Let's Obtain Transparency
Our report — DSA: Europe’s Injustice System — is out. Now it’s time to use it to achieve transparency and accountability.
Our investigation into the Digital Services Act’s implementation in Romania shows how a mechanism promoted as a transparency tool can instead be hijacked to serve power — whether it be the executive branch or other interests.
Although we managed to break a few stories during this research, many questions remain unanswered.
Transparency is the missing piece at virtually every level. Without it, secrecy, conflicts of interest, partisan bias, and overreach thrive.
That’s why we have sent a request for feedback and once again extended a hand to all the participants, hoping to receive the answers and commitments that the situation demands.
The letter:
Dear Participant to Romania’s content moderation architecture,
I hope this message finds you well. I’m reaching out to inform you that the first version of our investigative report on the implementation of the Digital Services Act (DSA) has been released (v1.0.1).
You can view the full report here: https://francezul.substack.com/p/dsa-europes-injustice-system.
In our assessment, we applied several key criteria to each participant in the DSA’s moderation architecture. Specifically, we focused on:
Secrecy: How transparent your funding and moderation activities are.
Unaccountability: Your responsiveness to inquiries and willingness to address issues.
Role Accumulation: The number of overlapping roles you hold.
Dependence: The degree of your financial independence from power structures.
Partisanship: Whether your stance is non-partisan or leans toward particular political interests.
Power: The influence you have in shaping the information landscape.
We would appreciate your feedback on these ratings and any steps you might consider to improve in these areas. As a general recommendation (not necessarily applicable to your organization), participants in the DSA moderation architecture could enhance their rating by:
reducing the number of accumulated roles to improve perceived impartiality;
disclosing full information about financing sources and avoiding links to executive powers or vested financial interests;
engaging more in grassroots activities that foster genuine citizen participation and accountability.
Your feedback is invaluable, and we hope this dialogue will contribute to a more transparent and accountable implementation of the DSA.
Through this process, we aim to obtain the missing answers and build an even more accurate picture of the DSA implementation in Romania.
We also expect to consolidate our analytical framework so that it can, eventually, be replicated in other countries facing similar mechanisms and challenges. The stakes are clear: to create a consolidated system to analyze DSA misuse and help enforce citizens’ rights across the EU.
The complacency of the DSA participants with Romania’s current “hybrid regime” is a cautionary tale for all similar actors across Europe: are they enforcers of a narrative, or do they support a system that will uphold justice for citizens, defending their right to share information, to know when they are censored, why, by whom, and to be able to appeal such decisions and even obtain redress.
The Tool We’re Building
For this purpose, we’re developing a web application to document, visualize, and update national DSA situations.
The tool will offer a multi-layered view of each country’s situation: a high-level dashboard, detailed actor profiles, a live censorship tracker, and a collection of primary sources. The following screenshots from our staging environment (a pre-production version) illustrate how this will look for Romania, based on the data from our report:
Country Dashboard
An overview of the national situation. Each dot in the graph represents a DSA moderation actor. The closer to the red area, the worse the rating; the closer to the green, the better the rating: indicating actors that ensure transparency, engage with journalists, remain independent from power, and focus on a single purpose.
DSA Actors View
A detailed look at participants, with filters by role (Trusted Flagger, Fact-Checker, Rapid Response System participant, etc.), leading to detailed profiles for each organization.
A Censorship Cases Database
A searchable repository that, in time, could be crowdsourced. It will help connect specific cases both to out-of-court settlement bodies and, where possible, to the DSA statement database. For the moment, we'll use it to track the abusive censorship instances we have documented and update their status.
Feedback much appreciated!
It’s a work in progress, and we plan to release the first version soon.
We welcome your comments and feedback.
 | A guest post by
|