This post was co-authored by Sheila B. Lalwani, a doctorate student and recent COMPASS Fellow hosted by EFF.

Age verification proposals are often presented as a simple tradeoff: sacrifice a little privacy to better safeguard children online. But that framing overlooks a more fundamental question. What happens to people who cannot verify their age at all? This is particularly a problem when users are required to prove their age with identity documents.

Age-related restrictions are developing quickly around the world. While they differ radically across jurisdictions, in the past year, we’ve witnessed a sharp uptick toward mandatory age assurance for social media access but also for other high-risk digital services.

For example:

• In late 2025, Australia became the first country to implement a minimum age requirement for prohibiting children under age 16 from creating or holding social media accounts. 
• India passed the Digital Personal Data Protection (DPDP) Act that includes mandatory verifiable parental consent and has undertaken ongoing discussions for social media restriction.
• The United Kingdom passed the Online Safety Act requiring age verification across a swath of services hosting content considered harmful to users under 18. More than half the states across the U.S. have enacted age verification laws. 
• An EU Commission’s expert report recommends a ban on social media access for users under 13. It also recommends mandatory age verification for platforms to ensure that users are ‘age appropriate.’ 

The Access Problem 

Age verification laws that are predicated on the necessity of users possessing a current passport, driver’s license, credit card, or similar documents proving their identity exclude critical sections of populations.  And this problem is global in nature: Millions of people lack government-issued identification or encounter regular challenges to obtaining or updating it. 

Roughly 15 million adult U.S. citizens lack a driver’s license, and a further 2.6 million lack any government photo ID; leaving large groups blocked from online content or services. The UK has a similar predicament: proof-of-age checks are often reliant on passports, driver’s licenses, or other recognized alternatives, which can pose unique challenges to people without these documents.

Much of the advocacy around age verification discusses the privacy harms of age verification. Yet these measures also threaten something more fundamental: equal access to information and the ability to exercise the right to freedom of expression. 

Unfortunately, age verification systems foster unequal access to information and provide an asymmetric solution to find essential information, build community, and weigh in on public discourse. As governments and companies increasingly require users to prove their age before accessing online services, these individuals risk being excluded from large parts of the internet altogether. 

Effects on Global Majority Countries 

Age verification laws reshape who can speak, who can access information, and who gets excluded from the digital public sphere. In other words, age verification is not a neutral safety measure: it presents a structural barrier to disproportionately exclude certain groups—particularly those in the global majority—and alters the architecture of global online expression. Some of these groups are already marginalized offline, and age verification extends that exclusion into digital spaces.

For instance, 850 million people globally do not have ID. Most of these individuals exist in primarily low and middle income countries in Sub-Saharan Africa and South Asia. The World Bank points out that many are members of marginalized groups and more than half of those lacking access to identity documentation also have children whose births have not been registered. Women are particularly vulnerable and are 8% less likely than men to have an ID. Other vulnerable groups, such as adults in low income countries, are less likely to have an ID when they fall below 25 years, as are those with a primary school education or less or those in rural areas. 

A policy paper from EDRi points out that age verification laws provide quick tech solutions but overlook longstanding structural challenges and undermine the universality of the internet. The analysis finds that age verification laws have serious human rights implications and ironically harm the very individuals they deem to protect. Moreover, these laws depend on the collection of harmful mass data that human rights organizations, including EFF, is fighting against—and has for decades. 

For example:

• In Morocco, a push to restrict children’s access would ban under-13s from creating accounts on gaming platforms. This could potentially create challenges for those with IDs that have incomplete information concerning the year of birth. In addition, this push would also impact those who attempt to leave Morocco.
• In Egypt, the lack of ID cards has created challenges for minority groups such as the Baha’i.
• Stateless individuals would also struggle under age verification laws. The Rohingya, the world’s largest population of stateless people, often lack IDs. 
• Kuwait’s Bidoon population also lacks proper identification materials. According to Amnesty International, this leads many to rely on standard civil identity cards, which can be restrictive.  
• Nigeria launched a national program to provide ID cards to its population in 2007. Since then, 64.4 million have registered, but that represents just over 30% of the national population.
• The Kafala system, a practice in several countries across the Middle East, also introduces challenges for age verification laws. Under this legal framework, migrant workers’ legal residency and employment status are bound to a specific employer. This potentially leaves stateless persons or migrant workers vulnerable to forced labor and restricted movements. 

