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 systems

The complaint calls for Meta to be investigated for potential breaches of Articles 12, 14, 16 and 20 of the Digital Services Act.

 
 
 
On 16 September 2026, WHAT TO FIX filed a complaint with the Netherlands Authority for Consumers and Markets (ACM) under the Digital Services Act (DSA), alleging that Meta has failed to diligently enforce its monetization rules and to provide effective ways to escalate potentially illegal monetization.
The complaint calls on ACM to investigate Meta for potential breaches of the following DSA provisions:
  • Article 14 - Terms and Conditions
  • Article 16 - Notice-and-Action Mechanisms
  • Article 20 - Internal Complaint-Handling System
  • Article 12 - Points of Contact for Recipients of the Service
 
Insofar as the concerns may reflect systemic weaknesses, the complaint also calls on Digital Services Coordinators to refer the matter to the European Commission for further investigation, in accordance with Article 65(2) of the DSA.
 
Read the complaint →
 

The basis for the complaint

 
The complaint draws on WHAT TO FIX’s thirteen-month effort to alert Meta to 11 Facebook pages apparently affiliated with EU-sanctioned actors that displayed signs of access to monetization products, in possible violation of EU sanctions law.
Despite repeated notifications and substantiated notices submitted through Meta’s DSA-mandated escalation mechanisms, 4 of the reported pages continued to show signs of monetization access as of 20 July 2026.
The complaint points to weaknesses in Meta’s monetization enforcement systems and handling of user reports and escalations. Such weaknesses are especially concerning given the scale of Meta’s creator monetization programs: Facebook disclosed paying creators $3 billion in 2025, with the number of benefiting accounts growing 17-fold over the past 3 years.
WHAT TO FIX is concerned that Meta may be facilitating payments worth billions while lacking reliable systems to enforce its monetization rules and process user reports of potentially illegal monetization.
 

Article 14: Inconsistent enforcement of Meta’s monetization terms

 
The complaint alleges that Meta lacks reliable systems for detecting violations and enforcing its monetization terms and policies in a diligent, objective and proportionate manner, including when explicitly notified of suspected violations.
WHAT TO FIX argues that Meta had access to the necessary internal and public-facing data to establish, with a high degree of confidence, that its monetization products were being accessed by Facebook pages with the potential to directly or indirectly benefit EU-sanctioned actors, creating a credible risk of violation EU sanctions law.
WHAT TO FIX also argues that when alerted to the pages, Meta did not appear to consistently acknowledge, investigate or act on the notices, including when these were duly substantiated with references to the specific law, as well as evidence of ongoing monetization access.
WHAT TO FIX’s complaint documents examples of:
  • pages facing no apparent consequences in the months following WHAT TO FIX’s notices;
  • pages facing apparent restrictions only to regain access a few weeks later;
  • pages facing apparent restrictions from some monetization products but not others;
  • pages facing apparent restrictions, while other pages, believe to share some admins, retained access.
 
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Article 16: No suitable pathway to escalate illegal monetization concerns

 
The complaint alleges that Meta’s notice-and-action mechanisms do not enable the adequate processing of user reports of potentially illegal monetization.
WHAT TO FIX used Meta’s notice-and-action mechanisms to submit notices regarding four of the reported accounts. In each case, WHAT TO FIX clearly identified the legal provisions it suspected to have been violated, the precise electronic location of the Facebook pages, and, in all but one case, provided evidence of ongoing access to monetization products. None of the four notices received a notification of decision.
WHAT TO FIX argues that Meta’s Legal Removal Request forms do not comply with DSA requirements for accessibility, timely, diligent, non-arbitrary and objective handling, and notification of decisions.
WHAT TO FIX’s complaint documents how:
  • Meta’s notice-and-action mechanisms were inaccessible to WHAT TO FIX team members seeking access from outside the EU;
  • one of WHAT TO FIX’s notices received no follow-up beyond an automated confirmation of receipt;
  • a separate notice received an immediate automated message indicating that the reported issue might not be supported by the legal removal request channel;
  • Meta’s requests for information came via disconnected email threads without case references, making them difficult to match to specific notices;
  • Meta’s responses appeared templated and failed to address any of the questions WHAT TO FIX raised, including requests for a direct legal-compliance point-of-contact;
  • Meta did not provide WHAT TO FIX with any notification of decision, even as WHAT TO FIX documented changes indicating likely enforcement actions on 22 July 2026.
 
