By Iryna Subota, for EUvsDisinfo
In December 2024, Telegram began restricting access to channels of Russian propaganda resources sanctioned in the EU. However, a study by the Centre for Democracy and Rule of Law revealed a wide range of tools used to bypass the ban. The persistence of Russian information manipulation and interference (FIMI) in the EU stems from two key factors. First, it is the inherent adaptability of Russian threat actors post-sanctions. Second, it is Telegram’s own platform gaps that continue to make it a threat to the EU’s information and digital resilience.
Adaptability of Russian FIMI
The adaptability of Russia’s information manipulation and interference is driven by two key factors. First is the continuous sophistication of technological capabilities themselves. When these improved technologies fall into the hands of malicious actors, they on purpose enhance and streamline methods for information interference and manipulation. This category encompasses established digital terrain, such as social platforms. The second key driver is the imposition of regulatory and sanctions restrictions within the EU, which significantly impede the spread of the Kremlin’s core narratives and agenda. It is precisely this external pressure and obstruction that have catalyzed the increased migration and activity of Russian state-affiliated propaganda resources onto the Telegram platform, viewing it as a less regulated frontier.
The Institute for Strategic Dialogue noted in its 2022 report that before the ban, the Twitter accounts of RT and Sputnik France actively promoted their Telegram channels (from 1 January to 28 February 2022, the word ‘Telegram’ was the most frequently used in posts by these accounts).Even with Telegram’s restrictions, the Russian FIMI ecosystem itself demonstrates a high degree of organizational and strategic adaptability.
The Centre for Democracy and Rule of Law identified several key tactics to evade them. For instance, sanctioned channels mask themselves under alternative names to complicate platform identification and enforcement. Visually, the channel may appear dissociated from the original propaganda resource, yet it functions as its de facto component, allowing for the continuous dissemination of prohibited content.
Russian actors create alternative but also duplicate Telegram channels. A single sanctioned entity may maintain ‘unofficial’ copies, allowing it to expand reach and bypass restrictions. The Centre for Democracy and Rule of Law, for instance, found a parallel RT channel with an identical name and image and synchronized publication times. The only operational difference was content selectivity not all posts were duplicated, only key narratives. This finding is strongly corroborated by the Alliance for Securing Democracy (ASD) study, which recorded the largest number of accounts fully or partially copying official RT and Sputnik content, precisely on Telegram, significantly more than on any other platform.
Additionally, Russia utilizes a widespread global distribution network. Sanctioned content is actively spread through Russian embassies, propagandists, international Russian/pro-Russian networks, and local pro-Russian actors across European countries. Key representatives of Russian propaganda and ‘soft power’ strategically use their personal or affiliated Telegram channels to disseminate prohibited content. Crucially, the official Telegram channels and accounts of Russian embassies in various countries have become a primary circumvention method. Their diplomatic status provides this ‘propaganda mouthpiece’ with legal cover, making direct blocking significantly more complicated. The Institute for Strategic Dialogue (ISD) research notes that in France, the Russian Embassy effectively replaced the blocked RT France and Sputnik, shifting its social media focus since March 2022 to become the main re-broadcaster of Kremlin narratives.
Furthermore, international Russian and pro-Russian propaganda networks serve as persistent mechanisms for disseminating sanctioned content. This approach is particularly dangerous because original materials are often created in Russian but are disseminated on Telegram in other European languages, dramatically expanding potential audience reach and moving sanctioned content beyond the Russian-language segment to acquire a full international dimension.
The Centre for Democracy and Rule of Law has identified another trend: the call for users to transition to Max (a Russian messenger released in 2025 by the VK company well known by its Russian clone of Facebook — Vkontakte). Regional Sputnik Telegram channels are suggesting that Russian-speaking populations in other countries read content on Max. Similar proposals to subscribe to Max pages were found in foreign-language Telegram channels, such as InfoDefence France 1. This signals a new stage: a combination of an old migration strategy with a new platform. Following the previous migration of Russian propaganda to Telegram, these new calls to switch to Max demonstrate the ongoing effort to pre-emptively adapt to potential Telegram restrictions and maintain influence over foreign audiences, especially among Russian-speaking users.
