This second report prepared by the Centre for Media Pluralism and Media Freedom (CMPF) for EDMO offers a summary of the iterative process of developing structural indicators for the Code of Practice on Disinformation (the Code). It contains a strengthened proposal for structural indicators, including implementation challenges. The report also includes a record of the overall process around structural indicators, as well as the specific process employed by EDMO in contributing to it. While the initial EDMO proposal for structural indicators is publicly available, it is also briefly outlined in Annex II of this report. The main novelties in the new proposal consist in an adjustment of metrics – based on expert feedback and the experiences of a first beta assessment by a third-party – a shift from an analysis of large datasets to data collection based on API-access, as well as an initial assessment of the feasibility of additional structural indicators. The core indicators in the new proposal are all based on the initial set of indicators: prevalence, sources, and audiences of disinformation, as well as collaboration and investments in factchecking – but their metrics are improved and adapted to provide a fuller picture of the problem. Further, limited metrics are provided to assess the monetisation of disinformation, the crossplatforms spread of disinformation, as well as cooperation across platforms – but these need to be further assessed and debated by stakeholders and experts – especially in the case of the (de)monetisation of disinformation. Finally, we looked at the possibilities of proposing indicators that assess algorithmic amplification and the resilience of audiences; while the former we see better served in the context of service level indicators, self-reported by platforms, the latter requires further research by technology experts – thus, the only metric on algorithms (recommendation of content) we found feasible in the current context is incorporated in the proposed indicator on prevalence of disinformation. For a fuller picture, we propose to complement the data collection with surveys and ask platforms and researchers to provide updates on data access, collaboration with researchers, the state of disinformation research in the EU, as well as platforms’ investment in fulfilling the Code’s commitments. As the first structural indicators were tested and the existing proposal is being strengthened, it is important that the scope of assessments increases – both in terms of indicators and the number of countries covered – with every new pilot. Various methodologies and approaches still need to be tested towards a more stable and comprehensive set of Indicators. We argue that, in the long-run, a systematic implementation of structural indicators, which would include their testing, reporting and improvements, is best placed in a multi-year research project that is adequately financed and assures the independence of the researchers in the process. From our perspective and based on extensive consultations with experts, this emerges as the only viable solution to secure a robust implementation. Such a pan-European research project would also be beneficial for the enforcement of the Digital Services Act, especially in relation to the systemic risks assessment.