Shared Responsibility, Unequal Power: Mapping the limitations of multi-stakeholderism in EU’s digital governance

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Abstract

With the adoption of the Digital Services Act, Digital Markets Act, Artificial Intelligence Act, and European Media Freedom Act, the EU has set in motion an ambitious regulatory project to shape the governance of digital platforms and AI systems. This paper maps the governance stakeholders involved in the operationalization of these four instruments and examines their distribution of powers and responsibilities. Building on existing typologies of platform governance and regulatory space theory, we introduce an analytical framework that foregrounds three structural elements–competencies, capacities, and connectedness–alongside eight regulatory functions, ranging from agenda-setting to enforcement and discourse shaping. We then operationalize this framework in the context of the standardization ecosystem, highlighting the growing prominence of standardization bodies as central actors in multi-stakeholderism. Our analysis shows that, despite the promises of multi-stakeholderism for more democratic and cooperative governance configurations, in practice this approach often disregards material power asymmetries. This reality privileges technocratic expertise and industry stakeholders over public-interest actors, hindering ultimately a more equitable and democratic governance paradigm. We conclude by arguing that pursuing strategic autonomy, as the EU boasts, requires reducing the regulatory power of private actors and strengthening capacities of actors normatively and materially grounded in the public interest.

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