Ref. Ares(2020)2922680 - 05/06/2020
(complemented
by
self amount of propaganda published (some measures
regulation)
should be taken only on heavily abused platforms).
Specific requirements in
terms of action upon referral
(including time limit of one
hour)
More explicit and detailed Negative (for smaller platforms). It's very hard to build
obligations
to
deploy a good law in this matter (e.g. copyrights
specific proactive measures infringements), but largest platforms should be
(including
automatic obligated to deploy them in at least some extend along
detection)
with reporting of effects.
Specific requirements to Negative (for smaller platforms). Many times this
cooperate with other hosting could be hard to implement. This should be more based
service providers to avoid more on voluntary approach.
the dissemination across
platforms
Sanctions in case of non-
EU should have power to block access to platforms that
compliance
are not complying with most important requirements.
This would be important in case of political
propaganda used to destabilize member states.
Exchanges of information Positive, but should be forced only on largest or most
with law enforcement to abused platforms (not every platform contains terrorist
limit any interference with materials). Amount of information provided should
investigations and to feed depend on the type of the platform and its size.
into the analysis of terrorist
material
Clarify
that
companies Positive
engaged
in
proactive
measures benefit from the
liability exemption (Good
Samaritan clause)
Requirement to Member Positive, poor quality referrals do a lot of damage for
States to increase referral the whole process
capabilities, quality criteria
for referrals and for referral
entities in Member States to
provide relevant support to
companies in case of doubt
about
qualification
as
terrorist
content
(e.g.
through points of contact)
Nomination of point of Positive, but for very small companies it could be
contact within Companies
illusionary
4
Reporting obligations for Positive, but only if the size of the platform will be
companies3
taken into account during deciding how specific the
reporting should be
Transparency requirements Positive
for companies vis a vis their
users4
Compulsory
safeguards, Positive
such as the ones in the
general chapter of the
Recommendation
The establishment of an Positive, but only if it wouldn't be very complicated to
external
audit/monitoring comply
mechanism for assessing
compliance of companies.
3 See point 41 of the Recommendation.
4 See points 16 and 17 of the Recommendation.
5