Telegram`s technical gaps
The study by the Centre for Democracy and Rule of Law highlights a series of technical gaps within the Telegram platform that allow content from sanctioned resources to continue circulating widely and unhindered.
The most prominent gap is selective and inconsistent blocking. While the EU has suspended the broadcasting and revoked the licenses of 27 Kremlin-backed propaganda resources, the platform’s enforcement remains piecemeal. Specifically, the study found that at least one Telegram channel is blocked for only 16 of these resources, while the channels of nine other sanctioned entities remain fully accessible without any technical restrictions (the Telegram channels for two sanctioned resources could not be identified). Furthermore, different language, regional, or thematic versions of the same propaganda resource are blocked only partially and inconsistently.
Another critical technical vulnerability is Telegra.ph, a free and anonymous service for creating and publishing articles developed by Telegram itself. Leveraging this platform allows actors to bypass not only sanctions-related blockages but also any additional checks or restrictions that might apply to official, state-affiliated domains. For example, the study of the Centre for Democracy and Rule of Law found this method being utilized on the Telegram channel page of the Russian Embassy in France. Here, the Telegra.ph platform is used for familiarization with full publications in the language of the local audience. Messages on Telegram contain a short announcement or quote, followed by a link to the Telegra.ph page with the full translation. It is worth noting that even if the same article is already available in French on the official website of the Russian MFA, the Telegram channel still publishes the version from Telegra.ph. This indicates a desire to create an additional, more difficult-to-track or block content dissemination channel.
Another way to bypass sanctions restrictions on Telegram is the use of the forwarded messages function. Blocking the channel itself proves insufficient because its content can be instantly forwarded to another channel without any technical impediments. As a result, the user gains full access to the material (text, images, video, audio), even if the original channel is subject to sanctions restrictions and is blocked.
Controversial Telegram`s regulatory status in the EU
Telegram’s ability to remain a “safe haven” for Russian FIMI is critically underpinned by its regulatory status within the European Union, which significantly limits the intensity of regulatory control.
The core of the issue lies in Telegram’s public provision of rounded data on the number of users in the EU, which complicates its classification as a Very Large Online Platform (VLOP) under the Digital Services Act (DSA). Although Telegram has not yet been designated as a VLOP, some of its features can be classified as “online platforms” under the DSA, and therefore it must already comply, for the features under the scope of the DSA, with the rules applicable generally to intermediary service providers. However, Telegram does not need to comply with the most stringent DSA requirements, creating an accountability gap that benefits malign actors.
In August 2024, the European Commission’s Joint Research Centre (JRC) initiated a technical investigation into Telegram’s user numbers, specifically referencing Article 24 of the DSA.
Telegram is notably not a signatory to the enhanced Code of Practice on Disinformation. From July 1, 2025, the Code’s obligations became auditable and serve as a possible reference for assessing if VLOPs (which Telegram is not designated as) effectively mitigate relevant systemic risks.
Furthermore, Telegram’s internal policy on disinformation vaguely states that if reliable accounts are registered on the platform, users automatically gain access to credible information. This policy is insufficient: users do not have a specific, formal mechanism for reporting disinformation, leaving the platform to decide how, and whether, to respond to the spread of fakes.
Russian FIMI has evolved into a highly adaptive ecosystem, exploiting both technical gaps and a critical regulatory vacuum to circumvent EU sanctions. The threat is fluid and cannot be neutralized by isolated platform decisions. The EU’s response must move beyond platform governance to address all components of the FIMI lifecycle those who create, distribute, and consume the content.
A more coordinated, continuous, granular monitoring of internal information environments would be vital to rapidly identify masked distribution channels and new migration attempts, ensuring a timely operational response to manifestations of Russian content.
Member States must significantly invest in increasing the level of media and information literacy among the population. This empowers citizens to critically assess the content and tactics used by propagandists, directly weakening the final link in the FIMI chain — the consumer.
Only a strategy that simultaneously strengthens regulation, ensures platform accountability, and builds cognitive resistance among its citizens can effectively counter this threat.
By Iryna Subota, for EUvsDisinfo