No ID, No Access

Age verification laws are less about confirming the age of a user and more about creating barriers to online participation that many people cannot reliably scale. The net result is reduced access, more data collection, and an increased chance of unequal or mistaken exclusion from accessing information online. 

Nobody doubts the importance of protecting children online. While proponents assert that age verification laws protect minors from harmful material, online harassment, and digital addiction, these laws are not the solution. They subvert fundamental freedom of expression rights and pose significant privacy risks.  

EFF has long warned against age-gating the internet. Age verification technology itself is often inaccurate and privacy-invasive, and as more countries considering implementing ID-based checks, the risks move beyond censorship and surveillance toward excluding some people entirely. That’s why we’re working with groups in the U.S. and around the world to push back against these laws, and why we hope you join our effort.

For more information on how to fight back against dangerous age verification laws, visit our resource hub at eff.org/age

The term “digital sovereignty” has become ubiquitous. European officials invoke it in debates about cloud infrastructure, AI, semiconductors, and platform regulation. Governments throughout the global majority use it to argue for greater control over data and communications infrastructure and boost their economies. Companies market “sovereign cloud” products designed to reassure their customers that their information stays under local jurisdiction. But digital sovereignty could be something more: an opportunity for users around the world to build more resilient, open  systems and the skills and infrastructure to maintain them.

There is no singular definition of digital sovereignty, nor is there a single coherent position in the digital rights space. Despite its growing popularity, the term remains frustratingly vague. Policymakers, regulators, civil society groups, and others can mean very different things when they use the term. But to start simply with a broad definition, we can say that it means having the capacity to control one’s digital destiny—though the implications of that will obviously differ considerably whether you’re talking about an individual or a country.

We can start by developing  a shared understanding of what digital sovereignty actually means. We’ve also included a glossary of terms at the bottom of this post. 

In Europe and other places where digital sovereignty has become a topic of policy, discussions focus on reducing dependency: on foreign (and particularly American) cloud infrastructure, chips, platforms, and at times, foreign political priorities. The concern is both economic and geopolitical. If essential infrastructure is controlled by companies elsewhere—and thus subject to the laws of another jurisdiction—then what control does a country actually have over its own digital future?

In global majority countries in particular, wars, sanctions, and the growing fragmentation of the internet have demonstrated for many that the physical infrastructure that underlies digital life is neither neutral nor invulnerable. 

Amidst this increasing geopolitical instability governments and civil society should consider whether digital sovereignty can help shore up that infrastructure. 

What are we talking about when we talk about digital sovereignty? 

A recent Franco-German joint paper on digital sovereignty defines it as the “capability and capacity to develop, provide, use, adapt and control digital technologies including hardware in an independent, self-determined and secure manner” and puts forward a framework to operationalize Europe’s capacity to act in the digital domain. 

Some governments, such as Germany’s, have started to put funding behind sovereignty efforts through initiatives like the Sovereign Tech Agency, which “invest[s] globally in the open software components that underpin Germany's and Europe's competitiveness and ability to innovate.” 

Positions on digital sovereignty among EFF’s allies across Europe vary. Open Rights Group have defined digital sovereignty as “the ability of a country to have control over its digital infrastructure, data, and technology” and states it to be “critical for the UK’s economic and national security.” 

Similarly, the European Partnership for Democracy has expressed concern that “a few Big Tech corporations decide our collective destiny,” and argue that the EU should explore “alternative ownership models for tech companies and clearly [define] their purpose and mission.” And our friends at EDRi (of which EFF is a member) have stated clearly that “Europe’s digital sovereignty starts with open source.” Some initiatives, such as DI.DAY, consider digital sovereignty an opportunity to free users from Big Tech dependencies.

