian-language content accounted for only about 16% of broadcasts. In 2016, quotas were gradually introduced for songs and programs in Ukrainian on the radio. In 2017, quotas for TV stations were established: 75% of content in the state language for national and regional channels, 60% for local channels, and 75% for TV news programs. Starting January 2024, legislation mandates that up to 90% of programming on TV must be in Ukrainian.

In April 2017, the National Security and Defence Council of Ukraine placed Russian companies such as VKontakte, Odnoklassniki, Mail.ru, Yandex, and Kaspersky Lab on sanctions lists. This decision was enacted by a Presidential Decree in May 2017, requiring internet providers in Ukraine to block access to these websites.

In February 2021, as part of the sanctions policy, the President enacted a Decision from the National Security and Defense Council to block three Ukrainian TV channels — 112, NewsOne, and Zik. These media outlets were believed to be owned by Viktor Medvedchuk, who has close ties to Russian President Vladimir Putin. The channels have been identified by media monitors as responsible for spreading over 50% of pro-Russian disinformation in Ukraine.

These measures have substantially dismantled the infrastructure for Russian information influence in Ukraine. Thus, before the full-scale war, Ukraine was finally detached from the Russian information space for the first time since gaining independence. Manipulative narratives could no longer be directly disseminated in Ukraine through Russian media. 

Simultaneously, the National Security and Defense Council tasked the Ukrainian government and state institutions with drafting conceptual documents. In February 2017, the Information Security Doctrine was adopted, followed by the Information Security Strategy in 2021. Both documents define the fundamental principles and guidelines, outline Ukraine’s national interests in the information sphere, identify threats to implementation, and establish the directions and priorities of state policy. However, they have not formed a robust normative system for building information security. Ukrainian state institutions in practice do not take these documents into account in their planning activities in the information security domain.

Following a series of cyberattacks on the telecommunication systems of state institutions, Ukraine adopted the Cybersecurity Strategy. This legal framework was later translated into the Law of Ukraine on Cybersecurity in September 2017, with a new Cybersecurity Strategy enacted in 2021.

Ukraine’s institutional setup for countering and analyzing

The Information Security Strategy, adopted in 2021, outlines the state actors and institutions involved in countering and analyzing FIMI, along with their respective responsibilities:

  • The National Security and Defense Council of Ukraine
  • The Cabinet of Ministers of Ukraine
  • The Center for Countering Disinformation
  • The Ministry of Information Policy
  • The Ministry of Foreign Affairs of Ukraine
  • The Ministry of Defense of Ukraine
  • The Security Service of Ukraine
  • The intelligence agencies of Ukraine
  • The National Council of Ukraine on Television and Radio Broadcasting

Interestingly, the document does not mention the Ministry of Information Policy, which is the central executive body responsible for ensuring Ukraine’s information sovereignty and security. The Ministry has undergone several transformations, with changing functions. Established in 2015, it was abolished in 2019, revived and merged in 2020 as part of the Ministry of Culture and Information Policy, and was finally renamed the Ministry of Culture and Strategic Communication on September 6, 2024. A new minister was appointed after the position had been vacant for over a year. Mykola Tochytsky, a career diplomat who previously served as Deputy Chief of the Presidential Office and Deputy Minister for Foreign Affairs, now leads the Ministry. The new functions and vision for the Ministry, particularly its role in countering FIMI, have yet to be defined.

In practical terms, two state institutions have become particularly visible in their activities, both established almost simultaneously: one under the then-Ministry of Culture and Information Policy and the other under the National Security and Defense Council.

The Center for Strategic Communication and Information Security, created under the Ministry, serves as one of the mechanisms to counter disinformation through collaborative efforts of the state and civil society. Its focus is on strategic communication to counter external threats, particularly information attacks from the Russian Federation. The Center operates in three areas: strategic communication, combating disinformation and enhancing resilience to it, and conducting information campaigns. Its activities are public and target Ukrainian, Russian, and foreign audiences.

The Center for Countering Disinformation operates as a working body of the National Security and Defense Council of Ukraine, which grants it specific legal status, resources, technical capabilities, cooperation with all executive authorities, and access to state secrets. This Center is responsible for implementing measures to counter current and anticipated threats to national security and interests in the information space, ensuring Ukraine’s information security, identifying and countering disinformation, combating propaganda and destructive information influences, and preventing attempts to manipulate public opinion. The Center focuses exclusively on external information threats to national security. Following the onset of full-scale Russian aggression against Ukraine, it has effectively become a “state fact-checker,” producing an “information picture of the day” that reflects the state’s position on ten key topics. The Center monitors various social networks, as well as 156 foreign internet resources and 812 individuals who spread disinformation in Ukrainian, Russian, German, and English. It is also responsible for blocking 200 YouTube channels and 24 TikTok accounts in Ukraine for violating Ukrainian law.

