'Your report is important to us': unnecessary barriers to submit content reports

This analysis, building on a HateAid report, examines how large online platforms implement their Digital Services Act obligations under Articles 16, 20 and 21 to provide user-friendly mechanisms for reporting illegal content. The authors tested reporting flows directly and cross-referenced findings with the European Commission's preliminary assessments of platform compliance.

The central finding is that several platforms design reporting processes that discourage users from flagging illegal content specifically, steering them instead toward simpler terms-of-service violation reports that carry lighter obligations for the platform. On Meta's services, reporting illegal content was found to require roughly 15 clicks compared to about 5 for a standard community-guidelines complaint, alongside added friction such as character limits and duplicated information requests; similar patterns were identified on YouTube and TikTok. The Commission's own preliminary findings reportedly flagged unnecessary steps in Meta's mechanisms.

The piece concludes that this "sludge" design appears deliberate, since platforms face fewer downstream obligations when content is reported as a policy violation rather than as illegal, and calls on the Commission to enforce Article 16 more robustly as a cross-cutting priority rather than a category-specific one.