DSA complaint: Meta’s monetization enforcement and reporting

 
 
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WHAT TO FIX files DSA complaint over Meta’s monetization enforcement and reporting failures

WHAT TO FIX filed a complaint against Meta Platforms Ireland Ltd. with the Netherlands Digital Services Coordinator, alleging violations of Articles 12, 14, 16, and 20 of the Digital Services Act.

By WHAT TO FIX - September 21, 2026
 
 
 
 
On 16 September 2026, WHAT TO FIX filed a complaint with the Netherlands Authority for Consumers and Markets (ACM), the Dutch Digital Services Coordinator, raising concerns about Meta’s inconsistent enforcement of its monetization terms and the inadequacy of its DSA-mandated user reporting pathways to handle reports of suspected monetization violations and illegal activity.
WHAT TO FIX calls on regulators to investigate Meta’s compliance with the following Digital Services Act (DSA) provisions and to require effective remedies where necessary:
  • Points of contact for recipients of the service (Art.12)
  • Monetization terms and conditions (Art.14)
  • Notice-and-action mechanisms (Art.16)
  • Internal complaint-handling systems (Art.20)
Read the complaint →
 

The basis for the complaint

 
Between June 2025 and July 2026, WHAT TO FIX made repeated attempts to alert Meta to 11 accounts seemingly affiliated with EU-sanctioned actors that displayed signs of access to its monetization products, in possible breach of EU sanctions law.
As of 20 July 2026, 4 of the 11 Facebook accounts reported by WHAT TO FIX continued to display signs of monetization access, despite WHAT TO FIX’s credible and repeated escalations via DSA-mandated mechanisms, public reporting and direct engagement with company executives and press teams.
 

Inconsistent enforcement of Meta’s monetization terms (Article 14)

Our complaint argues that Meta lacks reliable systems for detecting and enforcing its monetization terms and policies in a diligent, objective and proportionate manner, including when explicitly notified of suspected violations.
Using our Meta Monetization Archive and publicly observable signals, we documented:
  • Accounts that appeared to lose access to monetization products only to regain access a few weeks later.
  • Accounts that appeared to be restricted from some monetization products but not others.
  • Accounts that continued to display signs of monetization despite multiple reports.
We escalated our findings on multiple occasions, including through Meta’s DSA-mandated notice-and-action, internal complaints, and compliance-contact mechanisms.
Wherever possible, our escalations identified the accounts’ precise location, the legal basis for the legal-compliance concern, and evidence of ongoing monetization access.
Despite credible reports, Meta did not consistently acknowledge, investigate or act on our notices and accounts seemingly affiliated with EU-sanctioned entities continued to display signs of monetization.
 

No suitable pathway to process notices of illegal monetization (Article 16)

Our complaint argues that Meta’s notice-and-action mechanisms do not support the adequate handling of notices of suspected illegal activity involving monetization of content.
When attempting to use Meta’s DSA-mandated notice-and-action mechanisms to report suspected illegal activity involving monetization, we encountered various barriers:
  • Meta’s Legal Removal Request forms focused on categories such as intellectual property, defamation, privacy and illegal content, that did not adequately account for monetization;
  • Team members outside the EU could not access the reporting flow or forms, suggesting that Meta may be geo-gating its notice-and-action mechanisms.
Meta’s handling of WHAT TO FIX’s notices was also inadequate:
  • One submission received no response beyond an automated confirmation;
  • Another prompted an immediate automated message indicating that the issue might not be supported by the legal removal request reporting channel;
  • Meta’s requests for additional information arrived in disconnected email threads without case references, making them difficult to match to specific notices;
  • Meta’s follow-up messages appeared templated and did not respond to questions raised, including requests for a direct legal-compliance contact.
Two days later, from 22 July onward, WHAT TO FIX noted that the 4 accounts no longer displayed publicly observable monetization indicators. Meta did not notify WHAT TO FIX of any decision or enforcement action.
 

