DSA-Compliant Internal complaint-handling systems
Résumé
This contribution examines the implementation of internal complaint-handling systems by online platforms under Article 20 of the Digital Services Act (DSA). Noting a lack of transparency and direct response from major digital actors regarding their internal practices, the study proposes a conceptual framework to structure this second level of content moderation. The analysis advocates for a differentiated approach between first-level and second-level moderation. While a more summary or automated examination might be acceptable for the initial review of large volumes of content, the internal appeal process must provide a more robust, diligent, and specialized assessment . Five key recommendations are developed: increasing the time dedicated to second-level examinations, ensuring moderator specialization in specific legal fields and local cultural contexts, facilitating a contradictory process based on the statement of reasons, providing human-verified and comprehensive reasoning for decisions, and establishing an obligatory feedback loop. Finally, the study emphasizes that second-level decisions should serve as a structural tool to identify recurring errors, allowing for the continuous improvement of human teams and the retraining of automated moderation algorithms. This realistic approach acknowledges that while moderators are not judges, the internal complaint-handling system must guarantee a superior level of quality and reliability to ensure the effectiveness of the regulation .
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