Elsewhere in the world, conversations about digital sovereignty often take a different shape. Indigenous discussions of the topic have been ongoing for more than a decade and focus on the inherent right of Native nations to govern their own digital ecosystems. In Southeast Asia, the desire for digital sovereignty has created growth in the sovereign cloud industry, but the conversation isn’t purely economic: Concerns about jurisdiction for where data is held are driving much of the conversation. 

In Latin America, digital public infrastructure is often a key aspect of debates. Across Africa, leaders speak of a desire to shift the continent from being consumers of technology to becoming architects of their own digital infrastructure and data ecosystems. And in the Middle East and North Africa, concerns about reliance on U.S. technology companies—which have engaged in conflict and disproportionate censorship (particularly of Palestinian voices) in the region—are often paramount.

Reem Almasri, a senior researcher based in Jordan, recently spoke to EFF about digital sovereignty, which she sees as “the ability of people and communities to choose, control, and use technology that serves their needs and values,” particularly in light of the role that U.S. companies have played in regional conflicts.

In a January article, Almasri pointed to growing concerns about granting greater sovereignty and influence to governments over citizens’ data, communications, and websites, writing: “This is particularly worrisome in countries that impose high levels of internet and media censorship and run unaccountable surveillance programs on their citizens’ data.”

Indeed, while pushing for greater sovereignty from Big Tech has benefits, there is an inherent risk that some states will pursue digital sovereignty as a means of cutting off or splintering access—as we’ve already seen in Iran, Russia, and elsewhere.

For that reason, it’s no surprise that some, such as Iranian professor Azadeh Akbari, believe that “the current wave pushing digital sovereignty as the key to ending dependency on American and Chinese technology is negligent of its Eurocentric bias.” 

What does EFF believe?

In a world where people have digital sovereignty, civil society should be able to communicate freely, privately, and anonymously if they wish. People should be able to easily understand where their data lives and who has access to it. That data should be easily portable between platforms and services.

At EFF, we view digital sovereignty not as a walled garden, but as an opportunity for resilience and development of industries and skills. We believe that governments can and should take a role in crafting digital sovereignty that centers the autonomy of users rather than just re-creating a state of digital dependency with a new set of companies. Governments should support and use free and open source tools and projects built using principles of interoperability and data portability. This support should include employing full-time developers, UX designers, and community managers. Government policy and legislation should grant users control of their own data and a clear understanding of who can lawfully access it. Digital sovereignty should foster users’ ability to choose how they use digital products and services, free from unfair lock-ins, coercive terms and manipulative defaults. It should also foster the broader public interest internet, the part of the web that provides public goods and useful services without requiring the scale or the business practices of the tech giants.

Encryption backdoors are fundamentally incompatible with a vision of data sovereignty that centers user control. Governments should support the development and normalization of reputable end-to-end encrypted communications as well as strong encryption for data at rest. This support should include employing cryptographers and contributing to strong, peer-reviewed encryption standards strengthened by data minimization as a fundamental design principle, as well as refraining from legislating mandates for “lawful access” or any other reason.  

As technologists, we don’t have to wait for governments to act in order to create the digital sovereignty we want. We get the internet that we build. We can contribute to open source, decentralized, and end-to-end encrypted projects. We can build standards that make interoperability and data portability a feature from the very beginning. We can resist the call of proprietary solutions, user lock-in, and encryption backdoors.

And finally, while digital sovereignty is often framed as a response to the dominance of Big Tech, that does not mean that there is no role for private companies to play. There is no point in replacing the influence of a few mostly US-based tech companies with a handful of giants based elsewhere. Companies can and should build platforms and services on top of open source, decentralized protocols and contribute to the ecosystem. Companies should also minimize processing a person’s data except as strictly necessary to provide them what they asked for, and only with opt-in consent that makes it clear to users what data they are gathering, where it is stored, and who has access to it. And companies should build their tools and platforms in a way that allows interoperability and that makes it easy for users to leave with their data. Some of these practices are already required by law in some jurisdictions, but companies don’t have to merely do the bare minimum the law demands: they should respect their users and support data sovereignty right now.

