The European Commission is driving forward the implementation of the Trusted Flagger mechanism enshrined in the Digital Services Act (DSA). Comprehensive guidelines on the recognition procedure, as well as on notices and reports from Trusted Flaggers and the related measures taken by platform providers, are intended to support the practical implementation of the relevant DSA requirements.
In a position paper published on 7 July 2026, eco – Association of the Internet Industry generally welcomes the draft guidelines, but calls for targeted improvements.
The aim is legally certain, harmonised and practical implementation of the Digital Services Act (DSA), strengthening proven reporting structures while avoiding unnecessary hurdles. In its position paper, the Internet industry association contributes the experience of its member companies and of the eco Complaints Office, which has been receiving, assessing and forwarding reports of unlawful online content to hosting providers and online platforms for 30 years.
“The European Commission’s guidelines are an important step towards harmonised implementation of the Trusted Flagger mechanism in Europe. The actors involved, namely the national DSCs responsible for supervision, Trusted Flaggers and Trusted Flagger candidates, as well as providers of online platforms, need clarity with regard to authorisation requirements and options in the case of significant incorrect reports, as well as on prioritisation rules and reporting. We see an area of tension between the wishes of recognised Trusted Flaggers and the capabilities of platforms. The guidelines need to find a balanced path here. It is also crucial that the practical design remains open to the expertise of proven reporting bodies and established cooperation arrangements.
Only in this way can the system unfold its full potential in the fight against illegal content,” says Alexandra Koch-Skiba, Head of the eco Complaints Office.
In its position paper, eco calls in particular for:
- the criteria for independence and accuracy to be aligned more closely with objective decision-making processes
- application procedures for Trusted Flaggers to be made more transparent and predictable
- additional requirements for platform operators that go beyond the DSA to be avoided
- practical procedures to be created to preserve the integrity of Trusted Flagger status
From eco’s perspective, it is crucial that the guidelines clarify the legal framework of the DSA without introducing new obligations that are not provided for in the law itself. At the same time, they should offer sufficient flexibility so that proven voluntary cooperation between platforms and trusted reporting bodies can continue in future.
Trusted Flaggers have particular expertise in identifying and reporting illegal content. The DSA therefore provides that, for appropriately recognised organisations, online platforms must process notices of illegal content as a priority (“Fast Lane”). Priority processing means that platform providers carry out a prioritised review of the reported content.
If the platform provider shares the Trusted Flagger’s legal assessment, the content complained about is then removed.
