Raising Concerns Over Social Media Companies’ Failure to Disclose Risks Related to Their Monetization Services Under the DSA

 
 
DSA RISK ASSESSMENTS

WHAT TO FIX Raises Concerns Over Social Media Platforms’ Failure to Disclose Risks Related to Their Monetization Services Under the DSA

 
Published: 4 August 2025
 
 
 
On 3-4 June, 2025, WHAT TO FIX joined more than 75 representatives from Very Large Online Platforms and Search Engines (VLOPs and VLOSEs), civil society, and academia in Brussels for the 2025 Rights & Risks Stakeholder Forum, co-organized by the Global Network Initiative (GNI) and the Digital Trust & Safety Partnership (DTSP).
The forum came as VLOPs and VLOSEs are preparing for their next round of DSA systemic risk assessment and mitigation reports, due to the European Commission in August, and to be made public in November 2025.
Over two days of panels and workshops, participants reflected on past reports and explored ways to make the EU-mandated process more meaningful and impactful (see the GNI/DTSP event summary report).

Our Concern : No Disclosure Of Risks Related to Monetization Services

 
WHAT TO FIX’s executive director, Victoire Rio, raised concerns over the fact that none of the social media companies disclosed any risks stemming from the design, functioning and use of their monetization services in their existing DSA reports.
❌  YouTube - https://transparencyreport.google.com/report-downloads
❌  Facebook | Instagram - https://transparency.meta.com/reports/regulatory-transparency-reports
❌  TikTok - https://www.tiktok.com/transparency/en/dsa-transparency
❌  Snapchat - https://values.snap.com/privacy/transparency/european-union
❌  X - https://transparency.x.com/en/reports/dsa-audit-report
❌  Linkedin - https://www.linkedin.com/help/linkedin/answer/a1678508
This is especially concerning as monetization systems have become an inherent characteristic of all major social media platforms, influencing all four categories of systemic risks identified under the DSA:
🚫 Dissemination of Illegal Content -
Platforms monetization decisions can incentivize and finance illegal and illegally acquired content as well as illegal activity.
🚫 Negative effects for the exercise of fundamental rights  -
Platforms monetization decisions can adversely impact creators’ freedom of expression, right to non-discrimination, right to property, freedom to conduct a business, undermine the rights of the child, and negatively impact on media freedom & pluralism, as well as cultural, religious and linguistic diversity.
🚫 Negative effects on civic discourse, electoral processes and public security -
Platforms monetization decisions can incentivize and finance disinformation, bankroll FIMI and political campaigns, and threaten the creation of authentic and public interest content
🚫 Negative effects on physical and mental well-being -
Platforms monetization decisions can incentivize and finance harmful content, incentivize child labor, and fuel feelings of precarity.
Read our Submission to the European Board on Digital Services’ First Annual Report on Systemic Risks →

2025 Reports : What To Expect?

 
We’re hopeful that social media companies will do a better job disclosing how their monetization systems are influencing systemic risks, along with associated mitigation measures, in their upcoming reports to the European Commission.
This is especially important as social media monetization services are rapidly expanding, and platforms are redistributing ever larger sums of money — now in the tens of US$ billions — annually.
Read our Social Media Monetization 2025 report →
The reporting period 2024/2025 was also marked by a number of important developments, which would benefit from being thoroughly assessed and disclosed.
♦️ New and significant changes to monetization services
  • Linkedin launched its first revenue redistribution program - BrandLink (May 2025).
  • Meta consolidated its various revenue redistribution programs under one core program - Content Monetization - expanding payment opportunities to photo and text posts as well as stories in the process (from October 2024).
  • X updated its payment model - shifting from rewarding creators based on ads shown in their replies, to rewarding them based on engagement from paying users (October 2024)
  • Snapchat introduced an affiliate program, rewarding creators for referring advertisers to the platform (April 2025)
♦️ New mitigation measures
  • Meta announced efforts to more effectively demonetize spammy content (April 2025) and introduced new creator notices and on-platform information features to mitigate the monetization of unoriginal content (July 2025).
  • X filed a court case against a group of Vientamese individuals, to mitigate the use of inauthentic automation and fraud associated with its revenue redistribution program (May 2025).
While this list is not exhaustive, it emphasizes platforms’ continued focus on expanding monetization services, and their rising awareness of associated risks and need for mitigations.
Over the 2024/2025 period, we also revealed how Meta has been making monetization services available to EU-sanctioned entities, raising concerns over the viability — and legal compliance — of existing monetization review processes.
Read our report on how Meta engaged in revenue redistribution partnerships with RT, Sputnik and other EU-sanctioned entities →