Consumer association finds violations in reporting illegal content

• Investigation shows: Reporting channels on platforms have technical hurdles, dark patterns and lack of transparency
• Federation of German Consumer Organisations demands: Platforms must fully implement DSA regulations, competent authorities must exercise greater control
• Protection of children and young people on platforms: reporting channels should be particularly easy to use for minors.

Online platforms repeatedly make it difficult for users to report illegal content as legal violations. This is shown by an investigation by the Federation of German Consumer Organisations (Verbraucherzentrale Bundesverband). A total of ten online marketplaces and social media platforms were examined – each from the perspective of adult, unregistered and minors. The Digital Services Act (DSA) stipulates that online platforms must offer easily accessible and user-friendly reporting and complaint mechanisms.

“Users of online platforms repeatedly encounter illegal content, such as advertisements for fake shops or unauthorised dietary supplements. If they want to report this content, they sometimes have to overcome considerable hurdles. That has to change”, says Ramona Pop, Executive Director of the Federation of German Consumer Organisations. “Platforms are obliged to provide easily accessible options for reporting such content.“

Study reveals technical hurdles, dark patterns and lack of transparency

The Federation of German Consumer Organisations has examined the reporting and complaint procedures on five online marketplaces (AliExpress, Amazon, Shein, Temu, Zalando) and five social media platforms (Facebook, Instagram, Snapchat, TikTok, YouTube) from different user perspectives. Although the platforms offer reporting channels for illegal content, these are repeatedly characterised by technical hurdles, manipulative designs (dark patterns) and lack of transparency.

In many cases, the reporting channels were difficult to access and not always user-friendly. Long click paths, confusing selection lists and duplication of required information made reporting difficult. In some cases, mandatory confirmation of receipt was not received. Decisions were not made by the platforms at all or not made in a timely manner. In addition, technical hurdles and the automatic or mandatory provision of personal data when reporting could be a deterrent.

It was also noticeable that the reporting channels for minors on the five social media platforms did not differ from those for adults. In the opinion of the Federation of German Consumer Organisations, this means that the platforms do not comply with the European guidelines for age-appropriate design.

Regulatory authorities must monitor more effectively

“Illegal content has no place on online platforms. Easily accessible and user-friendly reporting and complaint mechanisms could help to remove it quickly. Platforms must finally implement the DSA regulations in full and remove all barriers to reporting illegal content – or face consequences in the form of fines,” said Pop.

The Federation of German Consumer Organisations is calling on competent authorities to consistently enforce the rules of the DSA and to hold platforms more accountable in this regard. In addition, platforms must ensure a high level of protection for privacy, security and the protection of minors. Age-appropriate reporting channels tailored to minors are particularly relevant.

Method 

The Federation of German Consumer Organisations examined ten selected online marketplaces and social media platforms to see how the reporting mechanisms for consumers are designed and to what extent they comply with the requirements set out in the DSA. The sample consisted of the following platforms: AliExpress, Amazon, Facebook, Instagram, Shein, Snapchat, Temu, TikTok, YouTube and Zalando. The review focused on Article 16 DSA (reporting and redress mechanisms) and Article 20 DSA (internal complaint -handlingsystem). The reporting channels were examined from the perspective of adult users with a user account on the respective platform and users without a user account. For the five social media platforms, the perspective of minors with a user account was also examined. The evaluation was based on a previously developed category system that is aligned with the legal requirements. The Federation of German Consumer Organisations reviewed the platforms between 9 October 2025 and 26 January 2026.