Facing Facts Network Members Call for Stronger EU Support and Accountability in Trusted Flagger Guidelines
23/07/2026
Brussels, July 2026
The Facing Facts Network Secretariat coordinated the submission of Facing Facts Network members 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 address illegal online hate speech across Europe. Trusted flaggers are organisations with expertise in identifying illegal online content, whose notices platforms must prioritise. The (draft) guidelines aim to clarify, among other aspects, the eligibility requirements, application process , onboarding and processing of notices of trusted flaggers by providers of online platforms and the interplay of the Trusted Flagger role with voluntary mechanisms.
This document presents the coordinated response of the Facing Facts Network to the Targeted Public Consultation on the Guidelines on the trusted flagger mechanism under Article 22 of Regulation (EU) 2022/2065 (Digital Services Act).
This submission has been coordinated and consolidated by CEJI – A Jewish Contribution to an Inclusive Europe, in its capacity as Secretariat of the Facing Facts Network. It reflects direct contributions and feedback from 11 Facing Facts Network member organisations and builds on the collective expertise of the Facing Facts Network, which brings together 41 member organisations across 20 EU countries. The following contributing organisations have consented to be mentioned: DigiQ (Slovakia), Fondazione Centro di Documentazione Ebraica Contemporanea (CDEC) (Italy), Fundación Secretariado Gitano (Spain), Háttér Society (Hungary), Human Rights House Zagreb (Croatia), INACH Secretariat (The Netherlands), Jewish Association Czulent (Poland), Ligue Internationale Contre le Racisme et l’Antisémitisme (LICRA) (France), The “Elie Wiesel” National Institute for the Study of the Holocaust in Romania (Romania), and ZARA – Zivilcourage und Anti-Rassismus-Arbeit (Austria).
A system under pressure
The response comes at a time when many organisations monitoring online hate speech 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. The submission emphasises that organisations monitoring online hate speech have 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. With this input, the Facing Facts Network and its members recommend that this expertise be explicitly recognised within the Guidelines and that funding opportunities, stronger procedural safeguards, transparent investigations, and clear protections for Trusted Flaggers organisations are ensured by the different actors working in implementing this legislation.
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. Facing Facts Online is a learning community where professionals from across Europe and beyond come together to strengthen their responses to hate crime and hate speech. 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.
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