Challenges of Trusted Flagger accreditation and platform relationships

Determine the specific challenges faced by organizations and individuals seeking accreditation as Trusted Flaggers under Article 22 of the EU Digital Services Act, and characterize how accreditation influences and structures their relationships with regulated online platforms in the course of reporting illegal content.

Background

The Digital Services Act (DSA) formalizes a new role for entities designated as Trusted Flaggers (TFs), accredited by national Digital Services Coordinators to prioritize notices of illegal content. Because the TF designation is recent and procedurally demanding, the practical hurdles to becoming accredited and the subsequent dynamics of engagement with platforms are not yet well documented.

Clarifying these challenges and relationship dynamics is essential for evaluating whether Article 22 achieves its aims, and for identifying where support, standardization, or guidance may be required to make TF participation effective and sustainable.

References

It remains unclear what the challenges are for organizations and individuals that pursue TF accreditation, and how their relationships with regulated platforms develop.

— "There is literally zero funding": Understanding the Emerging Role of Trusted Flaggers under the EU Digital Services Act  (2603.29874 - Sekwenz et al., 31 Mar 2026) in Introduction