A glossary of terms

The following terms are useful for understanding this blog post as well as the broader conversation about Digital Sovereignty:

Intermediary liability: the legal responsibility of online service providers (ISPs, websites, social media platforms) for unlawful activities by their users, such as defamation, copyright infringement, or illegal hate speech.

The stack: a secure, open-source technology framework, often focusing on European alternatives, designed to break dependencies on (mostly) US-based technology providers. It comprises interoperable, vendor-neutral, and transparent digital infrastructures designed to regain control over data, infrastructure, and technology.

Digital sovereignty: the ability of people, as nations, organizations, and individuals, to control their own digital destiny by retaining authority over their own data, technology, and infrastructure.

Data sovereignty: the principle that digital information is subject to the laws and governance frameworks of the country or region where it is physically collected, stored, or processed. It dictates that data remains bound by the specific privacy protections and regulations of its originating jurisdiction, regardless of where the collecting organization is located.

Digital commons: a shared, online resource, such as knowledge, software, and data, that is collectively produced, governed, and maintained by a community, intended for public access. Examples include Wikipedia, open source operating systems such as Linux, and Creative Commons licensed content.

Data portability/interoperability: the ability to easily transfer personal data from one service provider to another, or to a personal system, in a structured, machine-readable format. It empowers users to move away from "walled gardens," reducing vendor lock-in and enhancing user autonomy.

Digital dependency: the opposite of digital sovereignty. The inability of people as nations, organizations, and individuals to control their own digital destiny through control over their own data, technology, and infrastructure. 

Decentralization: a shift away from relying on centralized, often US-based, corporate platforms toward a distributed, user-centric internet where individuals, communities, and nations maintain control over their data, digital identity, and infrastructure.

End-to-end encryption (e2ee): a secure communication process where only the sender and intended recipient can access, read, or decrypt messages or data.

Fairness (à la the Digital Fairness Act): the absence of deceptive, manipulative, or addictive design practices that distort consumer choice and exploit vulnerabilities. 

User sovereignty: the concept that individuals possess absolute control over their personal data, digital identity, and online privacy, rejecting the centralization of power by large technology platforms. It emphasizes user consent, decentralization, and the ability to manage personal data using secure and independent tools.

Access to accurate information about reproductive and maternal health can be critical. But on Meta's platforms, simply talking about prescription medication, abortion care, or one's own medical experiences can be enough to trigger content removals and account restrictions.

That's why EFF recently submitted a public comment to the Meta Oversight Board in its consideration of a case involving an Instagram post about prescription drugs during pregnancy and childbirth. The case touches upon a topic we’ve been documenting for some time; last year we collected stories from individuals who had experienced censorship of reproductive health information on various platforms. Meta in particular stood out: Its moderation systems routinely fail to distinguish between prohibited drug transactions and legitimate discussion of medications, including educational information and people's firsthand experiences with healthcare.

Through our Stop Censoring Abortion project, EFF collected nearly 100 submissions from healthcare providers, clinics, educators, advocates, researchers, and others whose reproductive health content had been removed or suppressed by social media platforms. What we found was alarming: systemic over-enforcement, confusing policies, arbitrary takedowns, sudden account bans, de-ranking, and appeals that too often went nowhere.

Talking About Medication Isn't the Same as Selling It

In almost every case we reviewed, the censored posts and accounts did not actually violate the platforms' stated rules. Meta frequently cited its Restricted Goods and Services policy, which prohibits attempts to buy, sell, trade, donate, gift, or request pharmaceutical drugs. But the content EFF documented overwhelmingly consisted of factual or educational information—not attempts to sell or distribute drugs.

The consequences were significant. For example, the Miscarriage+Abortion Hotline had its Instagram account restricted and posts removed even though it was providing information about legally obtaining medication rather than offering pharmaceuticals for sale. Red River Women's Clinic and the RISE reproductive health research center at Emory University had accounts locked after posting about mifepristone.

Other users reported having their content quietly de-ranked or “shadowbanned,” limiting its reach without giving them meaningful notice or recourse. We believe educational content and people's experiences involving reproductive healthcare and medication should not be suppressed in this way.