The role of security sector institutions in countering FIMI is particularly critical during wartime. Since the escalation of full-scale aggression, the typically discreet operations of these services have become more public. A successful example is the campaign by the Defense Intelligence of Ukraine, which publishes intercepted phone calls of Russian soldiers to their families.

At the very beginning of full-scale aggression in order to guarantee a reliable source of information broadcasted live around the clock, Ukrainian authorities launched the initiative #UAtogether which was morphed into Theleton United News. This initiative united private media groups, public broadcaster and state TV channel Rada. Producing join media content also shielded Ukrainian population from the distorted information as well as open phycological operations that were targeted at Ukrainian media space.

Another key institution not mentioned in strategic documents, but influential in this sector, is the Office of the President. At the level of advisors, whose functions are not formalized, the Office informally coordinates and oversees activities in the field, sets narratives, identifies focal points, and highlights key topics. However, formal coordination among institutions responsible for countering FIMI is extremely limited, with no designated institution or official responsible for coordination. Additionally, the practice of holding coordination meetings at the Office of the President has been discontinued.

Parliament’s role in dealing FIMI: division of functions

Following the formation of the new Verkhovna Rada of Ukraine in 2019, parliamentary committees were established. Among the committees that address areas related to the fight against FIMI are:

  • The Committee on Humanitarian and Information Policy
  • The Committee on National Security, Defense and Intelligence
  • The Committee on Freedom of Speech
  • The Committee on Digital Transformation

The current composition and structure of the Verkhovna Rada have been preserved, as no parliamentary elections are possible in Ukraine under martial law.

Within this framework, the division of functions and activities among the committees takes into account the priorities of wartime parliamentary activity. The core parliamentary body responsible for creating a legal framework to counter FIMI is the Committee on Humanitarian and Information Policy, chaired by a representative of the pro-president political party, “Servant of the People.” However, there is no clear inter-committee coordination mechanism to guide the process of countering disinformation and hybrid threats.

The Digital Transformation Committee has an official mandate to communicate with Big Tech companies, which is closely related to the administration of social media platforms used for spreading malign information. Meanwhile, the Committee on Freedom of Speech is focused on the rights of journalists and media representatives, the regulation of media content, and combating synthetic content produced by foreign actors using AI or bot farms.

The Committee on National Security, Defense and Intelligence, as the primary parliamentary body in the areas of security and defense, addresses counteracting FIMI through the development of sanctions policy. However, given the committee’s heavy workload with defense-oriented issues, it is difficult to expect deeper involvement in FIMI-related matters.

While it is important to highlight the parliamentary dimension of fighting FIMI, attention should also be paid to the fact that the parliament itself can be a target of foreign information attacks. Recent FIMI campaigns aimed at the Verkhovna Rada and its members are connected to their legislative activities. For instance, active psychological operations have been detected during the adoption of the Law on Mobilization and the Law “On Protection of the Constitutional Order with Regard to the Activities of Religious Organizations.” Additionally, some personal informational attacks have been directed at active MPs who are leading the fight against FIMI.

Legislative framework for countering information threats

From the onset of the current convocation in the Verkhovna Rada of Ukraine (VRU) in 2019, a lot of attention of the parliament was devoted to the issues of information policy and creative conducive preconditions for countering FIMI.

There were several prerequisites for the parliament’s active involvement in shaping the legislative framework for combating FIMI. Firstly, the majority in the parliament was formed by the ruling political party, which allowed decisions to be made without extensive political debate. Secondly, some of the decisions in this area were introduced in the previous convocation. This showed the direction of movement, as well as the priority areas.

But the foundation was laid with the beginning of Russia’s full-scale invasion of Ukraine. In this context, it is worth noting that several initiatives have laid the groundwork for the current legal framework. In March 2022, the Verkhovna Rada also took steps to increase responsibility and punishment for crimes in the information sphere related to Russia’s aggression. In particular, amendments were made to the Criminal Code of Ukraine. An article was added on ‘Justification, recognition as lawful, denial of the armed aggression of the Russian Federation against Ukraine, glorification of its participants’. Since then, law enforcement agencies have been conducting thousands of proceedings that fall under the forms of crimes described in the article, including producing and disseminating relevant information materials. 

In May 2022, the Law ‘On the Prohibition of Propaganda of the Russian Nazi Totalitarian Regime, the Armed Aggression of the Russian Federation as a Terrorist State against Ukraine, and the Symbols of the Military Invasion of Ukraine by the Russian Nazi Totalitarian Regime’ was adopted. Although the legislative initiative came from MPs, the President of Ukraine also offered its proposals. This legislative act, in particular, prohibits the dissemination of information aimed at supporting or justifying the criminal nature of the activities of the Russian Federation; publicly deny, including through the media or the Internet, the criminal nature of the armed aggression of the Russian Federation against Ukraine; publicly use the symbols of the military invasion of Ukraine by the Russian Nazi totalitarian regime.

