DSA-Compliant Moderation Policy Template
A moderation policy built around EU Digital Services Act principles: timely, consistent, and documented.
The EU Digital Services Act expects content to be handled in a timely, non-arbitrary, and documented way. While the legal duties fall on platforms, brands that mirror those principles in their own comment sections moderate more consistently and are better prepared if a platform or regulator asks how harmful content was handled. This template gives you a ready-to-customize moderation policy aligned with DSA principles, plus an audit-log format and a compliance checklist. It pairs with our Statement of Reasons template.
Bereit zur Verwendung Vorlagen
DSA-Aligned Moderation Policy — Full Document
Wann verwenden: Customize the bracketed fields, share with your team, and review quarterly. This is an internal operational policy, not legal advice — consult a lawyer for obligations specific to your business.
SOCIAL MEDIA COMMENT MODERATION POLICY (DSA-ALIGNED) [Company Name] | Effective Date: [Date] | Version: [X.X] | Owner: [Role] 1. PURPOSE This policy sets out how [Company Name] moderates comments on its social media posts and paid ads. It is designed to reflect the principles of the EU Digital Services Act (DSA): timely action on illegal content, consistent and non-arbitrary enforcement, and clear documentation of decisions. This document is an internal operational policy, not legal advice. 2. SCOPE Applies to all comment sections on channels operated by [Company Name], including Instagram, Facebook, TikTok, YouTube, and Bluesky, across both organic posts and paid advertising, for audiences in the EU and elsewhere. 3. PRINCIPLES (DSA-ALIGNED) • Timeliness: Illegal or clearly harmful comments are actioned as quickly as possible, ideally within minutes, using automated detection at advertising scale. • Consistency: The same rules apply to every comment on every campaign. Enforcement is rule-based, not ad hoc. • Non-arbitrariness: Decisions follow the categories below rather than individual discretion in the moment. • Documentation: Every moderation action is logged with the rule it triggered and whether it was automated or human (see Audit Log). • Redress: Users who believe a comment was wrongly hidden can have the decision reviewed; wrongly hidden comments are restored. 4. CONTENT CATEGORIES AND ACTIONS Category A — ALLOW: Genuine questions, feedback, praise, constructive criticism, user-generated content. Category B — RESPOND: Customer service inquiries, product/pricing/shipping questions, legitimate complaints (reply within SLA). Category C — HIDE (not delete): Mild off-topic content, non-malicious competitor mentions, content needing review. Category D — REMOVE / HIDE PROMPTLY (illegal or clearly harmful): Scams and phishing, fraudulent or counterfeit links, hate speech and slurs, threats, sexual content, doxxing, other illegal content. Category E — ESCALATE: Legal threats, regulator or government contact, potential PR crisis, threats of self-harm (signpost crisis resources). 5. RESPONSE / ACTION TARGETS (SLA) • Illegal/Category D content: actioned within minutes (automated), reviewed same day. • Customer complaints: within 1 hour during business hours. • Product questions: within 2 hours during business hours. • Escalations: notify owner within 15 minutes. 6. TOOLS AND AUTOMATION • Primary tool: [FeedGuardians / tool name] • Automated detection and hiding: enabled for Category D. • Human review queue: Category C and E. • Audit log: all actions recorded (see next section). • Disclosure: where automated tools make a decision, this is recorded. 7. REVIEW AND REDRESS A user may request review of a hidden comment via [contact method]. Reviews are handled within [X business days]. If a comment was hidden in error, it is restored and the log is updated. 8. POLICY REVIEW This policy is reviewed [quarterly] and after any material platform or regulatory change.
Moderation Audit Log Template
Wann verwenden: A simple, auditable record of every moderation decision. FeedGuardians produces this log automatically; this format works if you maintain it manually.
MODERATION AUDIT LOG — one row per action Columns: • Date / Time (UTC) • Platform (IG / FB / TikTok / YouTube / Bluesky) • Post or Campaign ID • Comment summary (no personal data beyond what is necessary) • Category (A-E) • Action taken (Allowed / Responded / Hidden / Removed / Escalated) • Rule triggered (e.g. "Scam link", "Hate speech", "Competitor bait") • Decided by (Automated / Reviewer name) • Review requested? (Y/N) and outcome (Upheld / Restored) Example row: 2026-06-07 14:02 | Instagram | AD-10293 | Fake discount link impersonating brand | D | Removed | Scam/phishing link | Automated | N Keep this log retrievable. It is your internal equivalent of a DSA "statement of reasons" record and supports consistency reviews.
DSA Comment-Section Compliance Checklist
Wann verwenden: Run through this checklist quarterly. It maps your comment-section operations to the DSA principles of timeliness, consistency, and documentation.
DSA COMMENT-SECTION COMPLIANCE CHECKLIST [ ] Written moderation policy documented and shared with the team [ ] Real-time detection in place for scams, fraud, and hate speech [ ] Same rules applied consistently across every campaign and platform [ ] Every moderation action logged with its triggering rule [ ] Automated vs human decisions distinguished in the log [ ] A path exists to review and restore wrongly hidden comments [ ] Escalation route defined for legal, regulatory, and crisis cases [ ] Policy reviewed at least quarterly and after platform/regulatory changes [ ] If selling to the UK: also aligned with the Online Safety Act
Tipps für Verwendung von diesen Vorlagen
Automate the clear-cut cases
Use AI to detect and hide illegal content within seconds. Manual moderation cannot deliver the timeliness the DSA expects at advertising scale.
Write the rules down
A documented policy is what makes enforcement consistent and non-arbitrary rather than dependent on whoever is online that day.
Log everything
Keep a retrievable record of what was actioned and why. This audit trail is your internal analogue of a statement of reasons.
Keep a redress path
Be able to review and restore wrongly hidden comments. Respecting users' rights is central to the DSA's approach.
Allgemeine Fragen
No. This is an operational template to help you moderate in a way aligned with DSA principles. It is not legal advice. For obligations specific to your business, consult a qualified lawyer.
The DSA's formal duties fall on the platforms, not on individual advertisers, so you are not legally required to publish a statement-of-reasons or notice-and-action mechanism for your own posts. However, a documented, consistent moderation policy protects your brand, keeps your ad environments clean, and aligns you with the regulatory direction of travel.
A standard policy focuses on what to allow, hide, or delete. This version adds the DSA-aligned principles of timeliness, consistency, documentation, and redress, plus an audit-log format and a compliance checklist, so your moderation is defensible as well as effective.
Yes. FeedGuardians records every moderation action with the rule it triggered and whether it was automated, giving you the audit trail this template describes without manual logging.
Automatisieren Sie Ihre Antworten
mit FeedGuardians
Hören Sie auf, manuell zu kopieren und einzufügen. Lassen Sie die KI Ihre Kommentarantworten 24/7 mit Ihrer Markenstimme und genehmigten Vorlagen übernehmen.
Kostenlose Testversion starten7-day free trial
Verwandte Vorlagen
Mehr entdecken