The European Commission is seeking feedback until June 26, 2026, on a draft guidance for "trusted flaggers", organizations officially recognized to report illegal online content to platforms. The mechanism is provided for by the Digital Services Regulation and obliges platforms to prioritize these notifications, without transferring the final responsibility to decide whether content is illegal to the organizations.
The European Commission is preparing common guidelines for organizations that receive the status of "trusted flagger" under the Digital Services Regulation, a mechanism through which online platforms must prioritize notifications regarding illegal content.
The draft aims to clarify the criteria based on which national coordinators for digital services grant this status, how platforms and organizations should process notifications, and the necessary guarantees to prevent the system from being abused. The Commission is requesting feedback from platforms, already designated organizations, candidates, researchers, and civil society organizations until June 26, 2026, and the guidelines are expected to be adopted in the second half of 2026.
In short
The European Commission is seeking feedback on guidelines for the "trusted flaggers" mechanism provided for by the Digital Services Regulation.
Online platforms must prioritize notifications sent by these organizations, but remain responsible for deciding whether content is illegal.
Over 70 organizations have already been designated, with expertise in areas such as financial fraud, online harassment, child sexual abuse material, intellectual property rights violations, and other forms of illegal content.
The draft clarifies independence, objectivity, accountability, and the procedures for suspending or withdrawing the status.
The Commission's preparatory study shows that the implementation of the mechanism raises practical issues, including a lack of harmonization among national authorities, difficulties in assessing independence, and the limited capacity of some small organizations.
Under the Digital Services Regulation, "trusted flaggers" are specialized entities in detecting, identifying, and reporting illegal online content. The status is granted by national coordinators for digital services, and organizations must demonstrate expertise, independence from platforms, and the ability to act diligently, accurately, and objectively.
Notifications sent by these organizations must be processed quickly and prioritized by online platforms. The Commission emphasizes, however, that platforms retain the responsibility to verify notifications and decide whether the reported material is illegal. The mechanism covers illegal content, not any type of problematic content or content contrary to the internal rules of the platforms.
The examples indicated by the Commission show the diversity of the targeted areas. Among the already designated organizations are the Bank of Ireland, specialized in financial fraud, Someturva, which deals with online harassment, including the non-consensual distribution of intimate materials, and Child Focus, which works on child sexual abuse materials.
The draft guidelines aim to reduce the differences between national practices. Digital services coordinators must decide which organizations can receive the status, monitor their activities, and can suspend or withdraw the status if notifications are insufficiently precise, inaccurate, or poorly substantiated. The Commission's page on the mechanism shows that the status is valid at the European Union level, in relation to any online platform that falls under the scope of Article 22 of the Digital Services Regulation.
The stakes are double. On one hand, the Commission wants the reporting of illegal content to become faster and more reliable, especially where specialized organizations have knowledge that ordinary users or automated systems do not have. On the other hand, the mechanism must avoid the risk of private, public, or commercial organizations gaining disproportionate influence over online content moderation.
The preparatory study conducted for the Commission shows that the mechanism is still in an early stage and that national authorities, platforms, and potential designated organizations have requested official guidance to reduce uncertainties. The study identifies the lack of harmonization among national coordinators, differences regarding enforcement requirements and assessment procedures, as well as ambiguities regarding the suspension and revocation of status.
One of the most challenging stages is evaluating candidates. The study notes that national authorities have difficulties in verifying expertise and independence, especially in the case of newly created organizations, public bodies, intellectual property rights holders, or organizations that have received funding from platforms.
Another problem is administrative capacity. Designated organizations must publish annual reports on the notifications sent, the types of reported content, and the actions taken by platforms. The study warns that this obligation can become a burden for small organizations, especially for NGOs, if there is no technical support, information exchange, and adequate funding.
The guidelines also include guarantees for freedom of expression. The Commission wants designated organizations to remain independent, objective, and accountable, and the status can be suspended or withdrawn if the mechanism is misused. Organizations will need to publish annual transparency reports, and national coordinators will have the role of overseeing compliance with the criteria.
For users, the practical effect is that certain reports of illegal content should reach platforms faster. For platforms, the mechanism means clearer procedural obligations. For civil society, researchers, and specialized organizations, the status can provide an official avenue for intervention, but also obligations of transparency and accountability.
The Digital Services Regulation applies to online services used by European citizens, including social media platforms, online marketplaces, app stores, and booking platforms. The "trusted flaggers" mechanism is one of the components through which the EU seeks to make the enforcement of rules faster, more predictable, and more controllable, without eliminating the platforms' responsibility for their own moderation decisions.
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