Arcom’s contribution to the European Commission’s public consultation on the guidelines on trusted flaggers

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Arcom welcomes the fact that the European Commission is putting its draft guidelines on trusted flaggers out for public consultation, thereby offering all stakeholders the opportunity to contribute to their development on the basis of their operational experience.

The trusted flaggers mechanism, established by Article 22 of the Digital Services Regulation (hereinafter ‘DSR’ or ‘DSA’), is a key pillar of the scheme for moderating unlawful online content. Trusted flaggers are organisations recognised for their expertise in detecting, identifying and reporting unlawful content within one or more specific areas of expertise. As such, their reports are given priority treatment by online platform providers, who take a decision on them as soon as possible.

This draft rightly emphasises that their work is not limited to content moderation: it also helps to document the development of trends in the diffusion of unlawful content online and to detect any systemic shortcomings in the moderation processes of very large online platforms and very large search engines (hereinafter ‘TGPL/TGMR’), thereby playing a vital role in protecting internet users.

Arcom is particularly involved in this scheme in its capacity as the Digital Services Coordinator (hereinafter ‘CSN’) for France. It is responsible for assessing applications, ensuring that applicant entities meet each of the criteria set out in the Regulation, and for granting the status of trusted flaggers.

Arcom maintains regular contact with the trusted flaggers to whom it has granted this status. The eight trusted flaggers appointed in 2024 and 2025 published their annual reports in the first half of 2026, detailing the activities carried out under Article 22 of the RSN. In addition to the information made available to the public and required by Article 22(3), Arcom was also able to gather, throughout the past year, feedback and operational notices from the whistleblowers. These exchanges have enabled Arcom to enhance its contribution with a view to improving the effectiveness of the mechanism’s implementation.

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Arcom’s response to the Commission’s public consultation on its guidelines on trusted flaggers

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