Subsequently, the topic of countering Russia’s hybrid influence was deepened and clarified in the VRU resolution ‘On the use of the ideology of russism by the political regime of the Russian Federation, condemnation of the principles and practices of russism as totalitarian and human-hating’. This act was adopted in May 2023 and focuses on defining racism, or Russian fascism, as a criminal ideology that, through war and expansion, encourages Russians to commit violations of international law, war crimes and crimes against humanity.

In parallel, the parliament focused on developing a modern regulatory framework that would also create mechanisms to counter FIMI. In this context, it is worth mentioning the adoption of the Law on Media. This legislative act is one of the requirements of the European Commission on the way to opening negotiations on Ukraine’s accession to the EU. To a large extent, the law is based on the implementation of the Digital Service Act (DSA) developed by the European Union. Article 7 of the Law on Media contains a list of topics that contribute to the protection of the information field in Ukraine. However, this large document also contains a separate section on the specifics of media regulation in the context of armed aggression. The Parliament proposes a number of restrictions and additional regulation of the media, which is conditioned by the requirements of martial law and countering manifestations of aggression in the information space.   

In May 2023, the Law on Advertising was amended. According to the innovations, it is a violation of the law to cover the activities of the authorities of the aggressor state (occupying state) in information and analytical materials without a message about the status of the aggressor state.

In August 2024 in order to prevent hybrid aggression through religious channels the Law “On Protection of the Constitutional Order with regard to the Activities of Religious Organizations” was adopted against the backdrop of intensive FIMI, employed by the Kremlin with the aim to prevent it from happening.

 

Evolution and dynamics of analyzing, reporting on and countering FIMI 

 

Key hostile narratives employed by Russia against Ukraine and the West

Russian narratives are designed to underpin kinetic aggression in Ukraine, influencing difference facets of Ukraine’s domestic agenda, its resilience and state of play in defense and security sector as well as discrediting Ukraine in the eyes of international partners. Providing that war has started in 2014, some of the narratives used previously by Kremlin, evolved since 2022. Ukrainian agencies involved in countersign FIMI constantly monitor the information space both in Ukraine and broad and identify the core topics actively employed by Russian actors.

There are four main audiences which are addressed differently in terms of channels and narratives:

  • Ukrainians on the government-controlled territory;
  • Ukrainians on the occupied territories;
  • Western partners of Ukraine;
  • non-Western regions of the World (widely addressed to as Global South).

In aggregated form, the following topics are rated as most frequently used by Russian propaganda machine:

  1. Ukraine loses on the battlefield, while Russia demonstrates big success in occupying new Ukrainian cities and agglomerations;
  2. Ukraine warmongering state, unable to seat at the negotiation table presenting unrealistic demands in Peace Formula;
  3. Mobilization in Ukraine has failed;
  4. Instigating anti-Western sentiments including territorial disputes with neighboring countries, lack of military support, and interest of the Western countries in continuation of the war;
  5. Military assistance from partners is poor, inefficient, does not result in successes on the battlefield;
  6. Corruption is endemic in Ukraine and totally paralyzes the work of state institutions, all assistance is stolen by corrupt officials;
  7. Ukraine is a failed state, presenting Ukrainian authorities as incompetent, bogged in internal conflicts, including personal attacks on the President and top officials. Since May 2024 new narrative is actively injected in Russian FIMI claiming Zelenskyy’s power illegitimate since no elections were held;
  8. Russia is being portrait as a strong state largely unhurt by sanctions, having enough human and military resources to outlast Ukraine and the West;
  9. Europe is in peril, because of ill-thought decision of western leaders, war can easily spill over to the rest of Europe;
  10. Democracy is a threat to traditionalist societies.

 

Gaps used by the hostile actors

Fighting FIMI is an integral part of countering Russian aggression in Ukraine, as the Kremlin’s information operations aim to undermine the Ukrainian statehood itself. The steps already taken by government agencies and civil society form the legal environment and institutional framework for countering it. However, the severity of the challenges Ukraine faces requires additional legislative and organizational measures.

The fight against FIMI in Ukraine is inseparable from the need for strategic communication. Such communication should target 4 different audiences: 1) Ukrainian society inside the country 2) the population in the Russian-occupied territories 3) partners supporting Ukraine 4) non-Western countries. Against this background, there is a need for internal synchronization of the work of all agencies involved in the implementation of the information policy.

The “One Voice” policy, which was attempted to be developed at the government level in recent years, does not show the expected results. At present, the Cabinet of Ministers is not a hub for collecting, verifying and disseminating information to target groups. This is partly a result of the informal dominance of the Office of the President of Ukraine in decision-making process. For example, major initiatives on sanctions, implementation of the Peace Formula and cooperation with the United States are coordinated directly by the Head of the Office of the President, Andriy Yermak, and his deputies.

The work of the relevant ministries, particularly the Ministry of Defense, also shows inconsistencies in the development of strategic communication both on internal and external tracks. A striking example is the poor information support for the adoption of the new law on mobilization, which led to a significant public outcry.

