"There is literally zero funding": Understanding the Emerging Role of Trusted Flaggers under the EU Digital Services Act

2026-03-31

AI Summary

This study examines the structural challenges confronting trusted flagger entities during the early implementation phase of the European Union’s Digital Services Act, particularly resource constraints, platform cooperation barriers, and role adaptation difficulties. Drawing on in-depth interviews with representatives from seven certified flagger organizations and participatory workshops, complemented by a policy analysis framework, the research systematically uncovers post-certification operational burdens—including cumbersome procedures, sharply increased workloads, and misaligned platform objectives. The findings underscore an urgent need for standardized support mechanisms tailored to the resource limitations of flaggers and highlight the critical importance of integrating user-representative perspectives to strengthen the content governance ecosystem. This work provides empirical grounding and innovative pathways for refining regulatory implementation under the Act.

Abstract

The European Union's Digital Services Act (DSA) introduced regulatory mechanisms which serve as a way to manage harmful content online. The recognition of Trusted Flaggers (TFs) is one such mechanism which accredits entities with experience, platform independence, and skill in identifying and reporting illegal content. With the DSA's TF role being roughly one year old, we interviewed representatives of seven such TF organizations to learn about their experiences of becoming a TF and how it impacts their interactions with online platforms and with individual users. We additionally ran a workshop involving TF representatives, primarily as it was requested by TFs themselves, who collectively wanted to share experiences of their new role and learn from each other rather than be isolated. Notably, we found that accreditation as a TF can be cumbersome, that resources for TFs remain the same despite an increasing workload, and that platforms priorities often diverge from TFs. We conclude with recommendations for future research into understanding user representation within the DSA and the need for standardization measures tailored to the needs and resource constraints of TFs.

Problem

• Trusted Flaggers
• Digital Services Act
• content moderation
• online platforms
• regulatory compliance

Innovation

• Trusted Flaggers
• Digital Services Act
• content moderation
• online platform regulation
• qualitative study