Review the evidence →
 

Article 20: No effective means to challenge Meta’s decisions concerning suspected monetization violations

 
The complaint alleges that Meta’s internal complaint-handling system does not provide adequate means of challenging Meta’s decisions regarding suspected monetization violations.
WHAT TO FIX used Meta’s standard in-product reporting system to report four of the Facebook pages it suspected to violate Meta’s monetization terms. Meta notified WHAT TO FIX that it had reviewed the pages against its Facebook Community Standards and found them not to be violating.
As the recipient of decisions from Meta, WHAT TO FIX sought to use the DSA-mandated internal complaint-handling system to challenge Meta’s decisions.
WHAT TO FIX argues that Meta’s internal complaint-handling system did not provide effective redress.
WHAT TO FIX’s complaint documents how:
  • Meta’s button to request a second review was defective, making the system not user-friendly.
  • Meta’s internal complaint-handling system offered no pathway to specify the nature of the complaint or to offer substantiating information.
  • Meta’s option to complain about the reporting process did not give rise to any meaningful follow-up or remedy.
 
Review the evidence →
 

Article 12: No effective point-of-contact for escalating monetization-related legal and compliance concerns

 
The complaint alleges that Meta’s publicly disclosed points-of-contact do not offer an effective means of raising legal compliance concerns involving content monetization.
WHAT TO FIX tried to identify an electronic point-of-contact to raise its monetization compliance concerns including through Meta’s help center, AI Support Assistant, and direct emailing with the company.
WHAT TO FIX argues that none of the provided electronic points-of-contact were suitable for reports of potentially illegal monetization.
WHAT TO FIX’s complaint documents how:
  • Meta either redirected WHAT TO FIX to its standard, and unsuitable, electronic reporting forms; or
  • Meta did not respond to WHAT TO FIX’s inquiries.
 
When prompted, Meta’s AI Support Assistant appeared to confirm that “Article 12 of the Digital Services Act (DSA) is implemented through Meta’s established electronic communication channels, including the in-product reporting tools and the Legal removal request forms” and that there are “no separate public email addresses for this function”.
Review the evidence →
 

WHAT TO FIX: Our recommendations

 
Taken together, Meta’s inconsistent monetization enforcement, unsuitable notice-and-action mechanisms, inadequate internal complaint-handling system, and lack of effective point-of-contact for monetization-related compliance concerns suggest that Meta may lack reliable systems to enforce its monetization rules and to process reports of potentially illegal monetization.
Through this complaint, WHAT TO FIX calls on regulators to investigate and ensure compliance with relevant DSA provisions, with a particular focus on:
point Monetization terms that clearly identify monetization policies, procedures, measures and tools as well as internal complaint routes;
point Reliable enforcement systems that support diligent, objective and proportionate application of monetization rules;
pointAdequate escalation mechanisms that allow users to effectively notify the company to potentially violating and illegal monetization.
WHAT TO FIX also calls on Digital Services Coordinators to refer the matter to the European Commission to examine whether the shortcomings identified may indicate wider failures in Meta’s systemic-risk assessment, mitigation and transparency obligations. This request follows indications that Meta failed to adequately disclose monetization-related risks and mitigation measures in its 2025 risk assessment report.
 
When platforms facilitate payments worth billions, monetization cannot be a regulatory blind spot.
The DSA provides the tools to ensure clear, predictable monetization rules; diligent enforcement; effective reporting and redress mechanisms; and meaningful transparency and oversight. Regulators must ensure its comprehensive enforcement.
 
Read the complaint →