Towards a Code of professional integrity for European fact-checkers and OSINT organisations

By Iva Nenadić and Marijana Grbeša

Considering the prominent role of fact-checking organisations in the EU policy against disinformation, it is crucial that such organisations and projects abide by the highest professional standards. In this contribution, Dr Iva Nenadić of the European University Institute’s Centre for Media Pluralism and Media Freedom and the University of Zagreb and Professor Marijana Grbeša of the University of Zagreb propose and explain a list of principles and concrete measures to ensure the integrity of fact-checkers, especially when their work is funded by public money.

“Fact-checkers’ credibility depends upon their independence and their compliance with strict ethical and transparency rules”

The youngest member state of the European Union, Croatia, is also the first one to pilot a significant investment of public money into the establishment and strengthening of the system of fact-checking and verification of the information that circulate public spaces, media, and online platforms. The investment of HRK 45 million (~ EUR 6 million) is ensured through the National Recovery and Resilience Plan, implementing the EU Recovery and Resilience Facility, which seeks to mitigate the economic and social impact of the coronavirus pandemic and make European economies and societies more resilient in the green and digital transitions.

The investment is managed by the Croatian Ministry of Culture and Media and the Agency for Electronic Media. To adequately define the scope and the focus of the investment, the Agency for Electronic Media commissioned an independent expert study, co-authored by us: “Strengthening society’s resistance to disinformation: analysis of the situation and guidelines for action” (draft available in Croatian, English version forthcoming). The Study provided a comprehensive overview of: the national media and information context; the extent and nature of transnational disinformation and misinformation challenges and their manifestation in Croatia; the potential for automation and application of artificial intelligence in fact-checking and verification; and the key standards, principles, and solutions promoted by the key European and international organisations.

The Study served as a basis for suggesting the activities that the investment should support. These first and foremost promote the need for collaboration between traditional media and independent fact-checking organizations and between practitioners and multidisciplinary academic community and other relevant stakeholders. This approach reflects both the national context and the recommendations put forward by the Council of Europe, the European Commission, and UNESCO, as well as relevant projects such as the European Digital Media Observatory (EDMO). The activities should further support the development and application of new technologies, including artificial intelligence and OSINT (open-source intelligence) in the process of journalistic verification and fact-checking, and this should be followed by continuous training and capacity building of all those who will use these technologies.

The Study also highlighted the need for clear and implementable integrity and transparency standards for both sides in the funding scheme – those who will allocate the money and those who will use it. Many relevant projects, including for instance the Media Pluralism Monitor, emphasise the importance of having clear criteria and full transparency in the allocation of any kind of public and state managed resources to the media and journalists, in particular considering that such support may play a pivotal role in maintaining newsrooms’ viability in the context of the financial difficulties that media outlets are facing.

Fact-checking organisations are having a prominent role in the EU policy to tackle disinformation. The European Commission’s 2018 Communication that established the “European approach to tackling disinformation” saw fact-checkers “as an integral element in the media value chain”. The 2022 Code of Practice on Disinformation, a form of self-regulation and still the key instrument in the European approach to tackle disinformation, strengthens the collaboration between fact-checkers and online platforms (signatories of the Code) in labelling and combating disinformation in the online sphere, which in some cases may include also acting on poor journalism, misleading headlines and clickbait.

Considering their prominent role in the EU policy against disinformation, it is crucial that fact-checking organisations and projects abide by the highest professional standards. This is also highlighted in the Commission’s 2018 Communication: “Fact-checkers’ credibility depends upon their independence and their compliance with strict ethical and transparency rules”. Fact-checking organisations and projects are increasingly facing criticisms about the lack of transparency related to the process of selecting the topics or statements to fact-check, as well as regarding the very methodology of validating the facts. Louk Faesen et al. (2021) point out also that a number of critics are concerned about the bias of fact-checkers.

At the moment, there is no common self-regulation of fact-checking organisations in the EU. The biggest and the most relevant collaboration of fact-checkers in Europe is organized under the European Digital Media Observatory (EDMO). To join EDMO, fact-checkers have to satisfy certain criteria. Specifically, they need to have an EU focus, demonstrate their competence in fact-checking, for which sufficient evidence is if an organisation is a signatory of the Code of Principles of the International Fact-checking Network (IFCN), demonstrate transparency in disclosing their organizational and proprietary structure, disclosing and avoiding any potential conflict of interest, display independence from political parties or movements and “comply with the applicable rules of ethics in their area of expertise”.

However, there seem to be no available documents or self-regulation of fact-checkers in Europe in which such ethical rules are clearly described. This void should be filled in by the new European Fact-Checking Standards Network Project, funded by the European Union, that seeks to establish a Code of Professional Integrity for European fact-checkers and OSINT (open-source intelligence) organisations. In the meantime, when demonstrating competence and professionalism, European fact-checkers refer to their compliance with the principles of IFCN.

