Trusted, but Treated Like Anyone?

Summary

In February 2026, the first Trusted Flagger reports under Art. 22 DSA were published. They show how individual platforms interact with individual organisations, but they say little about how consistently Very Large Online Platforms (VLOPs) handle notices of illegal content in practice.

As part of a cross-national experiment with ten other European civil society organisations, ÖIAT spent two months reporting illegal content on X, YouTube, Facebook and TikTok as a designated Trusted Flagger. We focused on German-language content that violates Austrian law: Holocaust denial, National Socialist re-engagement (Verbotsgesetz 1947), prohibited Nazi symbols (Abzeichengesetz 1960) and incitement to hatred (§ 283 StGB). In total, we submitted 89 reports.

Platforms acted on 85 % of them, which is well above the roughly 50 % removal rate we usually observe. But the way platforms acted raises questions. Facebook and TikTok frequently justified their decisions with their own community guidelines rather than the national law cited in our reports. Content that did not breach those guidelines was often only geoblocked in Austria rather than removed. And each platform runs a different reporting process, which makes systematic reporting by Trusted Flaggers unnecessarily difficult.

Key Findings

• Platforms tool action on 85 % of our 89 reports, with removal rates ranging from 92 % to 36 % on YouTube.
• Roughly one in four reported items was only geoblocked in Austria, leaving it accessible from other countries (e.g. Germany).
• Facebook and TikTok repeatedly referred to their community guidelines instead of the national law cited, suggesting Trusted Flagger notices go through the same guideline check as ordinary user reports.
• Content violating community guidelines tended to be removed globally, while content “only” illegal under Austrian law tended to be geoblocked.
• Reporting processes differ fundamentally between platforms: TikTok offers no external form or email notifications and YouTube offers no Trusted Flagger route for comments.
• Offenders increasingly use AI-generated images and hidden symbols to share Nazi salutes and swastikas, and much illegal content on TikTok disappears within days, before it can be documented.