Transparency in online content moderation isn't merely a fundamental rights issue — it is also about safeguarding democracy. The increased transparency in content moderation introduced by the Digital Services Act (DSA) will play a crucial role in identifying the risks posed to, inter alia, online civic discourse and the electoral process, particularly as it creates transparency obligations for platforms such as Google’s Youtube and Meta’s Facebook.
Under Article 34, Very Large Online Platforms (VLOPs) and Very Large Online Search Engines (VLOSEs) are required to monitor ‘content moderation systems’ to identify systemic risks. Related mitigation measures include, among others, ‘adapting content moderation processes’ (Article 35).
Article 15 of the DSA requires providers to submit transparency reports concerning content moderation on their services. In order to guarantee the quality and consistency of reports, the European Commission has chosen a standardised reporting system. To this end, it has adopted an Implementing Regulation under the DSA to create a report template.
Civil Liberties Union For Europe (Liberties) in collaboration with the European Partnership for Democracy (EPD) participated in the Commission’s public consultation process on the DSA Implementing Regulation by submitting the following recommendations to shape the transparency report template.
1. Ensure the reports are clear and easy to understand
It is vital to provide context and clearer explanations for specific data fields. Providers should explicitly link the content of the Qualitative Template to relevant metrics, and they should be granted flexibility in incorporating qualitative reporting in order to achieve this.
2. Contain meaningful information
The information provided should be meaningful and create a basis for further proceedings. Therefore, the details on the input/removal requests, the initiator, including the trusted flagger and their relationship to governments and their authorities and bodies, the number of pending cases, thematic areas, and language should all be accessible. Transparency should provide proper information on how VLOPs and VLOSEs conduct content moderation and how thoroughly they investigate requests. It is also crucial to know who and why to initiate content moderation.
3. Facilitate public access and processing of data
We suggest that the European Commission make the DSA transparency reports easily accessible to the public by proactively publishing them on a dedicated platform in a timely manner.
You can read our response in full here.
See also our paper focusing on risk assessments and risk mitigation measures for civic discourse and electoral processes stemming from Articles 34 and 35 of the DSA.