The absence of one coordination center leads to a duplication of functions between different bodies and reduces their effectiveness. Small illustration is that two most active agencies, Center for Strategic Communication and Information Security and Center for Countering Disinformation, have no clear-cut separation of their functions and areas of responsibility. In practice, it means that each institution determines its own portfolio and action plan that can overlap with the other’s.

It is also noteworthy that in many state institutions strategic communication is left to consultants and freelance specialists. This practice can help to attract highly qualified external specialists, but it can also have a negative impact on institutional capacity. Experts point to the poor performance of press services, which do not respond to media requests for direct comments or interviews. Some ministers show self-censorship in public appearances. 

At the legislative level, there are also gaps that require additional work by the Parliament. Despite the progressive nature of media and advertising laws, law enforcement agencies still do not have sufficient tools to counter hostile influence on the information space. For example, the terms FIMI, disinformation, propaganda, bot, bot farm, synthetic content, etc. need to be defined by law. This will help in the legal qualification of crimes and the selection of appropriate punishments.

There is also a need to regulate the activities of social networks that do not fall under the category of mass media. The fact that the unregulated activities of the Telegram social network pose a threat to national security is the subject of lengthy discussions. At the same time, the sensitivity of the issue may be explained by the fact that many state institutions use Telegram in formal and informal ways to communicate their position and steer public debate.

The dilemma of freedom of speech and military censorship has not been resolved, leading to a distortion of the information space and the risk of harm to the armed forces. On the one hand, it is an issue of operational security not to disclose to adversary sensitive information about tactics and strategy of the Armed Forces. After 10 years of war Ukrainian lawmakers consider the example of Israel, where  journalists working with the army have to submit their materials to the censorship committee for review. On the other hand, there’s strong media community in Ukraine argues that any restrictions are harmful for the freedom of speech and creates venue for abuse of power.

Limiting access of Ukrainian citizens to Russian content proved to be effective and mostly protects Ukrainian information space from massive information attacks. But at the same some Russian narratives appear in Western outlets, and access Ukrainian media from there.

Media literacy courses have not become an official part of Ukrainian education system at any stage. Currently, only some experimental pilot programs have been introduced in several secondary schools across country. Which also brings to the service to question of coordination between different governmental bodies, in this case: the Ministry of Culture and Strategic Communication and the Ministry Education.

 
Countering Russian proxies inside Ukraine

With the start of the full-scale aggression in became obvious that some restrictive measures should be applied inside the country regarding political institutions with strong connection to aggressor state. Based upon the evidence documented by Ukrainian law enforcement agencies in 2022, the Decree of the President banned the activities of the pro-Russian parliamentary party “Opposition Platform – For Life”. The party openly transmitted the official position of the aggressor country towards Ukraine on the level of its leadership and members. In total, 13 pro-Russian parties have already been banned by Ukrainian courts.

Apart from partisan dimension, the crucial influence in information domain was realized through Russian Orthodox Church. In August 2024,The Ukrainian Parliament has adopted a bill banning religious organizations in Ukraine that are linked to Russia. The law also stipulates that church organizations dependent on Russia will not be able to use state and municipal property. Such effort should limit Russian special services’ influence, with for decades was covered behind freedom of religion.

 

Outlook for future risks and responses

New battlefields of the war of narratives

As the Russo-Ukrainian war drags on, we can expect Russia to devote significant resources in Western countries to negatively influence the level of public support for Ukraine. The current trend is vividly illustrated by the regional elections in the Eastern German states of Thuringia and Saxony, where the far-right Alternative for Germany (AfD) party has taken the lead. One of its election slogans is to stop arms supplies to Ukraine.

Also in the short term, against the backdrop of the presidential elections in the United States, the Kremlin will focus on producing messages about red lines and nuclear escalation, calling on the new US administration to reduce its support for Ukraine. To this end, many already traditional narratives can be used, including “Ukraine is a failed state”, “corruption is endemic in Ukraine”, etc. The relatively new narrative that President Zelenskyy is the illegal leader will also be actively circulated.

In the run-up to the second peace summit, now being prepared for the end of the year, the Kremlin will be looking for all possible channels to discredit the idea of the 10-point Peace Formula in non-Western regions of the world. Here, we can expect to see greater convergence between Russia and China in proposing alternative peace initiatives that have nothing in common with a just and stable peace. 

At the same time, anti-Western rhetoric will also be used by Russian side, aiming at slowing down military supplies and other kind of support to Ukraine.

Provided that communication with international partners is one of the prime tasks for Ukrainian StratCom teams, relevant bodies are focused on intensifying consultations on arms deliveries and countering Russian narratives targeting the level of support. To motivate partners involvement, Ukrainian leadership  has to come up with asymmetric and creative steps. A recent example is Kursk operation, which among political and military objectives also served for communication purposes. President Zelensky himself confirmed that the operation launched by Ukrainian armed forces on the territory of Kursk oblast of Russia was also leveling the increase of military assistance to Ukraine and debunking myths about Russian red lines and invincibility of Russian army.

