Shortly after migrants flooded the Spanish territory of Ceuta, notices popped up around Instagram and Facebook.1 These notices are not organic; they were coordinated by the European Commission along with two government-funded NGOs they designated as “reliable and trustworthy” fact-checkers.2

Facebook migration guide naming IOM and OSCE as consultants beside Meta's help assistant

The European Commission’s rapid response has two components. The first warns presumed migrants about illegal traffickers. The second insists that “Monitoring must increase, cooperation with fact-checkers to be strengthened.”

Instagram search results for Ceuta with a migration-information warning and Get migration info button

The EU “Code of Conduct on Disinformation” establishes strict information control protocols. This code explicitly threatens Facebook, Instagram, LinkedIn, TikTok, YouTube, and Google Search with hundred million dollar fines if they do not obey these directives. The Commission already issued a €120M fine to X for refusing to censor political content.

The European Commission has activated this protocol for Ceuta. “TikTok and Meta have activated crisis protocols and have now put in place an ad-hoc escalation and cooperation mechanism with fact-checkers,” a European Commission Vice-President claimed on X.

Henna Virkkunen post stating that TikTok and Meta activated crisis protocols and an ad-hoc fact-checker cooperation mechanism

Who decides what is disinformation? The European Commission designated two transnational organizations as their arbiters for Ceuta: the International Organization for Migration (IOM) and the Organization for Security and Co-operation in Europe (OSCE). Neither NGO is independent or objective; both are political advocacy groups overwhelmingly funded by governments.

According to its charter, the IOM’s purpose is “to make arrangements for the organized transfer of migrants” and “to provide, at the request of and in agreement with the States concerned, migration services.” IOM received over $3B from governments in 2024.

IOM’s ten largest donors, 2024 Share of the displayed top-ten total using combined assessed, voluntary and in-kind contributions IOM’s ten largest donors, 2024 United States of America · $1,517,000,000 · 52.2%United States52.2%European Commission · $480,000,000 · 16.5%European Commission16.5%Canada · $176,000,000 · 6.1%Canada6.1%United Kingdom · $157,000,000 · 5.4%Germany · $156,000,000 · 5.4%United Nations organizations and pooled funds · $135,000,000 · 4.6%Netherlands (Kingdom of the) · $93,000,000 · 3.2%Australia · $76,000,000 · 2.6%Japan · $59,000,000 · 2.0%Italy · $57,000,000 · 2.0% United States of America · $1.52B · 52.2%European Commission · $480M · 16.5%Canada · $176M · 6.1%United Kingdom · $157M · 5.4%Germany · $156M · 5.4%United Nations organizations and pooled funds · $135M · 4.6%Netherlands (Kingdom of the) · $93M · 3.2%Australia · $76M · 2.6%Japan · $59M · 2.0%Italy · $57M · 2.0%

In 2024, IOM made its official policy to “effectively mainstream gender equality” and “deliver gender-responsive approaches that are inclusive of persons of all genders.” Another IOM report “aims to support the development of inclusive measures for migrants with diverse SOGIESC [sexual orientation, gender identity, gender expression and sex characteristics] to benefit from protection programming across their migration journey.” Its advocacy is a direct conflict of interest with fact-checking on behalf of the European Commission and Meta.

IOM Gender Equality Policy introduction with the gender-mainstreaming passage highlighted

Likewise, OSCE is an advocacy organization funded by national governments, not an independent or objective evaluator.5 In their “ACTION PLAN FOR THE PROMOTION OF GENDER EQUALITY,” they wrote, “Stressing the need for the OSCE to develop further and strengthen a continuous and sustainable gender-mainstreaming process, to promote a gender-sensitive and professional working environment and management culture, and efforts towards gender balance in staffing in particular on a professional level.” OSCE received over €70M from governments in 2024.