And when Meta gets these decisions wrong, the appeals process too often fails to fix them. In several cases EFF documented, accounts were restored only after journalists drew attention to the problem or someone with a personal connection inside Meta intervened. A moderation system shouldn't require knowing the right person to get an erroneous decision reversed.

Meta Can—and Must—Do Better

Our submission calls on Meta to make five changes—the same five changes we asked for last year.

First, Meta should publish clear, understandable policies so users can know what content is permitted and what might result in removal, downranking, or account suspension. Second, those rules must be enforced consistently and fairly. Third, Meta must provide meaningful explanations for enforcement decisions, including what rule was violated and how users can appeal. Fourth, users need a functional appeals system that doesn't depend on insider access.

Finally, Meta should expand human review. Reproductive healthcare is precisely the sort of nuanced and context-dependent subject that automated moderation systems struggle to understand. As our research shows, automated systems can mistake education for drug sales, misinterpret terminology, overlook cultural and political context, and even classify legitimate advocacy as dangerous content. Human moderators should therefore play a greater role when automated systems flag sensitive healthcare information or political expression.

Meta has chosen to allow discussion of reproductive healthcare, including abortion, on its platforms. That commitment means little if its moderation systems nevertheless prevent people from accessing or sharing that information.

At a moment when reproductive rights are under attack around the world, the stakes are particularly high. Restricting access to essential healthcare information can have profound consequences, especially for people who already face barriers to reproductive care.

Users deserve a system in which rules aren't applied arbitrarily, appeals actually work, and vital health information isn't silenced because an automated system failed to understand its context. Meta can—and must—do better.

You can read our comment in full below.

EFF and ARTICLE 19 have submitted joint comments to the European Commission on draft guidelines for the Digital Services Act’s trusted flagger mechanism. Having long advocated for a DSA that protects freedom of expression while preserving intermediary liability protections and the prohibition on general monitoring, we welcome the Commission's effort to provide practical guidance on how the trusted flagger system should operate. 

The DSA’s trusted flagger system can help platforms identify illegal content more efficiently. But if implemented poorly, it could also encourage over-removal of lawful speech, weaken due process, and give government authorities disproportionate influence over online expression. 

We support the Commission's focus on good practices and illustrative examples, rather than legal interpretations that could inadvertently steer platforms toward particular enforcement outcomes—and argue that the guidelines should include stronger safeguards to protect freedom of expression, due process, and the impartiality of the trusted flagger system. 

We also support the Commission's clarification that the DSA itself does not define "illegal content"; that determination must come from applicable national or EU law. Trusted flaggers submit prioritized notice, but platforms remain responsible for determining whether content is actually illegal. Platforms must therefore conduct careful, informed assessments and should not assume that a trusted flagger notice necessarily warrants restricting content. 

Our submission highlights several areas where the guidelines could be strengthened: 

• Cross-border assessments require caution. Platforms should not rely on a trusted flagger notice to assess legality across Member States, where national legal frameworks may differ. 

• Systemic risks extend beyond content moderation. The DSA's systemic risk framework should not rely too heavily on individual moderation decisions, but should also consider broader platform design choices, including recommender systems. 

• Law enforcement authorities should generally not be granted trusted flagger status. They already have statutory powers under Article 9 of the DSA, and combining those powers with trusted flagger status creates a risk that platforms may treat trusted flagger notices as de facto removal orders, undermining due process and the rule of law. 

• Civil society organizations play an essential role. Civil society organizations help identify illegal content and report human rights abuses, but the guidelines should also recognize that these organizations may face retaliation for their work and should be protected from abusive campaigns that threaten their independence. 

• Trusted flaggers should complement—not replace—existing partnerships. The new mechanism should not sideline existing trusted partnership programs, including collaborations with civil society organizations that do not or cannot hold trusted flagger status, especially those outside of the EU with valuable regional expertise.  
  

Read the full submission here:

This post is part 2 in a series about automated content moderation. Read the first post here.

