Euroconsumers' Input to the European Commission's Draft Guidelines on the Trusted Flagger Mechanism under Article 22 DSA

In its input to the European Commission’s draft Guidelines on the trusted flagger mechanism under Article 22 of the Digital Services Act, Euroconsumers calls for a broader, more diverse trusted flagger ecosystem with stronger participation of consumer organisations. Through complaint handling, market monitoring, testing and direct support to scam victims, consumer organisations have unique expertise in identifying illegal content such as online scams, fraudulent practices and unsafe products. Euroconsumers asks the Commission to explicitly recognise this expertise, clarify that independence should be assessed on an organisation’s ability to act impartially rather than on cooperation with platforms as such, keep the application process proportionate and streamlined, recognise AI-assisted detection tools, and strengthen procedural safeguards before trusted flagger status is revoked.

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