Digital Platforms as Critical Infrastructure: German and European Union Policy Responses to Safeguarding Democratic Information Environments in Times of Crisis

Abstract This article argues that systemically relevant digital platforms for public communication exhibit characteristics of critical democratic infrastructure. Platforms structure the visibility, circulation, and interpretation of political information and thereby shape conditions of democratic will-formation. Building on deliberative democratic theory, critiques of the bourgeois public sphere, systemic approaches to public communication, and platform studies, the article conceptualizes public communication as an infrastructural precondition of democratic legitimacy without presupposing a unified or historically inclusive public sphere. The article makes two contributions. First, it develops an account of criticality distinguishing the infrastructural role of platforms from formal legal classification as critical infrastructure. Platforms become democratically critical where communicative function combines with systemic dependency, limited short-term substitutability, cascading effects, and heightened crisis relevance. Second, it examines how German and European Union (EU) regulatory frameworks distribute responsibility for the availability, integrity, plurality, and resilience of platform-mediated communication. The analysis identifies fragmentation: the Digital Services Act addresses systemic risks; the Digital Markets Act and European Media Freedom Act address gatekeeper power and media-platform relations; and cybersecurity and critical-infrastructure regimes address operational resilience. None treats democratic communicative continuity as an integrated infrastructural objective. The article concludes that this fragmentation matters for democratic resilience, particularly in crises and hybrid-threat environments. It proposes infrastructure-sensitive platform governance combining continuity and risk-management obligations with public accountability, structural measures against dependency, and support for interoperable and non-commercial alternatives. Critical-infrastructure language must, however, be used cautiously: protecting democratic communication cannot justify direct state control over lawful political speech or suppression of counterpublics.