Internal complaint-handling system did not address monetization (Article 20)

Our complaint argues that Meta’s internal complaint-handling system does not provide adequate means of challenging Meta’s decisions regarding suspected monetization violations.
Facebook’s in-product reporting system offers no dedicated option to report a content or account for monetization violation. The decision notifications we received in response to our reports indicated that the accounts had been assessed against Facebook’s Community Standards rather than Meta’s monetization terms and policies.
When attempting to use Meta’s DSA-mandated internal complaint-handling system to challenge Meta’s initial decisions, we faced the following challenges:
  • no option to specify the nature of our reports or provide a written explanation or attachments to substantiate our complaints;
  • Defective ‘Request Review’ button.
We complained about these shortcomings using Meta’s provided “file a separate complaint about our reporting process” option. Those complaints generated automated confirmations but no meaningful follow-ups or remedy.
 

No effective legal and compliance contact (Article 12)

Finally, our complaint argues that Meta disclosed points did not provide an effective means of raising legal compliance concerns related to monetization.
We tried to identify an electronic point of contact to raise our monetization compliance concerns via Meta’s help center, AI Support Assistant, and direct emailing with the company.
Meta either did not respond to our inquiries or redirected us to its standard electronic reporting forms, none of which appeared suitable for reports about potentially illegal monetization.
 

WHAT TO FIX: Our recommendations

 
Taken together, Meta’s inconsistent monetization enforcement, unsuitable notice-and-action mechanisms, ineffective internal complaint routes, and lack of an effective compliance contact raise concerns about Meta’s compliance with Articles 12, 14, 16 and 20 of the DSA, with respect to the provision of its monetization products.

pointMonetization-related compliance with the DSA

Our complaint calls on ACM to investigate Meta’s compliance and require Meta to adopt timely and effective remedies, with a particular focus on the following:
  • Monetization terms that outline Meta’s approach to monetization enforcement and clearly identify internal complaint routes and their rules and procedures;
  • Monetization enforcement systems that are suitable to identify violations of Meta’s monetization terms and policies and guarantee diligent, objective and proportionate enforcement;
  • Notice-and-action mechanisms that are available to all individuals and entities, regardless of their location, and enable the processing of notices related to suspected illegal content monetization;
  • Reporting pathways that support the reporting of suspected monetization violations—whether via dedicated reporting options or via the processing of existing reports against monetization terms and policies in addition to Community Standards;
  • Internal complaint-handling systems that allow users to specify when a complaint concerns an alleged violation of monetization terms and policies and offer text and/or attachment fields to enable users to substantiate their complaints;
  • Compliance points of contact that include an electronic channel enabling direct and rapid communication with Meta’s legal and compliance teams about all kinds of legal compliance issues, including in relation to Meta’s provision of monetization products;
  • Meaningful transparency about monetization practices, enforcement, and commercial relationships, that mirror existing advertising-transparency and enable effective oversight.
 

pointMonetization policies and enforcement as a risk factor

Meta facilitates payments at enormous scale. Per its own disclosure, it paid out nearly $3 billion to creators through its creator monetization programs in 2025. As our research continues to show, the weaknesses identified in this complaint are not limited to defective sanctions screening.
Meta’s apparent failures to enforce its monetization rules diligently and consistently, and to process credible user reports has the potential to contribute to systemic risks.
Our audit of very large online platforms’ risk-assessment reports, however, found that Meta did not disclose monetization-related risks and mitigation measures, even as it introduced new monetization features and monetization safeguards during the reporting period.
Given the potential for adverse impact across the Union, as well as the repeated and widespread nature of Meta’s apparent failure to diligently enforce its monetization terms and policies, our complaint also called on ACM to refer the matter to the European Commission for further examination, in accordance with DSA article 65(2).
 
Platforms that facilitate payments at enormous scale cannot treat monetization as a regulatory blind spot. Effective DSA compliance requires clear monetization rules, diligent and consistent enforcement, accessible reporting and complaint mechanisms, and meaningful transparency to guarantee oversight.
 
Read the full complaint →