WHAT TO FIX’s Submission to the European Board on Digital Services’ First Annual Report On Systemic Risks

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 input.

Our submission to the European Commission and EBDS made three important contributions:

Mark the absence of reference to the design, use and functioning of monetization services in the VLOPs’ first round of reports.

Provide an overview of 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 believe that platforms must be required to assess and disclose the impact of these services on systemic risks and to adjust their monetization terms, policies, and enforcement to ensure adequate mitigation of these risks.