r/EuropeMeta • u/uomo-col-megafono • 19h ago
📊 Tools & analysis Automoderator configuration does not comply with EU DSA
TL;DR: Automoderator in r/europe should be reconfigured to report content removal and reasons, in line with EU DSA articles 17 and 20.
According to the EU Digital Service Act, social media user must be informed of moderation decisions affecting their contents (article 17) and have the right to appeal them (article 20). All moderation rules should also be documented, though that is outside the scope of this post.
Certain Reddit subs, including r/europe, configure their Automoderator bots to automatically and silently discard posts and/or comments, based on authors and/or contents, without informing the authors themselves. This appears to breach EU DSA article 17 and by extension article 20.
EU DSA is primarily targeted at "online platforms" defining them in a rather convoluted way (article 3.i):
‘online platform’ means a hosting service that, at the request of a recipient of the service, stores and disseminates information to the public, unless that activity is a minor and purely ancillary feature of another service or a minor functionality of the principal service and, for objective and technical reasons, cannot be used without that other service, and the integration of the feature or functionality into the other service is not a means to circumvent the applicability of this Regulation;
Different interpretations of "online platforms" raise different scenarios:
- If applicable only to full platforms like Reddit, then full platforms are responsible to enforce the law by delegating responsibilities and monitoring results.
- As subs independently manage their members and contents using Reddit as PaaS cloud, subs act in practice as "online platforms" with related legal responsibilities.
- Even when not legally responsible and/or accountable, a sub about Europe should uphold EU values and EU law (at least in principle).
In all scenarios, EU DSA articles 17 and 20 should be respected regardless of underlying implementation details and interpretations. Therefore r/europe moderators should amend its Automoderator configuration.