At the state level, Ukrainian leadership is concentrated on securing the flow of weapons and ammunition to Ukraine. In the recent case during the reshuffle of the governmental team in September 2024, new Foreign Minister A. Sybiga has declared that provision on praters’ military support in the main task for Ukrainian diplomats. During official meetings of the president with his foreign counterparts, the issue of support of Ukrainian armed forces and defense industries is one of the core messages. Periodic meeting of Ukraine Defense Contact Group (known as Ramstein) also demonstrate straight forward and assertive position on forging military partnerships within the format of capability coalitions as well as bilateral track.

On societal level, even in 2024, on the third year of full-scale aggression, the opinion poll agencies register that Ukrainians appreciate the support provided by international partners, and most are convinced that this support will increase or remain at the same level over the next few years. At the same time, Ukrainians themselves keep still keep high level of support to Ukrainian Armed forces, donating and fundraising for the needs of the army. Yet another survey shows, that ​​65% of Ukrainians believe that Ukraine’s victory is very likely. 69% are ready to endure hardships because of the war for the sake of victory as long as necessary.

On the other hand, one of the key narratives of Russian FIMI targeting Ukrainian society is that the partners are turning away from Kyiv, cutting their financial and military support to Ukraine, are more focused on their domestic issues or help to other international partners (like Israel). The goal of such campaigns is to break the spirit of Ukrainian, sow distrust to authorities and spread disappear and frustration.

 

Addressing sore spots

One of the long term information threat for the EU (also affecting Ukraine) will be to maintain the unity of the member states on Russia policy which started to emerge after the full-scale aggression. The main narratives will be oriented to destroy the current policy framework, including questioning sanctions policy, energy embargoes, transfer of the Russian assets to Ukraine’s needs. As the European Union plans to reform and open its Enlargement policy, it will run counter Russian interest to retain political control over three aspiring states, Ukraine, Moldova and Georgia. It is expected that the Kremlin will try its best to drive the wedge between the EU member states as for taking any decision on membership negotiations with the states mentioned above.

Malign messages targeting Ukrainian audiences in this regard will include: the West has abandoned Ukraine, no one wants Ukraine in the EU, EU values run counter to traditional Ukrainian society, Europe is rotten and spoiled, Ukrainians are only wanted at low-qualified low-paid jobs, etc. Such campaigns aim to bring down the record high support for Ukraine’s European integration, which states at over 80% during all three years of war.

Ukrainians, who have left the war-torn country since 2022 and received the temporary protection in the EU, are already the object for various FIMI campaigns targeted at western audiences and aimed at discrediting Ukraine. Such narratives include portraying Ukrainians as danger and economic burden to the hosting countries. But the refugees themselves are also a very sensitive to manipulation audience, which can potentially be employed to influence Ukrainian decision-makers.

Full-scale war has completely changed the media consumption in Ukraine. In recent years, for the first time in history, TV has lost its position as the main source of information to Ukrainians. Only 42,7% of citizens look for information on TV, while social media is used as the main source of information by 73.4%. Furthermore, during the recent year the trust for news on TV has dropped by almost  half, from 61.1% in 2023 to 34.1% in 2024. This is largely caused by monopolization of TV broadcast by national telethon. Having played an important role of consolidating trustworthy information and preventing panic and manipulation in the first months of war, two and a half years on, the telethon is mostly viewed as a tool of censorship that promotes political leadership of the country. Criticism of the authorities, as well as true political pluralism in the telethon, is significantly limited. TV companies often neglect the balance of opinions, giving preference to speakers from the government alone. At the beginning of the year, MP Yaroslav Yurchyshyn sent a request to the State Audit Service to assess the effectiveness of the telethon. Based on the results of the audit, the service determined that the program used to fund the United News was conditionally effective. Despite this, the newly appointed  Minister for Information Policy and Strategic Communication Mykola Tochytskyy stated that the telethon will continue as long as the war continues.

At the same time, Ukrainian authorities also encourage communication in Telegram channels, creating official ones and cooperating with anonymous ones like Joker or Trukha. The network is also used by Ukrainian special services in their activities. For example, official Ukrainian chatbots were created by Ministry of Digital Transformation, Defense Intelligence and Security Service in Telegram to collect information about Russian troops and their weapons, collaborators, and so on. On 28 April 2014 these bots were blocked by Telegram due to unknown reasons. It is unclear whether the personal information of people using these bots was not jeopardized. Chief of Defense Intelligence K. Budanov mentioned that Telegram remains one of the rare tools that prove to be effective in communication with the occupied territories.

On 19 September the National Coordination Centre for Cybersecurity (NCCC), a key body for coordination and control in the field of cybersecurity, decided to ban the installation and use of Telegram on the official devices of government officials, military personnel, employees of the security and defence sector, as well as enterprises operating critical infrastructure. The only exceptions will be those for whom the use of this messenger is part of their official duties.