When whistleblower Frances Haugen leaked a set of documents from Meta in 2020, among the revelations was a jarring statistic: The company’s algorithms designed to detect terrorist content incorrectly deleted nonviolent Arabic-language content 77 percent of the time, while failing to detect hate speech under the company’s own policies in many instances. Meta’s own transparency report released later that year demonstrated similar findings. Five years later, researchers in the region report that overzealous moderation remains a problem, while paths to remedy have all but collapsed.

Where these systems are faltering in Arabic, they’re positively failing in less-resourced languages. As a 2025 report from the Center for Democracy and Technology found, labeled datasets in certain languages and dialects such as Maghrebi Arabic and Kiswahili contain inconsistencies, bias, and inaccuracies due to the limited hiring of annotators who actually speak the languages as well as shifts in the languages themselves. An investigation into ChatGPT’s outputs in several low-resource languages demonstrates the depth of problem.

But language disparities are just one of several concerns as automated moderation becomes more widespread. From the systemic suppression of content from Palestine to the repeated misclassification of LGBTQ+ content as adult or explicit material, these varied examples demonstrate the risks of overreliance on automated moderation—and the need for stronger safeguards.

Transparency, Cultural Competence, Appeals

As we discussed in Part 1 of this series, automated systems can process content at a scale that humans never could, potentially enabling better moderation at scale and alleviating the psychological load on ill-paid moderators whose jobs require them to view incredibly disturbing content. But automated systems also reproduce existing biases, struggle to understand context, and often make mistakes that disproportionately affect journalists, activists, artists, and other vulnerable and marginalized communities.

As Rachel Griffin wrote in 2023, “Perfectly accurate moderation is not only technically out of reach but intrinsically impossible.” Despite those intrinsic flaws, there is a great deal companies, policymakers, and civil society can do to help ensure that highly-automated systems operate in ways that respect human rights, minimize predictable harms, and provide meaningful accountability when they fail. If companies are going to continue relying on automation to moderate users’ speech—and there is little reason to believe they won’t—then accountability must evolve alongside these technologies.

That evolution can start with committing to the Santa Clara Principles 2.0. These principles, first outlined in 2020 and re-launched in 2021 after substantial international input, reflect the needs and expectations of the global community and specifically address automation. The first Foundational Principle states:

Companies should ensure that human rights and due process considerations are integrated at all stages of the content moderation process, and should publish information outlining how this integration is made. Companies should only use automated processes to identify or remove content or suspend accounts, whether supplemented by human review or not, when there is sufficiently high confidence in the quality and accuracy of those processes. Companies should also provide users with clear and accessible methods of obtaining support in the event of content and account action. 

Drawing on the Santa Clara Principles 2.0, international human rights standards, and years of research documenting the shortcomings of automated moderation, we propose eight recommendations for policymakers thinking about regulation and companies deploying AI-assisted content moderation systems.

1. Automated technologies should help, not replace, human moderators. For example, automated systems can help flag and prioritize content for review, while humans can interpret context, handle sensitive cases, and refine system performance.
2. Companies must be transparent about when and how automation is used in content decisions.
3. Companies must regularly audit their automated systems for bias, with particular attention to low-resource languages, vulnerable and marginalized communities, and conflict zones.
4. Users must have the ability to appeal, and to provide context when they believe human or automated moderation decisions have wrongfully removed their content. Appeals should be promptly evaluated and decided by human moderators.
5. Companies should regularly assess the human rights impact of their moderation decisions, and issue public statements of the results
6. If they rely on third-party vendors, companies should carefully (and regularly) audit those vendors for compliance with these same principles
7. Lawmakers should avoid promoting and passing legislation that effectively or explicitly mandates automated moderation systems
8. Policymakers should also refrain from attempting to dictate platforms technical and design choices to favor or disfavor particular expression.

These recommendations understand that automated content moderation isn’t just a technical problem for clever engineers and product teams to solve. Because content moderation shapes public discourse and fundamental rights, its design and oversight must respond to the concerns of policymakers, civil society, independent researchers, and the communities most affected by these systems.

