WHAT TO FIX’s Submission To The DSA’s Article 40 Delegated Act

As the EU’s Digital Services Act (DSA) continues to take shape, the European Commission solicited input on the application of Article 40, which requires very large online platforms and search engines (VLOPs and VLOSEs) to provide access to their data for the purpose of conducting research into the detection, identification and understanding of systemic risks in the Union.

The commission requested input on the types of data, metadata, and data governance documentation which should be requested for the purpose of monitoring and assessing compliance and conducting research related to systemic risks and mitigation measures.

At WHAT TO FIX, we’re particularly concerned by the impact of social media monetization services on systemic risks - and concerned by how under and over enforcement of monetization terms and policies are fueling harmful content and behavior, while also undermining unique content creation and media freedom.

We recommended that social media platforms provide access to the following data:

Data on the enforcement of their monetization policies - including qualitative information on the processes and systems in place, as well as quantitative metrics on actions taken

Data on the monetization status and history of content and accounts restricted for platform or legal violation

Data on the geographic origin of monetized pages publishing in European Union languages

We made the case that the above data would enable much needed research into:

The extent to which platforms are channeling funds to actors involved with illegal or harmful content or activity

The extent to which platforms’ current rollout of monetization programs is contributing to the proliferation of mis-and disinformation

The extent to which platforms’ current rollout of monetization programs is negatively impacting media freedom and pluralism, as well as freedom of expression and information