The DSA
The Digital Services Act provides procedures, obligations, and enforcement mechanisms regarding illegal digital content and, to some extent, harmful digital content. In addition, it establishes channels for cooperation among platforms, search engines, researchers, and public authorities.
The DSC
The DSC is, among other responsibilities, expected to assess and respond to systemic risks affecting society resulting from the mechanisms and activities of very large online platforms and search engines. Its task is therefore not merely to enforce rules. It requires judgments about phenomena occurring throughout society. Yet the DSC’s epistemic position is structurally indirect. It cannot observe society in its entirety. Its understanding of systemic risks must be reconstructed through proxies: platform reports, researcher access, trusted flagger input, complaints, audits, and other mediated sources. Each source is necessarily partial and may be incomplete, delayed, strategically framed, or otherwise unreliable. The DSC therefore faces a particular epistemic problem: it exercises regulatory judgment about societal phenomena that it can observe only indirectly through potentially biased or incomplete sources. Nevertheless, as was suggested in blog post 135, an institution cannot simply rely on necessarily partial mediated representations of reality. It also needs to remain connected to the lived realities experienced by the people it is intended to serve.
Different approaches to reality
This challenge is intensified by the epistemic fragmentation of contemporary societies. Citizens encounter different information environments, different experiences, and different interpretations of reality. Institutions cannot fully register these fragmented realities. When they do register elements of them, they must distinguish between isolated incidents, vocal minorities, organized campaigns, emerging social trends, and genuine societal concerns. Institutions therefore risk focusing on phenomena that are visible but not necessarily relevant, or overlooking phenomena that are relevant but insufficiently visible. This risk is inherent to institutional functioning. Institutions must simplify social complexity through procedures, indicators, legal frameworks, expert assessments, and organizational routines. Limited capacity to process the available information intensifies the problem.
The challenge
The DSC consequently faces a double risk: becoming captive to highly visible fragments of reality or becoming detached from lived reality. The first risk is difficult to avoid because (social) media and political actors can amplify precisely those phenomena that are already highly visible. Visibility, however, does not necessarily indicate societal relevance or representativeness. The second risk may be even harder to avoid because the DSC cannot simply remove the proxies through which it observes society. It needs information from platforms, researchers, trusted flaggers, citizens, and other actors. These sources provide necessary perspectives, but each represents only part of the social reality from which systemic risks emerge. The question is therefore how the DSC can independently remain connected to the lived realities experienced by the society it is intended to serve.
Interdemocracy
Interdemocracy addresses the epistemic gap experienced by the DSC by creating a procedurally organized participatory process through which citizens can articulate, examine, and contextualize their experiences of systemic risks. It does not replace existing evidence streams. Rather, it can provide an independent societal evidence layer alongside them. This independent evidence layer can potentially reduce the epistemic distance between the DSC and the society whose resilience it is charged with protecting. It also addresses a second problem. The participatory process itself can contribute to societal democratic resilience by developing citizens’ capacity for autonomous self-expression, listening without immediate judgment, and collective sense-making. The purpose is therefore not to transform citizens into another source of raw data. It is to create conditions under which experiences that may otherwise remain invisible, fragmented, or mediated through other actors can become collectively articulated and available for institutional consideration, while contributing to societal democratic resilience rather than instrumentalizing citizens in the service of institutional needs.
Resilience Council
A Resilience Council provides the institutional interface through which this societal evidence can become relevant to the DSC. Unlike traditional stakeholder consultation, a Resilience Council is not primarily designed to collect opinions. Nor is it intended to replace expertise. Its function is to create a structured mechanism through which the societal evidence generated through Interdemocracy can enter the institutional epistemic environment and provide corrective feedback to institutional perspectives. This creates several potential advantages. First, it broadens institutional perception. Civil society organizations, educators, researchers, practitioners, and citizens can detect emerging social dynamics before they become visible through formal indicators. Second, it creates a mechanism for reciprocal correction. The institution can expose its own understanding to societal experiences, while participants can encounter perspectives that differ from their own. Third, it can strengthen institutional legitimacy. Decisions are more likely to be perceived as legitimate when people recognize that their experiences have been considered, even when those experiences do not determine the final outcome. Fourth, it can strengthen institutional resilience. An institution with access to a wider range of corrective feedback may be less vulnerable to both technocratic insulation and populist overreaction.
Democratic infrastructure
The long-term challenge facing democratic societies is therefore not merely the presence of disinformation, polarization, or extremism. It is also the possibility that institutions gradually lose contact with the realities they are intended to govern. Once that contact weakens, errors become harder to detect and trust becomes harder to restore. A Resilience Council should therefore be understood not simply as an advisory body attached to a Digital Services Coordinator, but as a democratic infrastructure for maintaining institutional contact with society. The Digital Services Act provides the regulatory guardrails. Existing institutional actors provide expertise, evidence, and enforcement capacity. Interdemocracy provides a structured societal evidence layer. The Resilience Council provides an interface through which that layer can become part of the DSC’s process of self-correction. The objective is neither to replace expertise with popular sentiment nor to replace mediated evidence with lived experience. It is to create conditions under which institutional knowledge and societal experience remain in continuous contact.