WHAT TO FIX’s Submission to the European Board on Digital Services’ Annual Report on Systemic Risks
Published: April 3, 2025
In November 2024, Very Large Online Platforms and Search Engines (VLOP/SEs) submitted their first round of systemic risk assessment, mitigation and audit reports, in compliance with Articles 34, 35 and 37 of the Digital Services Act (DSA).
The European Board for Digital Services (EBDS) is responsible for undertaking an annual review of prominent systemic risks in cooperation with the European Commission (Art. 35). In preparation for this report, the board solicited public inputs.
At WHAT TO FIX, we’re deeply concerned by the unregulated expansion or social media monetization services - and their impact across systemic risks.
Our submission to the European Commission and EBDS made three important contributions:
Establish the current absence of reference to the design, use and functioning of monetization services in existing reports. Provide an overview of how monetization services impact on systemic risks, as defined under Art. 34.1 of the DSA. Outline why monetization systems are influencing factors which should be proactively assessed alongside other platforms characteristics, as identified under Art. 34.2 of the DSA.As social platforms continue to rapidly expand their monetization services, we call for the impact of these services on systemic risks to be assessed and for platforms’ monetization terms, policies, and their enforcement to be subject to regulatory oversight.
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