EU Ukraine

Open letter to the EU: protect people affected by Russia’s attack on Ukraine

Brussels, 1 March 2022

Re: Recommendations related to tech platforms and telecoms operators in the context of the war in Ukraine

Dear Vice-President Věra Jourová,

Dear High Representative Josep Borrell,

Dear Commissioner Thierry Breton,

Dear Commissioner Didier Reynders,

Dear Commissioner Ylva Johansson, 

On behalf of Access Now, we write to provide a list of recommendations to share with tech platforms and telecoms operators in the context of the war in Ukraine. We welcome the swift engagement of the European Union in these matters and we ask for your support in the area of connectivity, platforms’ operations, data protection, and non-discrimination.

Access Now is an international NGO that works to defend and extend the digital rights of users at risk around the world. We operate in 13 countries, including in the Central and Eastern Europe region, and we operate a 24/7 Digital Security Helpline that provides technical support to activists and journalists on the ground. 


Thousands of people from and in Ukraine are trying to stay in touch with their families and contact authorities as they face the war, seek shelters, or find refuge in the neighbouring countries. We ask for the EU’s support in:

  • Asking telecom operators and internet providers to protect infrastructure to maintain connectivity and prevent internet and communications shutdowns;
  • Asking telecom operators in the European to waive call, text, and data charges for all communications from and to Ukraine. At minimum, all roaming charges should be lifted. As telecom operators meet in Barcelona for the Mobile World Congress, we call on them to assist the population in Ukraine and quickly address this request; 
  • Asking EU governments and telecom operators in the EU to lift SIM registration and other identification requirements for anyone arriving in the EU territory from Ukraine to help people to communicate with their families and authorities and avoid administrative delays;
  • Asking telecom operators to boost network capacity, as through “cell-on-wheels” mobile cell sites, in key locations such as border crossings;
  • Highlighting the financial need to support the adequate supply of SIM cards at the borders and in the processes to support fleeing from Ukraine;
  • Facilitating the export, transfer, and activation of new connectivity technologies, including alternatives to traditional telecommunications infrastructure such as mesh networking, satellite, and radio-based tools, as appropriate and in coordination with local actors.
Platforms’ operations

People in Russia, Ukraine, and Belarus on the one hand, and in EU Member States on the other, rely on the services of social media companies and other platforms to communicate and stay informed. While the EU is working on a comprehensive platform regulation we need to recognise that war times require special rules and exemptions: 

  • Platforms and communications services must remain available in Russia, in Belarus and in Ukraine. In war time and other fragile and conflict-affected situations, these platforms are even more necessary for civic organising, communications, and receiving and imparting information. The need to limit the impact of harmful actors cannot be the basis for limiting entire services; 
  • Under the current exceptional circumstances, however, we support the suspension of Russia Today, Sputnik, and key Russian state-sponsored propaganda actors from these platforms, including in Russia. We would like to reiterate that any restrictions should be in compliance with the rule of law and the principles of legality, legitimacy, and necessity and proportionality; 
  • We support the demonetisation of certain actors spreading disinformation on platforms like Facebook and YouTube. (Even under normal circumstances, we support a ban on microtargeting for advertisements including political content;)
  • We recognise the need for algorithmic content curation to particularly promote online content to favour verified news sources. We recommend that allow-listing procedures take into account specificities of national contexts and they don’t fully rely on either government or the platform’s own decisions. The lists of authorised and promoted content must include civil society organisations and humanitarian response groups;
  • We ask for the EU support in calling companies to preserve documentation of violence, for potential future efforts to hold people accountable for violating humanitarian law and human rights violations and ensure that victims get access to remedy. 
Data protection

As people move across borders to seek refuge from war, it is paramount to protect their personal information from exploitation and from unauthorised access. It is critical to ensure the rights to privacy and data protection of refugees, asylum seekers – and organisations’ and individuals’ who aid them at the border and beyond to avoid risks of persecution. We ask the EU to:

  • Ensure that the EU border agency and measures to welcome refugees in the EU guarantee the protection of their information and abide by strict data minimisation principles;
  • Call on tech and telecoms companies to limit data collections of people leaving Ukraine and to not comply with data localisation requirements in Russia to avoid persecution of dissidents and journalists.
Non-discrimination at the border

We strongly welcome the decision of EU countries to open borders to welcome people from Ukraine. Ukraine is a home to many Russian and Belarusian nationals who fled their repressive regimes to find refuge in free and democratic Ukraine. Some of them report that their bank accounts have been frozen due to their nationality, leaving them unable to buy basic necessities, and pay for transportation and housing in Ukraine or abroad. 

We ask for your support to call on EU countries to keep the borders open for all people leaving Ukraine, including third-country nationals and people of color living and studying in Ukraine.

We would like to stay in touch with you and your teams during the deployment of these recommendations and to discuss any additional measures that tech and telecom companies may take to protect human rights in this conflict.

Best regards,

Fanny Hidvégi

Europe Policy Director

Estelle Massé

Europe Legislative Manager

Natalia Krapiva

Tech-Legal Counsel, Central and Eastern Europe