Facing Facts Network Calls for Stronger EU Support and Accountability in Trusted Flagger Guidelines
23/07/2026
Brussels, July 2026
The European Commission is seeking feedback on draft guidelines for the Trusted Flagger mechanism under the Digital Services Act (DSA). Trusted flaggers are organisations with expertise in identifying illegal online content, whose notices platforms must prioritise. The guidelines aim to clarify the roles and obligations of trusted flaggers, online platforms, and Digital Services Coordinators.
The Facing Facts Network has submitted its response to the European Commission’s public consultation on the draft Guidelines for the Trusted Flagger mechanism under the Digital Services Act (DSA), urging stronger protections, sustainable funding and greater platform accountability to ensure the mechanism can effectively combat illegal online hate speech across Europe.
Drawing on the expertise of eleven member organisations from across Europe, the submission highlights the growing challenges faced by Trusted Flaggers – civil society organisations designated to identify and report illegal online content. While the DSA recognises their important role, the Network argues that the draft Guidelines place disproportionate obligations on Trusted Flaggers without providing the resources, safeguards and recognition necessary to carry out this public-interest function effectively.
A system under pressure
The response comes at a time when many organisations monitoring online hate are facing increasing pressure. According to the Network, platforms are rolling back content moderation protections while hate and polarisation continue to grow online. At the same time, many civil society organisations are struggling with limited resources, increasing administrative burdens and the psychological toll of monitoring harmful content. Some organisations are even reconsidering whether they can continue serving as Trusted Flaggers under the current conditions.
Eight key priorities for stronger Guidelines
The Facing Facts Network identifies several areas where the draft Guidelines should be strengthened.
First, the Network calls for sustainable and independent funding for Trusted Flaggers. Rather than relying on direct platform funding, it proposes a Commission-administered funding mechanism financed through contributions from internet intermediaries, helping preserve operational independence while ensuring organisations can meet their responsibilities.
Second, the response argues that the Guidelines should be firmly anchored in fundamental rights, recognising Trusted Flaggers’ contribution to protecting both freedom of expression and the right to live free from abuse and discrimination. The submission also recommends preventing commercial Trusted Flaggers from charging victims or victim support organisations for reporting services.
Third, the Network highlights a significant imbalance in accountability. While the draft Guidelines contain detailed requirements for Trusted Flaggers, they place comparatively few enforceable obligations on online platforms. The submission calls on the European Commission to develop clearer guidance governing platform responsibilities and their interactions with Trusted Flaggers.
The response also recommends clearer rules for cooperation with law enforcement, including preserving removed content for at least six months to facilitate criminal investigations and judicial redress, as well as improved coordination between Trusted Flaggers, Digital Services Coordinators and police authorities.
Recognising expertise and protecting Trusted Flaggers
The submission emphasises that organisations monitoring online hate possess specialised knowledge that is often overlooked. This includes expertise in recognising coded language, context-dependent hate speech and forms of discrimination targeting different communities and languages across Europe. The Network recommends that this expertise be explicitly recognised within the Guidelines.
The response also raises concerns about the potential misuse of the Trusted Flagger mechanism, including bad-faith complaints against organisations that expose shortcomings in platform moderation or attempts by extremist actors to obtain Trusted Flagger status. The Network recommends stronger procedural safeguards, transparent investigations and clear protections against abusive allegations.
Building a stronger Trusted Flagger ecosystem
Beyond the draft Guidelines themselves, the Facing Facts Network calls for greater investment in training, structured dialogue and cooperation across Europe. The submission recommends that the Commission support existing initiatives such as Facing Facts Online, establish regular multi-stakeholder forums and facilitate cross-country exchanges between Trusted Flaggers to improve consistency and share best practice.
The Network also urges the Commission to strengthen oversight of platforms alongside oversight of Trusted Flaggers, ensuring that both sides of the mechanism are held accountable for fulfilling their responsibilities under the Digital Services Act.
A collaborative contribution
The response was coordinated by CEJI – A Jewish Contribution to an Inclusive Europe in its role as Secretariat of the Facing Facts Network. It draws on contributions from member organisations across Europe, including current Trusted Flaggers with extensive practical experience of reporting illegal online hate speech and engaging with platform moderation systems. The submission reflects discussions held during the Facing Facts Network Annual Meeting in Vienna in June 2026, bringing together civil society organisations, Digital Services Coordinators and other stakeholders working to strengthen Europe’s response to online hate.
As implementation of the Digital Services Act continues, the Facing Facts Network hopes its recommendations will help create a Trusted Flagger mechanism that is adequately resourced, rights-based, transparent and capable of delivering stronger protection for victims and communities across Europe.