With all this in mind, and considering the specific context in Croatia, we put forward a list of integrity and transparency principles for applicants in the funding scheme of the National Recovery and Resilience Plan that aims at establishing and strengthening the system of fact-checking and verification in the information environment in Croatia:

Organisational independence: political, economic, and other

  • An organization can be considered dependent when it depends on one key source of funding that may have certain political, economic, ideological, or other interests that potentially conflict with the public interest. Examples on which the principle of organisational and editorial independence is built: if an organization specialises or applies for a project of checking information in the political sphere, it must not receive funds from politicians, political parties, political groups or other actors with an established political agenda; a local fact-checking organization or media must not depend on sources of funding related to local authorities and local businessmen in a way that reduces their independence, and when such funding exists, it should always be allocated through public tenders with full disclosure of the allocation criteria and allocated amounts; if the organization specializes or applies for a fact-checking project in the field of health (dis)information, it must not receive funds from, for example, pharmaceutical industry and other organizations that may reduce its independence.

Professional impartiality and independence

  • Organisations that perform fact-checking activities should approach all content impartially and equally, and editorial decisions should be made independently of any political, economic or other influence; fact-checker should adhere to the high standards of verification prescribed by the most relevant world organizations and projects in the field of fact-checking (such as IFCN or EDMO), regardless of who is the source of the information; verification of information must not be ideologically biased and must not be directed only at political actors, persons or organizations belonging to one ideological spectrum, while excluding others.
  • Fact-checking organisations must not advocate for political options and/or candidates.


  • Transparency in disclosing their ownership and organisational structure, and procedures and methodology of fact-finding: the names, short biographies and the scope of work of the persons involved in the fact-checking process, project manager(s), and editors/directors, where applicable; easily accessible and clear description of the procedures it uses when selecting information/story to be analysed and verified, and the verification process; simple and transparent channel for communication with the fact-checking organization or project via online and other channels should be enabled;
  • Transparency of funding: fact-checking organisations should clearly disclose funding sources, i.e., on their website; if the media and fact-checking organizations receive funds from supranational sources (e.g., the European Union programs and the like), the state and/or regional and local governments, public bodies and institutions, it should always be through public tenders and transparent in terms of allocated amounts and allocation criteria; the funding received from commercial entities should also be transparent;
  • Transparency of sources: when debunking disinformation, a fact-checker should transparently list all the sources used in establishing facts, so that these sources can be consulted by others; wherever possible, a fact-checker should refer to more than one source to correct the information; fact-checkers should warn of a potential conflict of interest of a source used, especially if this could affect the accuracy of the evidence; whenever possible, a fact-checker should contact the person who is the author of the claim that is marked as false, especially if it concerns statements by public persons;
  • Transparency of computer systems for fact-checking: the code should be open source and publicly available to the greatest extent possible; the procedure for defining, training and evaluating machine learning models should be described; the limitations of the developed modules within the fact-checking system should be described; it is necessary to describe the data used for the development of the machine learning model and indicate the possible biases present in the data; the data on which the models were trained should be publicly available unless, in relation to this data, there are possible restrictions related to the protection of personal data or copyright; it is necessary, to the extent possible, to apply methods for the explainability of machine learning models.


  • Fact-checking organisations should be guided by the principle of reach and relevance in the selection of information to fact-check, whereby priority should be given to information and contents that affect the public interest and safety of society or of vulnerable communities; on its website, the fact-checking organisation should clearly describe the procedures and criteria used in selecting information that is subject to verification, acknowledging that only information for which the factuality can be determined is a subject to verification, and such information should be clearly distinguished from the expression of opinions and value judgments that cannot be the subject of fact-checking (also according to the case law of the European Court for Human Rights);

The right to correction and publication of corrections

  • Fact-checking organisations should publish the policy of publication of corrections on its website; the fact-checker is obliged to publish a correction when it is determined that there was a mistake in the procedure, sources, content or conclusions, and the correction must be published so that it is noticeable and that the audience can see the correction as easily as possible; a fact-checker should take responsibility for any damage caused to third parties by his negligent work.

No conflict of interest

  • A clear commitment to prevent and, in case, disclose any conflict of interest that may in any way threaten the fundamental principles of independence, transparency, and impartiality.

Fact-checking and OSINT organizations act as influential authorities who have the power to set agendas and frame issues for national and transnational media and audiences in challenging times. Therefore, their work should be guided by the highest professional standards and evaluated against well-defined benchmarks that the upcoming Code of Professional Integrity should seek to provide.