OSCE Donors (2024) Share of listed pledge amounts · every donor below 4% grouped as Other OSCE Donors (2024) European Union · €21,802,260 · 28.3%European Union28.3%Germany · €17,882,076 · 23.2%Germany23.2%Norway · €10,022,993 · 13.0%Norway13.0%United States · €7,046,644 · 9.1%US9.1%Sweden · €3,595,157 · 4.7%Finland · €3,286,064 · 4.3%United Kingdom · €3,246,517 · 4.2%Other (33 donors below 4% each) · €10,218,240 · 13.3%Other13.3% European Union · €21.80M · 28.3%Germany · €17.88M · 23.2%Norway · €10.02M · 13.0%US · €7.05M · 9.1%Sweden · €3.60M · 4.7%Finland · €3.29M · 4.3%United Kingdom · €3.25M · 4.2%Other (33 donors below 4% each) · €10.22M · 13.3%

While the European Commission has no jurisdiction over non-EU States, Effort has corroborated that these notices appear in the United States, Canada, Australia, Mexico, and the United Kingdom. This implies that these countries are all affected by the European Commission's rapid reponse protocol — including its political censorship.

Footnotes

  1. Instagram screenshot from Bill Melugin’s X post. Policies and similar screenshots independently verified by Effort.

  2. Meta notice European Commission statement.

  3. The Commission states that DSA fines may reach 6% of a provider’s global annual turnover. It fined X €120 million in December 2025 and AliExpress €550 million in July 2026.

  4. The table reproduces the ten largest contributors shown in IOM’s Financial Report for 2024, using combined assessed, voluntary, and in-kind contributions rounded to the nearest million dollars.

    IOM’s ten largest donors, 2024
    RankDonorContributionEntity type
    1United States of America$1,517,000,000Nation state
    2European Commission$480,000,000EU institution
    3Canada$176,000,000Nation state
    4United Kingdom$157,000,000Nation state
    5Germany$156,000,000Nation state
    6United Nations organizations and pooled funds$135,000,000UN organizations and pooled funds
    7Netherlands (Kingdom of the)$93,000,000Nation state
    8Australia$76,000,000Nation state
    9Japan$59,000,000Nation state
    10Italy$57,000,000Nation state
  5. See the OSCE’s 2004 Action Plan for the Promotion of Gender Equality and its Annual Report 2024 funding tables.

  6. OSCE Annual Report 2024

    OSCE Donors (2024)
    RankDonorPledgeEntity type
    1European Union€21,802,260Supranational institution
    2Germany€17,882,076Nation state
    3Norway€10,022,993Nation state
    4United States€7,046,644Nation state
    5Sweden€3,595,157Nation state
    6Finland€3,286,064Nation state
    7United Kingdom€3,246,517Nation state
    8France€3,010,000Nation state
    9Italy€1,680,930Nation state
    10Switzerland€1,391,266Nation state
    11Ireland€659,098Nation state
    12Austria€545,518Nation state
    13Netherlands€468,000Nation state
    14Czech Republic€460,494Nation state
    15Japan€266,828Nation state
    16Liechtenstein€255,356Nation state
    17Malta€224,666Nation state
    18Bulgaria€160,000Nation state
    19Luxembourg€153,000Nation state
    20Latvia€140,000Nation state
    21Monaco€120,000Nation state
    22Poland€112,782Nation state
    23Cyprus€90,000Nation state
    24South Korea€62,468Nation state
    25Georgia€50,000Nation state
    26Lithuania€50,000Nation state
    27Slovenia€46,951Nation state
    28Estonia€45,000Nation state
    29Spain€41,572Nation state
    30Romania€37,395Nation state
    31Montenegro€34,000Nation state
    32Slovakia€34,000Nation state
    33Andorra€20,000Nation state
    34Türkiye€20,000Nation state
    35Croatia€13,089Nation state
    36Thailand€10,734Nation state
    37Albania€10,000Nation state
    38Canada€3,000Nation state
    39San Marino€1,387Nation state
    40Moldova€706Nation state