It deems doubtful that the decision will have any sufficient positive effects as Telegram can still be used on non-official devices. Furthermore it is still questionable what device might be qualified as official. On the other hand state and local institutions and their representative share information on non-official anonymous Telegram channels.

Such a rapid shift of audience from traditional media to social networks, which are not regulated by any legislation in Ukraine, may pose a threat to the country’s information security. Unlike television and official media, new media are more likely to spread fakes, manipulations, and outright disinformation. Widely spread, anonymous channels with their “insight” information that cannot be verified are particularly dangerous.

 

Is AI a game-changer: opportunity or a threat?

AI is already widely used in Ukraine to counter Russian aggression. Leaving aside purely military use, we will focus solely on its application in information dimension.

AI has become the one field to demonstrate productive cooperation between Ukraine’s start-ups and world-known companies and Ukrainian state.

AI offers wide possibilities in monitoring information space, detecting threats and planning pre-bunking campaigns. One of the Ukrainian startups, Mantis Analytics, claims to monitor in real time over 600,000 messages on 13,000 Telegram channels using AI that is taught to identify eighteen scientifically based technics of manipulation. They provide daily reports to the National Security and Defense Council on dozens of such campaigns, for each of which AI automatically identifies the top three messages. It also shows the dynamics of each campaign over a certain period of time, its coverage, and the percentage of the total amount of information. Researchers say, Russian information attacks are just like the ones on the kinetic battlefield: relying on mass cannon fodder rather than quality.

Another successful example is private business Osavul, that offers AI-powered platform for information environment assessment. Analysts of the Center for Countering Disinformation under the National Security and Defense Council have participated in machine learning process of Osavul system on the initial stage. Now the Center is using the software for their own analysis and relies on the company in monitoring of the information space on the occupied territories.

On the other hand, AI provides possibilities on automated creating and distribution of manipulation campaigns with better personalization and targeting. Analyst observe the boost in creation of pages and accounts completely populated with AI-generated content. In 2023, the analysts of the Center for Countering Disinformation unrevealed a network of YouTube channels in Africa with completely AI-generated content, promoting Russian narratives by fake journalists. Cases of using deepfakes in Russian manipulative campaign have been registered since the start of the full-scale war, portraying for example president V. Zelenskyy or the Commander-in-Chief of the Armed Forces general V. Zaluzhnuy, calling on Ukrainian to give in.

At the same time, there are cases of obvious failure in Ukrainian state communications connected to the use of AI that sow distrust to any information coming from state institutions. On the official X account of the Verkhovna Rada the destructions caused by the Russian missile strike of  residential area in Dnipro was illustrated by an AI-generated image of a child on the debris of the house. Such approach basically created the impression that the event itself was not real.

Ukraine is also using AI in documenting Russian war crimes, such as mass killings of civilians in Bucha and Mariupol, and prove that Russian officials’ repeated denials of them are lies. Software of American company Plantir is used by Prosecutor General’s Office to collect evidence of how war crimes are connected with exact units of Russian Armed Forces. Another American company, Clearview AI, provided technology used to identify and locate Russian war criminals, deported Ukrainian children, killed Ukrainian soldiers.

Of course, though serving some very practical tasks for the country at war, the use of this technology is controversial as Clearview AI has been sewed and banned in a number the EU stated for violating privacy of its citizens and personal data protection legislation. But it only highlights the total absence of any legislation in Ukraine that regulated the use of AI.

 

Uniting efforts: Ukraine and the EU against FIMI

In search of better orchestrated response

Civil society and expert community in Ukraine played crucial role in shaping public policy on countering disinformation. The start of Russo-Ukrainian war in 2014 prompted the rise of civic initiatives and NGOs devoted to debunking Russian myths and countering disinformation. First days of full-scale aggression mobilized Ukrainian civil society to protect Ukrainian information space and establish informal strategic communication with different target groups, including Western partners, Ukrainians inside the country and on occupied territories. Some attempts have also been made to appeal to Russian population, that did not bring lasting results. The high level of involvement was witnessed in 2022-2023 when independent communication specialists produced content both for horizontal communication in partner countries and at the same time participated in non-public initiatives helping Ukrainian ministries and special services. Unfortunately, many such experts confirm that recently the level of interaction with the state drastically decreased.

Another issue on  the forefront of countering FIMI is internal coordination of effort between different public agencies. At the moment, it is difficult to identify unified coordination place which covers existing relevant governmental, parliamentary and special institutions involved in fighting disinformation and propaganda. Although strategic communication unit has been established in Ukrainian government with the support of international partners, some ministries still prefer to apply their own approach to communication. Also some gaps can be observed in coordination of relevant activities on the level of the parliament. Different committees take part in development of legal and institutional infrastructure, but there’s no intercommitte taskforce or expert group that could facilitate the work.

