By Joseph Bernard A. Marzan

A new policy paper urges the Philippines to adopt a rights-based, whole-of-society framework against foreign information manipulation and interference (FIMI), warning that the country’s highly digital public sphere leaves democratic institutions vulnerable to covert influence operations.

The study, titled “Foreign Information Manipulation and Interference in the Philippines: A Rights-Aware Governance Framework for Democratic Resilience in an AI-Mediated Information Environment,” proposed a four-layer Philippine FIMI governance framework.

The proposed framework covers four “layers”: detection and attribution, legal architecture, financial intelligence, and capacity and resilience.

The framework would aim to make covert, coordinated, and foreign-linked manipulation harder to execute, easier to detect, and less damaging to public trust, while avoiding censorship or surveillance architecture.

“The framework follows a simple sequence. A possible FIMI operation must first be detected and assessed. Once a credible basis for concern exists, the applicable legal and institutional standards must determine what is actionable,” the paper said.

“If the activity is sustained through organized resources, the financial and operational infrastructure must be made more visible. Finally, because enforcement cannot reach every operation and because manipulation adapts over time, the country must build durable capacity and resilience,” it added.

The paper was written by Frances Claire Tayco, Ivan Pulanco, and Dominic Ligot of CirroLytix Research Services.

It was developed following an April 29, 2026, hybrid forum convened by CirroLytix and the University of Asia and the Pacific School of Law, with support from Internews and the European External Action Service (EEAS).

The EEAS, the European Union’s diplomatic service, popularized the FIMI concept to describe coordinated, often state-linked efforts to distort the information environment.

Under the first layer, detection and attribution, the paper urged the country to build the capacity to detect coordinated manipulation instead of policing unpopular speech.

It suggested a focus on identity irregularities, behavioral anomalies, network clustering, unusually rapid amplification, repeated narrative synchronization, and strategic targeting of trust-bearing institutions.

The paper cautioned that these patterns should be treated only as signals for analysis and not as automatic proof of wrongdoing.

On the second layer, legal architecture, the paper said any legal framework should define actionable conduct without criminalizing protected expression.

It also raised the idea of “tiered accountability” for active FIMI actors and facilitators, platforms that fail to meet lawful transparency or preservation duties, and low-level procedural violations, as well as institutionalized oversight from all three branches of government.

“The second layer provides the legal architecture required to make FIMI governance actionable. It must define what conduct is covered, differentiate core wrongdoing from facilitation or compliance failures, create proportionate platform obligations, and embed oversight mechanisms,” the paper explained.

“A tiered model is more defensible than treating every role as equally culpable. It allows the law to focus scarce enforcement resources on actors that materially design, fund, or sustain manipulative operations,” they added.

On the third layer, financial intelligence, the paper said the Philippines should examine tools that can help expose the money behind influence operations without creating generalized political surveillance.

Potential areas for scrutiny include recurring payments to amplification operators, abnormal small-value disbursements consistent with paid influence labor, payments routed through intermediaries, foreign-origin funding transferred into domestic political influence ecosystems, and possible virtual asset channels where evidence supports relevant typologies.

“A FIMI framework should therefore examine cross-payment-service-provider intelligence-sharing, subject to strict legal and privacy safeguards. The objective is not indiscriminate information pooling. It is to permit proportionate collaboration where there is a lawful trigger and where payment patterns indicate organized manipulation, fraud, or covert foreign-linked influence financing,” the paper stated.

Under the fourth layer, capacity and resilience, the paper said media, information, and artificial intelligence literacy should be treated as long-term civic infrastructure rather than a one-off awareness campaign.

It recommended literacy programs on narrative seeding, artificial consensus, strategic timing, synthetic personas, emotional targeting, manipulated media, automated amplification, and AI-mediated information retrieval.

The authors said artificial intelligence is changing the operating environment because it can lower the cost of producing content, translating narratives, fabricating personas, and sustaining coordinated engagement.

The paper warned that AI can support “synthetic coordination,” not only synthetic media, by helping actors vary messages across audiences, automate responses, monitor controversies, and make campaigns more adaptive.

