Democracy Shield: WHAT TO FIX’s Position Paper

 
 
Blog > Policy

Democracy at Risk:
Regulating Social Media Monetization Services under the Democracy Shield

Published: January 15, 2026
 

As the European Democracy Shield takes shape, WHAT TO FIX calls on the EU to introduce robust monetization oversight to protect information integrity, guarantee electoral integrity and safeguard EU media and authentic creators.

 
 
 
Social media companies pay billions to content publishers every year through their monetization services, with minimal transparency or oversight.
WHAT TO FIX has been pioneering research into social media monetization governance since 2019. Our research points to routine violations of platform monetization policies as well as increasingly unfair monetization terms, which present a serious threat to democracy in the EU.
Notably, we find that platforms offer revenue generating opportunities to EU-sanctioned entities, FIMI actors, political parties, politicians and government-affiliated entities, as well as frequently incentivize – and financially reward – foreign, inauthentic and policy violating activity.
European media and creators, meanwhile, were dispossessed of the ad placements they once owned on social media and are increasingly at the mercy of automated and unaccountable royalty payment processes, which threaten the viability of their activity and the quality and plurality of the European information ecosystem.
 

Recommendations
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dot Assert the Applicability of EU Digital Service Regulations to Social Media Monetization Services

 
Risk Management Approach - the Democracy Shield should assert the applicability of the DSA risk management framework – intended to provide a future-proof approach to mitigating systemic risks to the Union stemming from the design, functioning and use of digital services – to social media monetization services.
  • DSA Art. 34 - DSA Art. 34 should be interpreted as requiring VLOPs to assess the impact of their monetization systems across all systemic risks to the Union on an annual basis, as well as prior to deploying functionalities that are likely to have a critical impact on the risks identified.
  • DSA Art. 35 - DSA Art. 35 should be interpreted as requiring VLOPs to put in place and disclose annually reasonable, proportionate and effective mitigation measures to the monetization risks identified.
 
Transparency - the Democracy Shield should clarify and expand EU transparency obligations to enable meaningful oversight of platforms’ monetization practices.
  • DSA Art. 15 -  DSA Art. 15 should be interpreted as requiring online platforms to disclose the number of monetization restrictions applied during the reporting period. Monetization restrictions should be categorised by type of violation (content policies, monetization policies, monetization terms), detection method (proactive, reactive) and the type of restriction applied (Meta’s DSA transparency report January-June 2025, section 15.1.c offers a useful example). Art. 15 should also require platforms to report on the number of complaints they received in respect to these monetization restrictions and the number of instances where platforms’ decisions were reversed.
  • DSA Art. 45  - the EU Code of Conduct on Disinformation should be updated to account for platforms’ increasingly diversified monetization offerings beyond advertising related services. These include performance based royalty programs, subscription and tip services, and branded content partnerships. A dedicated Code of Conduct on Monetization could also be envisioned.
  • DFA - the upcoming Digital Fairness Act (DFA) should guarantee EU consumers access to information on the monetization status of the accounts they interact with.
 
Best practices - the Democracy Shield should assert that VLOPs’ monetization services are subject to EU and national laws and clarify that best practices regarding legal compliance will be further specified through upcoming DSA Codes of Conduct (Art. 45), DSA Guidelines and annual reports by the Board of Digital Services (Art. 35).
 

dot Guarantee Adequate Oversight of the Use of Social Media Monetization Services in the Context of Elections

 
Risk Management Approach - the Democracy Shield should integrate an explicit mention of social media monetization as a source of financing, which may benefit political actors and their campaigns and enable and facilitate violations of election finance laws.
  • DSA Art. 34 - DSA Art. 34 should be interpreted as requiring VLOPs to identify and assess the risks of their monetization services enabling or facilitating violations of election finance laws. Notably, platforms should be required to discuss the risk of their monetization services enabling illegal donations, as well as processing fund transfers benefitting political actors and their campaigns in violation of legal sourcing and disclosure obligations.
  • DSA Art. 35 - DSA Art. 35 should be interpreted as requiring VLOPs to report on the mitigation measures they put in place to prevent (or otherwise mitigate) the abuse of their monetization services in the context of elections. They should also be required to outline their approach to ensuring the effectiveness of these measures.
 
Transparency - the Democracy Shield should call for transparency on the monetization contracts entered into with political actors by VLOPs and the funds transfers issued in their benefit.
  • DSA Art. 15 - DSA Art. 15 should be interpreted as requiring VLOPs that opted to prohibit access to their monetization services to political and government actors to disclose the number of such accounts they demonetized, categorized by sub-type, over the reporting period.
  • DSA Art. 18 - DSA Art. 18 could be expanded to require VLOPs to notify national Election Commissions when a monetization contract is entered into or a fund transfer is issued that is suspected to benefit a political candidate or political party during an election campaign and would require formal disclosure.
 

dot Strengthen the Financial Protections of European Media and Authentic Creators

 
Fair contracting - the Democracy Shield should assert the right of EU media and authentic creators to fair monetization terms, as well as explicitly call for financial compensation in instances where these terms are violated by platforms.
  • DFA - the upcoming Digital Fairness Act (DFA) should build on the EU Directive on Unfair Terms in Consumer Contracts to specify what constitutes unfair terms in the context of standard monetization contracts. The DFA should identify a clear pathway for EU consumers to challenge unfair terms as well as unfair enforcement, and clarify how EU consumers may access remedy, including in the form of financial compensation.
 
Transparency - the Democracy Shield should call for transparency on the monetization restrictions of EU media actors.
  • EMFA Art.18 - should be interpreted as requiring VLOPs to disclose the number of monetization restrictions applied against media service providers, as identified through EMFA self-declarations, within a given year. Disclosure should include the grounds for restriction, as well as the number and outcomes of associated dialogues. This reporting should come in complement to the reporting made under DSA Art. 15 discussed above.