VSE Response to the European Commission’s Draft Guidelines on Trusted Flaggers under the Digital Services Act
VSE Calls for a Stronger Role for Victim Support Organisations under the Digital Services Act
Victim Support Europe (VSE) has submitted its response to the European Commission’s draft Guidelines on Trusted Flaggers under the Digital Services Act (DSA), calling for the formal recognition of victim support organisations as key actors in identifying and addressing illegal online content.
Drawing on their direct work with victims of cybercrime, online abuse, fraud, hate speech, child sexual abuse material, and technology-facilitated violence, victim support organisations bring unique expertise that goes beyond content moderation. Their frontline experience allows them to identify emerging risks, understand patterns of victimisation, support reporting, and contribute to the prevention of further harm.
In its submission, VSE emphasises that the Trusted Flagger mechanism should not be viewed solely as a technical content moderation tool, but also as an instrument for protecting fundamental rights, reducing victimisation, and creating safer digital environments. VSE calls for stronger cooperation between platforms, Digital Services Coordinators, law enforcement, victim support services and other relevant stakeholders, as well as secure reporting channels that prioritise victims’ safety and wellbeing.
The submission also highlights the importance of involving victims themselves in the design of online safety responses. Through appropriate safeguards, training and support, victims of online crime can contribute valuable insights into harmful content, emerging risks and effective prevention measures. VSE proposes exploring victim-led Trusted Flagger initiatives supported by dedicated victim care mechanisms to ensure participation remains voluntary, trauma-informed and safe.
VSE’s recommendations aim to ensure that implementation of the Digital Services Act is fully aligned with victims’ rights, helping to create a digital ecosystem that is safer, more responsive to victims’ needs, and better equipped to prevent future harm.
