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

Marie-Therese Sekwenz, Kyle Beadle, Simon Parkin

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.

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

Paper Structure

This paper contains 33 sections, 3 figures, 1 table.

Table of Contents

  1. Introduction
  2. Background
  3. Related Work
  4. Flagging as content moderation measure
  5. A Legal Lens on Trusted Flaggers
  6. Method
  7. Semi-structured interviews
  8. Interview recruitment and participants
  9. Participating organizations -- website analysis
  10. Interview analysis
  11. Validation workshop
  12. Limitations
  13. Results
  14. Trusted Flagger activities
  15. Trusted Flagger activities and users
  16. ...and 18 more sections

Figures (3)

  • Figure 1: Steps in our engagement with Trusted Flagger entities.
  • Figure 2: Statement of Reason Database Capturing Information About TF Notices About Restriction Types and Violations by Statement of Reason Category Reason taken on the 11/5/2025 european_commission_dashboard_2025noauthor_api_nodate.
  • Figure 3: Statement of Reason Database Capturing Information About Content Type and Content Moderation Measures of TF Notices taken on the 11/5/2025 european_commission_dashboard_2025noauthor_api_nodate.