This is the second post in a 2-part series on automated content moderation. Read the first post here.

This blog post is part 1 of a 2-part series. The second part sets out recommendations for companies and policymakers.

Six years ago—one month into a global pandemic—we argued that the automated moderation processes many platforms were rapidly adopting should be highly transparent, easily appealable, and temporary. We warned that "protocols adopted in times of crisis often persist when the crisis is over."

That warning proved prescient. The use of automation and artificial intelligence (AI) to identify, flag, and moderate content has become the new norm—a permanent feature of how platforms govern speech online. In this two part series, we’re take stock of this new norm, and considering what platforms can and should do to ensure that AI serves online expression rather than stifling it.

A brief history of automated content moderation

From spam filtering and keyword blacklists to the hash-matching technologies used to identify child sexual abuse material and terrorist content, automated technologies have been used in commercial content moderation for many years. While these tools have long posed risks to freedom of expression, their use was, for quite some time, relatively limited in scope.

Then, in 2017, a blog post published by Facebook (now Meta) described the company's "fairly recent" use of artificial intelligence to identify, classify, and remove violent extremist content. At the same time, Facebook emphasized caution, noting that it did not want to suggest there was "any easy technical fix."

Just one year later, Mark Zuckerberg appeared before the U.S. Senate's Commerce and Judiciary Committees and disclosed that "99 percent of the ISIS and Al Qaida content" removed by Facebook was flagged by AI "before any human sees it." He also stated that Facebook was "developing A.I. tools that can identify certain classes of bad activity proactively and flag it for our team at Facebook." At the time, we raised concerns about the ethical implications of using AI in this manner.

Then came 2020. The sudden reduction of the human moderation workforce, combined with a dramatic increase in social media use—and with it, a surge in misinformation—created the perfect conditions for platforms to expand their reliance on AI-driven moderation. It quickly became apparent that companies'—and particularly Meta's—approach to moderation during the pandemic represented a backslide in transparency, freedom of expression, and access to remedy. The increased reliance on automation was a significant factor.

The costs and benefits of AI content moderation

We knew in 2020 that the use of AI to moderate content would present problems for online freedom of expression. Today, those problems are well-documented. A 2025 joint declaration by special rapporteurs and representatives of the United Nations (UN), Organization for Security and Co-operation in Europe (OSCE), Organization of American States (OAS), and African Commission on Human and Peoples’ Rights (ACHPR) states:

“The use of AI content moderation can lead to over-removal, discrimination and censorship. Reliance on inherently biased datasets and opaque training processes can amplify pre-existing inequalities, risking homogenisation of expression, and erasure of linguistic and cultural diversity.”

EFF and many of our allies have documented these impacts. For example, our 2019 paper co-authored with Witness and Syrian Archive examined the impact of extremist content regulations—and their implementation through automation and AI—on human rights documentation. A 2020 report from Human Rights Watch highlighted the consequences of these removals, noting: "There is no way of knowing how much potential evidence of serious crimes is disappearing without anyone's knowledge."

The Center for Democracy and Technology's recent series on content moderation in the Global South demonstrates persistent inequities in content moderation of four “low-resource” languages—so-called because the relative scarcity of training data makes it more difficult to develop equitable and accurate AI models for them. 

Content moderation often disproportionately impacts vulnerable and historically marginalized groups, and AI content moderation is no different. GLAAD recognizes the role AI plays in scaling content moderation but notes that “when moderation systems lack nuance, transparency, and human oversight, they can fail to curb harassment and wrongly suppress legitimate LGBTQ content.”

These failures are not incidental. They are a predictable consequence of deploying automated systems to make complex judgments about language, culture, context, and identity at scale.

All of that said, automated content moderation can offer important benefits. The primary one: helping to spare human content moderators who must review content that varies from whimsical to horrific, often for little pay and with devastating mental health consequences. Outsourcing this work to the bots can offer some relief—though it’s worth noting that the humans hired to train the AI models face a similar dynamic.