Some difficulties are also visible on the level of international cooperation. Ukrainian agencies working on the issue confirm the high interest to unique Ukrainian experience from international partners. Foreign counterparts are interested in receiving information about Ukrainian cases and approach in countering FIMI, while there is an evident lack in reciprocal sharing of information. There is no stable format or platform for regular exchange of information. Ukrainian experts are not included in planning or practical activities of European bodies. The only exception is a representative of the Center for Countering Disinformation permanently present in NATO Strategic Communications Centre of Excellence in Riga.

Coalitions matter

Ukrainian experts are hopeful that bilateral security agreements that Ukraine has been signing with partners since Vilnius NATO Summit, will also improve coordination in information domain. Each such document contains clauses on information security. Thus, profile agencies plan to actively exchange information with signatory countries and conduct joint information campaigns.

Ukraine has come forward with the initiative of International Information Coalition, so called Information Ramstein, to counter Russian information threats targeting Ukraine and democracies worldwide. First announced in January 2023 by then-Minister of Culture and Information Policy O. Tkachencko, the initiative has not yet gained enough practical traction. While partners still work on determining the framework, the project lacked leadership and clear action plan on Ukrainian side with the vacant seat of the profile minister.

The initiative proposes to launch three working groups focused on different dimensions of countering information aggression. On domestic level, it is expected that members will doble down on development of institutional infrastructure, technologies and legislation to counter existing and new threats. Second dimension describes measures needed for the support of countries at risk, including financial support, boosting skills, sharing expertise. Finally, third most advanced level outlines partner coordination of narratives and best practices exchange across democracies worldwide.

 

MPs at the forefront of the fight against FIMI

Ukrainian parliament has faced a two-edged issue, preparing legislation on media in 2022. From one side, there was an acute threat to national security from Russian-backed media channels and propaganda outlet stirred by Kremlin. From the other, Ukraine committed itself to fast track of implementation of European Commission recommendations. One of the recommendations directly requested from the Ukrainian Parliament to adopt the Law on Media profoundly based on Digital Services Act. Significant effort has been demonstrated by the profile committee of Verkhovna Rada in the attempt to unite the demands of the EU and realities of fighting the war on the ground. After two years since the Law on Media has been enacted, it is obvious that the legislation already needs to be amended. At the same time, the new draft laws aiming to regulate operation of the social media are put forward. The documents circulating already take into account norms of the Digital Services Act.

Given the fact that a social network such as Telegram operates in a virtual grey zone, without any officially stipulated possibility of official communication with Ukrainian government agencies, this creates opportunities for the Russian secret services to use the network to promote their hostile narratives and organize subversive activities in Ukraine. Aggregated data shows that as of 2023, there were more than 33,000 active Telegram channels in Ukraine with a total of 282.6 million subscribers. This demonstrates the scale of the threat, especially against the backdrop of data showing that over 70% of Ukrainians receive news about the war from Telegram. Studies also show that Telegram channels popular among Ukrainians often misinform their audiences, publishing fakes and unverified information.

In March 2024, MP Mykola Kniazhytskyi proposed a draft law on amendments to certain laws of Ukraine on the regulation of information sharing platforms through which mass information is disseminated.

This document proposes that each social platform must ensure communication with Ukrainian regulatory authorities on compliance with the law, and must also confirm its safety for our citizens, and above all, the absence of government officials and citizens of the aggressor country among the owners.

On 29 August, the Committee on Humanitarian and Information Policy decided to develop a new version of the draft law based on the provisions of Kniazhytskyi’s proposal. It was decided that the draft law should be registered in the Verkhovna Rada of Ukraine by the end of September 2024. In discussions, representatives of the committee pointed out that the draft law may also contain provisions that would take into account other gaps in the current legal framework. For example, a legislative definition of the terms disinformation, propaganda, etc. may also find a place in the future law.

 

Conclusions and recommendations

Russia’s full-scale invasion of Ukraine has fundamentally changed the paradigm of the fight against Foreign Information Manipulation and Interference (FIMI), as the scale of information confrontation has increased dramatically. At the legislative level, several important initiatives have been adopted to enhance the legal framework for countering hostile propaganda and information influence. A crucial element of this effort has been the ban on pro-Russian political forces in Ukraine, along with recent measures to protect religious space from the influence of the Russian Orthodox Church and its special services. However, the practice of combating FIMI has also highlighted significant gaps in the current institutional and legislative framework.

