Online disinformation poses a threat to contemporary societies, as it potentially undermines the principles and grounding processes of Western democracies through the intentional distortion of events. By exploring the contemporary scenario, this paper intends to highlight the role of non-state actors in the contemporary techno-social system, where they stand a potential supporters or challengers of counter-disinformation policy in the Eu geopolitical arena. Our investigation analyses the policy process from 2015 to 2022, which resulted in the enactment of the Digital Service Act (DSA). It represents the legislative instrument to regulate the services offered by online platforms and is part of a broader package of digital single-market reforms. The analysis is based on secondary empirical materials, such as theoretical and empirical literature, and policy documents, in order to detect the type of multi-level governance shaped by the DSA. The results of this exploratory investigation detect the potential benefits as well as critical issues of the new European governance, with specific reference to the counter-disinformation policy. Findings also provide insights into the modulation of the regulatory framework over the last decade and a basis for future investigations concerning the actual implementation of the DSA at the end of 2023.