In addition, AI models could potentially be trained over time to be more precise, accurate, and dynamic, helping to mitigate over-censorship and disinformation. The jury is still out on whether this potential will be realized; what we do know is that new approaches to the persistent problem of over and under-enforcement are desperately needed.

Automated moderation is no longer an experiment

Getting the balance between real costs and potential benefits depends a lot on the details: how automated systems are designed, trained, implemented, and audited.  

Despite advances in the sophistication and scale of automated moderation systems, many of the transparency, accountability, and due process safeguards advocated by civil society, researchers, and human rights experts have yet to be fully realized. At the same time, automated systems have become increasingly central to how platforms enforce their rules and govern online speech.

The question today is not whether companies will use AI to moderate content, but under what conditions they should do so. And now as ever, the answer is not that the public should just trust that platforms’ deployment of increasingly powerful systems will serve, rather than inhibit online expression. In fact, as automated systems become more sophisticated and more deeply embedded in platform governance, the need for transparency and accountability becomes more urgent. 

This is part 1 of a 2-part series. You can read the second part here.

This week, politicians in the UK pushed forward with plans to eviscerate privacy and free speech on the internet by announcing a ban on social media for users under 16 that is set to take effect in Spring 2027. 

The UK government continues to falsely characterize this policy as a necessary response to growing concerns about online harms for young people. In reality, much like the Online Safety Act, it will cause more harm than it will prevent. 

Users of all ages are burdened with proving their age before accessing content, with social media platforms such as Snapchat, TikTok, YouTube, Instagram, Facebook, and X included in the ban. There remains no reliable, privacy-preserving method of verifying the age of every internet user and methods vary from one platform to the next.

Young people will not simply be protected from being contacted by adults or endlessly scrolling—they’ll also lose access to educational videos on YouTube, local events on Facebook, and potentially cut off from distant friends and family. 

Public policy must be effective, proportionate and respectful of fundamental rights. Young people deserve better than a policy built on panic, and all internet users deserve a safe and free internet. A social media ban generates headlines, but it will not solve the problem. 

A Brief History of Age-Gating in the UK

Age restriction proposals in the UK date back to a decade ago, when the proposed Digital Economy Bill was put forth to (among other things) restrict young people from accessing pornographic websites. While the Digital Economy Act of 2017 passed without age-based restrictions, it laid the groundwork for later age verification measures.

Over the next few years, age checks for porn websites were announced then delayed several times. But it wasn’t until a consultation under the 2016-2019 May government and the 2020 publication of the Online Harms Whitepaper that age verification became a broader idea.

In 2023, the UK passed the controversial Online Safety Act, establishing powers that could weaken privacy protections and freedom of expression for internet users worldwide. In July 2025, the government implemented age assurance measures on sites hosting “harmful” content. 

And despite politicians affirming repeatedly that the Online Safety Act would solve all of the problems with online safety, this year they decided it in fact did not go far enough. American social psychologist and The Anxious Generation author Jonathan Haidt—who has called for age-related social media bans around the world, despite significant scientific doubt about his research—met with the UK Health Secretary in February to push for the ban.

In March, politicians introduced plans for a social media ban into the Children’s Wellbeing and Schools Bill to “prevent children under the age of 16 from becoming or being users” of “all regulated user-to-user services,” to be implemented by “highly-effective age assurance measures”—effectively banning under-16s from social media. 

When this proposal came before the House of Commons, MPs defeated and proposed their own amendment: enabling the Secretary of State to introduce provisions “requiring providers of specified internet services” to prevent access by children, under age 18 rather than 16, to specified internet services or to specified features; and to restrict access by children to specified internet services which ministers provide. 

But the social media ban does not stop there. The provision also requires internet service providers to limit the time kids spend online, and has rules about who can contact them online. These extreme rules will take decisions about using technology away from families and put them in the hands of government regulators. 

The history of this proposal shows that the UK government has repeatedly returned to the same flawed idea: restricting access to online services by requiring age checks for everyone. But the fundamental problems have not changed. There is still no widely available way to verify age online without compromising privacy—but even if there were, broad restrictions on social media will inevitably limit access to lawful speech, and valuable online communities, and arts and culture.