European policies promoting information integrity: media, civil society and citizens.

This paper proposes a theoretical framework to analyze regulatory misfit in European policies promoting information integrity, including the European Media Freedom Act (EMFA), the Digital Services Act (DSA), and the European Democracy Shield. Drawing on systemic deliberative democracy theory (Habermas 1996; 2022), it conceptualizes the digital public sphere as an intermediate space connecting institutional deliberations with social processes of opinion formation. Democratic deliberation is understood as emerging from the interaction among institutional, media, and civic subsystems (Mansbridge et al. 2012). Regulators, media organizations, political parties, and civil-society actors each play complementary roles in fostering autonomy, transparency, and reflexivity within the European public sphere. This perspective highlights that evaluating information integrity and the effectiveness of European regulation requires examining the interconnections between these different spaces rather than focusing on any single actor or sector. By integrating systemic deliberative theory with the study of digital governance, the paper provides a conceptual lens for understanding how European regulatory frameworks interact with systems that differ in their institutional capacities and communication dynamicsx. The framework offers a foundation for future empirical research and policy analysis across the European Union.