WHAT TO FIX Submission To The First Annual Report On Systemic Risks

 
 
notion image
 
↓ DOWNLOAD
 
 

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

3 April 2025
 
As the EU Digital Services Act (DSA) continues to take shape, we at WHAT TO FIX are pleased to have the opportunity to contribute to its continued development and enforcement.
We’re excited to share our submission to the European Board for Digital Services’ request for input, designed to inform its first annual report on systemic risks and recommended mitigation measures.
If you’ve been following our work on monetization and social media, you’ll already know that we see platform monetization services as a puzzlingly overlooked factor contributing to systemic risks across the EU and globally.
With social media platforms rapidly expanding the scope and scale of their monetization services, we believe that monetization systems must urgently be subjected to regulatory oversight.
This submission provided us with a unique opportunity to lay out our case, and connect the dots on how monetization systems relate to the DSA and its approach to risk management.

TLDR - Monetization Systems are a core Characteristic of Social Media Platforms Which Must Be Addressed As A Risk Factor Under The DSA

 
The submission is a short read, which we would encourage you to read in full, but here are the main takeaways:
  • Social media monetization services are critical to media viability and the creator economy — but they can also fuel harmful financial incentives and the harmful allocation or withholding of financial resources.
  • Decisions over who is eligible for payment, and what actors and content get financially rewarded — much like decisions over what content is or is not allowed to be shown on a platform, or amplified via recommender systems and paid advertising — can shape the content that gets created, amplified, and consumed, with the potential to impact systemic risks. If anything, monetization decisions can have even more far-reaching consequences, as they revolve around the allocation of funding, rather than content.
  • Transparency around platforms’ approach to monetization is limited, preventing researchers from being able to independently assess the adequacy of platforms’ monetization systems, including program designs, terms and conditions, monetization policies and their respective enforcement.
  • The DSA risk management approach offers a critical mechanism to bring much needed transparency and oversight to the monetization systems of Very Large Online Platforms’ (VLOPs) - along with a framework for assessing risks associated with the design, functioning and use of monetization services, and for developing effective mitigation measures.
  • As an immediate step towards mitigating the risks stemming from their monetization systems, we recommend that VLOPs drastically expand transparency around their monetization systems and commit to a principled approach to monetization governance.
 
At WHAT TO FIX, we’ll continue to unpack what is known — and unknown — about platforms’ approach to monetization.
We are also supporting the development of Monetization Principles, informed through multi-stakeholder consultations.
Get in touch if you want to discuss further and keep an eye on our #AdRevenueSharing project for more.
 
 
Featured