Recommendation for Ukraine
  1. Before the full-scale aggression began, Ukraine took several strategic steps intended to establish a foundational information structure to counter hybrid and informational threats. The Information Security Strategy adopted in 2021 was a response to the level of threats and the appropriate tools for addressing them. Clearly, there is a need to revise this strategy to align with wartime requirements, new challenges, and a more systematic approach to countering them. Discussions on this topic are already underway among relevant institutions, but work on a new version of the document has not yet begun. Since there are four committees in the Ukrainian parliament directly connected to the area of information security, it advisable to hold the inter-committee hearings on the outline of future Strategy. Conclusions of the hearings should be shared with the working group developing new document.
  2. The approach to developing a “One Voice Policy” for Ukrainian state institutions needs to be consolidated, with a clear definition of the ministries’ sub-departments and specialized strategic communication institutions responsible for promoting coordinated messages and joint approaches to countering FIMI. It seems logical that the center of coordination should be at the level of the head of government, but the current system of informal power division may lead to primary coordination coming from the Office of the President of Ukraine. A first step to launch coordination mechanisms could be periodic meetings or gatherings of those responsible for strategic communications at the state institutional level. Unified approach to messaging, especially to external audiences should definitely include members of the parliament and civil society.
  3. While seeking a whole-of-society approach to countering FIMI and securing strategic outreach, an appropriate division of power must be established among Ukrainian actors and stakeholders. Disrupting the malign activities of Russia and other adversarial states should primarily be the responsibility of security services and the intelligence community. At the same time, strategic communication aimed at tailoring narratives for target audiences must be actively implemented by state strategic communication infrastructure and non-governmental institutions. The parliament should concentrate on filling gaps in legislation framework to provide legal at the same being open for external consultation on every stage of legislation process.
  4. Streamlining parliamentary work requires the initiation of coordination among committees and experts involved in this area. A temporary investigative committee (task force) could serve as a relevant platform for MPs to collaborate and make more informed decisions on countering FIMI, particularly regarding the criminalization of hostile activities related to disinformation and propaganda, setting a regulatory environment, and ensuring a balance between freedom of speech and national security. For the next parliamentary convocation, establishing a dedicated committee on countering FIMI might also be a viable option.
  5. To actively counter FIMI, the Verkhovana Rada should intensify its efforts on improving legislation that defines the nature of criminal acts related to violations of the Ukrainian information space. Legally defined concepts of disinformation, propaganda, synthetic content, and bot farms should be established to assist law enforcement agencies in accurately identifying the signs of information crimes.
  6. The use of the social platform Telegram should be fully integrated into Ukraine’s legal framework through official cooperation with the Ukrainian regulator and representatives. At the same time, Ukraine must take all necessary measures to ensure the security of state institutions that have accounts on this platform. De-anonymizing Telegram channels is also an important task that will enhance the quality of information content. An import role in achieving this task should be played by the parliament. The Verkhovna Rada should take the first step in creating regulatory bases for social network on the national market.
Recommendations for the EU
  1. The European Union serves as a model for Ukraine in building systemic approaches to establish an effective regulatory framework for the Ukrainian information space. The Media Law, enacted in December 2022, was developed with consideration of European norms, particularly the Digital Services Act. However, as practice shows, it is not sufficient to merely adopt similar norms in domestic legislation; it is also crucial to maintain a strong position in communication with Big Tech and other entities that influence the formation of the information space. Therefore, it is important for Ukraine that practices are adapted at the EU level so that both the EU and Ukraine can present a united front in meetings with large corporations in defense of their rights and the protection of their information sovereignty against encroachments by unscrupulous actors. The European Parliament on the level of profile parliamentary committees may set open hearing on the state of play on cooperation with Big Tech companies.
  2. The EU has made significant strides in identifying FIMI and creating an official toolkit to counter it. Some of this positive experience could be incorporated into the norms of the Common Foreign and Security Policy, thereby expanding joint approaches to candidate countries committed to aligning with EU acquis. The European Parliament in accordance with the EU treaties is deeply involved in shaping Common Foreign and Security Policy, including possibility to request a report from senior officials in the area of the EU defense and security. The EU may propose accordant change,
  3. The experience of using artificial intelligence (AI) during the Russian-Ukrainian war indicates that authoritarian states often gain advantages in weaponizing AI compared to Western European countries, which may impose moral or value-based restrictions on its use. In light of this, the EU should intensify its efforts to address the use of AI for security and defense purposes to establish a reliable defense system and deter real and potential adversaries. The European Parliament played a key role in developing EU’s legislation on artificial intelligence. Thus its modification and adaptation to changing realities is also part of the responsibility of the EP.
  4. The European Union and its partners should also take more serious measures to coordinate efforts against FIMI. Ukraine has an ambitious proposal for an International Information Coalition, which suggests mechanisms for joint detection and response to serious information threats. This initiative requires renewed momentum from both the EU and Ukraine, especially following the emergence of new leadership in the European Commission,  the European External Action Service and European Parliament.
  5. Given the EU’s progressive approaches to enlargement policy after the European elections in 2024, it is likely that Russia will attempt to obstruct the rapprochement of Ukraine, Moldova, and eventually Georgia. Therefore, it is essential for the EU to provide regional support to candidate countries in developing their informational resilience, as well as to supply joint tools for countering FIMI. Areas of cooperation should include experience exchange, inclusion in early warning mechanisms for detecting and countering FIMI, and the establishment of a shared map of threats and risks among EU member states and candidates. The European Parliament may give an initial push to introducing changes to the enragement policy. Relevant committees in cooperation with civil society may kick-start these changes by issuing a resolution with call the EU institutions, including European Council and European Commission.