Publication of a study on trusted flaggers and Commission's draft guidelines

IRIS 2026-6:1/15

Justine Radel-Cormann

European Audiovisual Observatory

Article 22(1) of the Digital Services Act (DSA) requires providers of online platforms to take the necessary technical and organisational measures to ensure that notices submitted by trusted flaggers acting within their area of expertise are given priority and are processed and decided upon without undue delay. Those notices are meant to notify the online platforms of the presence on their service of specific items of information that the notifier considers to be illegal content (Article 16 DSA). 

Article 22(2) DSA foresees the award by the Digital Services Coordinator of "trusted flagger" status to applicants with particular expertise in identifying illegal content. 

On 29 May 2026, the European Commission released a study supporting the implementation of the trusted flaggers mechanism under the DSA. 

The study found that similar tasks of notice submission were entrusted to voluntary trusted flaggers created by platforms themselves (very large online platforms) or non-profit organisations. These voluntary flaggers were often chosen on a reputational basis. The study identified 47 voluntary trusted flagger schemes (31 administered by online platforms, 12 by civil society and four by governmental organisations). Some of these voluntary trusted flagger schemes had a specific thematic focus, such as “hate speech, incitement to self-harm and violence”, “negative effects on civic discourse or elections”, “intellectual property infringements”, etc. The most commonly covered areas were IP infringement, cyber violence and protection of minors, and cyber violence against women. The study describes some voluntary trusted flagger schemes such as the “YouTube Priority Flagger Program”, managed by Google, which is open to organisations with expertise in any policy area. Meta manages the “Trusted Partner Programme”, which is also open to organisations with expertise in any policy area. Snapchat and JeuxVideo.com, meanwhile, operate the “Trusted Flagger Program” and “JeuxVideo.com trusted flaggers” respectively. 

Also on 29 May 2026, the European Commission, in accordance with its obligation under Article 22(8) DSA, published guidelines on "Trusted flaggers" (Article 22(8) DSA). The guidelines aim to assist providers of online platforms and Digital Services Coordinators to apply Article 22 regarding the award, suspension and revocation of trusted flagger status, as well as provide interpretative guidance on trusted flaggers. Their publication was accompanied by the launch of a targeted consultation in which the European Commission is seeking feedback from relevant stakeholders. The deadline for submitting feedback is 10 July 2026.


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This article has been published in IRIS Legal Observations of the European Audiovisual Observatory.