At the same time, the authors said analytics, digital forensics, open-source intelligence, and human-governed AI tools can strengthen detection and resilience.

“FIMI cannot be defeated through enforcement alone. A democratic society must become harder to manipulate over time. This requires stronger citizens, safer investigators, better public knowledge systems, and durable networks of cooperation,” the paper said.

The study said the Philippines is particularly exposed because of its heavy reliance on digital platforms, the presence of commercial influence networks, geopolitical tensions over the West Philippine Sea, electoral vulnerabilities, and uneven institutional capacity.

According to DataReportal, the Philippines had 98 million internet users and 95.8 million social media user identities as of late 2025, making digital platforms central to political debate, public controversy, and national security narratives.

The paper emphasized that FIMI should not be treated as ordinary misinformation or disinformation because it is defined by “deliberate, coordinated, and manipulative behavior” carried out by foreign state or nonstate actors, often through proxies or domestic intermediaries, to shape the information environment toward strategic objectives.

“FIMI can include falsehoods, but it is not defined by falsity. It may rely on: accurate but selectively presented facts; authentic documents placed in misleading context; real grievances amplified at strategic moments; legitimate public controversies artificially intensified through coordinated behavior; true institutional weaknesses reframed to degrade trust more broadly,” it said.

The distinction matters because influence operations may use false claims, but they may also rely on true information that is selectively framed, repeatedly amplified, or weaponized through coordinated behavior.

“The distinction between disinformation and FIMI is especially important. Disinformation analysis often begins with content: whether a claim is false, misleading, or deceptive. FIMI analysis begins with conduct: whether actors, platforms, accounts, and amplification systems are being coordinated in manipulative ways to achieve strategic objectives,” the study said.

The recommendations come as Philippine officials and lawmakers increasingly discuss foreign interference and information manipulation as national security concerns.

The House Committee on National Defense and Security formed a technical working group in February 2026 to consolidate bills seeking to regulate and penalize foreign interference, according to the House of Representatives.

CASE STUDIES

The paper used the February-March 2026 attacks against the Philippine Center for Investigative Journalism (PCIJ) as a case study of how FIMI-relevant activity may operate in practice.

The PCIJ, at the time, republished a video explainer on identifying pro-China propaganda patterns in Philippine media and online spaces.

Within days, statements were issued through the Chinese Embassy in Manila’s public communication channels questioning the PCIJ’s independence and emphasizing its past funding from the U.S. government’s National Endowment for Democracy.

A PCIJ report based on data compiled by the group Democracy.net.ph found that the initial embassy post was also shared within about two hours by 107 accounts with a combined estimated reach of nearly 3 million followers.

The analysis examined more than 640 unique Facebook accounts and assessed 219 as having a medium to high likelihood of inauthenticity.

Across five analyzed anti-PCIJ posts, 21.4 percent to 34.6 percent of commenting accounts and 9 percent to 25 percent of sharing accounts were flagged as having high inauthenticity signals.

The paper said the PCIJ case does not establish every possible legal or operational inference, including direct payment relationships for every amplifier, individual intent for every account, complete platform-side coordination evidence, or immediate criminal liability under existing law.

“These limitations are not weaknesses of the analysis. They clarify the institutional need for stronger evidence-preservation mechanisms, platform transparency, financial intelligence, and carefully designed legal thresholds,” they said.

STABLE RESPONSE

In the paper, the authors said the Philippines should avoid both underreaction and overreaction.

“A weak response would leave the country exposed to covert foreign-linked manipulation. An overbroad response could damage the freedom it claims to defend,” the paper said.

The authors said the country’s response should focus on coordinated manipulative conduct rather than viewpoint alignment, strengthen evidence and accountability without becoming a truth-policing mechanism, and improve visibility into platforms and financial infrastructure without creating generalized surveillance.

The paper said the Philippines already has important assets, including investigative journalists, civic researchers, public-interest technologists, legal experts, civil society organizations, and institutions that are beginning to recognize the problem.

“A democratic response to FIMI should build the shield before swinging the sword,” the paper said.