Panel Summary | Platform Monetization and Freedom of Expression

Summary of the Roundtable on Comparative Legislation Regarding Platform Monetization and Freedom of Expression.

1. Background

The monetization of platforms—that is, the systems through which platforms enable creators, publishers, and other stakeholders to generate revenue—was addressed as a separate, though related, issue from content moderation. It was noted that monetization encompasses three avenues: revenue facilitated by brands (branded content, creator marketplaces), revenue facilitated by audiences (subscriptions, tips), and revenue paid by platforms (revenue-sharing and bonus programs). Within these channels, a distinction was made between products that the platform directly funds and those it merely facilitates: in the latter case, the decision on what to fund rests with the audience or the brand, not the platform. The platform’s operational role also varies depending on the product and the platform. For example, a tipping tool may be purely promotional, with payments routed through a third party, while other monetization products involve the platform directly in contracting and payment.

During the discussion, it was noted that Meta reported having paid creators $3 billion in 2025 through its revenue-sharing programs, and that similar programs have expanded from YouTube, Facebook, and Instagram to TikTok, Snapchat, X, and, most recently, LinkedIn. It is reported that Meta’s “Partner-Publisher List,” the only list of its kind currently published by a platform, includes approximately 17 million accounts; the list is overwritten daily, with no historical record retained.

2. Risks of Monetization

It was noted that the risks could be organized along a spectrum ranging from insufficient enforcement to excessive enforcement of the rules. Risks of insufficient enforcement include financial incentives for inauthentic activity, harmful or illegal content, and content theft—including accounts, some based in Asia, that divert revenue from original creators by reposting and monetizing stolen content. Risks of over-enforcement include the restriction of revenue for legitimate creators and the resulting self-censorship, as creators adjust their content to avoid demonetization.

According to Meta’s own EU transparency report for the first half of 2025, the platform took enforcement action against nearly 125,000 accounts it had identified as violating its monetization policies between January and June 2025. Separately, it was found that accounts previously flagged by Meta’s paid fact-checking partners continued to have access to monetization tools—a pattern examined in “(De)monetizing Repeat Disinformers”. According to YouTube’s own transparency report, approximately 51% of appealed decisions—across all types of restrictions—were reversed, and the majority of those reversals specifically involved decisions related to monetization.

The report also highlighted high-risk categories that were monetized despite nominal policy exclusions, including police and military pages.

3. Platform Rules and Their Enforcement

The report described how monetization rules operate on three levels (partner eligibility, account or product criteria, and content restrictions), although the details of each level vary considerably by platform and are indicative rather than standardized. Partner-level criteria typically include age limits and exclusions for politicians and government entities; some platforms impose additional restrictions that others do not. X, for example, specifically excludes state-controlled media.

During the meeting, it was noted that an audit of the platforms’ monetization terms against Article 14 of the EU’s Digital Services Act (DSA), Auditing Monetization Terms: Platforms are Failing Creators Under the DSA, identified substantial compliance deficiencies. In particular, it was found that YouTube’s monetization terms are not publicly available; those of other platforms include provisions subject to discretionary enforcement with no established liability for miscalculations, as well as clauses that restrict creators from disclosing their earnings or making critical statements about the platform.

4. Legal and Regulatory Framework

Throughout the discussion, it was emphasized that, pursuant to Article 14 of the DSA, monetization terms fall under existing transparency obligations; Articles 12, 16 and 20 provide relevant reporting channels; and Articles 34 and 35 set forth risk assessment and mitigation for systemic platforms. A formal complaint under the DSA regarding Meta’s monetization enforcement and reporting practices was also mentioned; this complaint has since been published.

Under the Digital Markets Act (DMA), transparency obligations currently apply to “Audience Network” publishers (third-party apps), but not to creators within the platforms. The platforms have not published a justification for this distinction; in practice, they do not report in-platform monetization data under the DMA’s transparency obligations.

Finally, the upcoming Digital Fairness Act (Digital Fairness Act) (a European Commission proposal, not yet adopted) was identified as a possible avenue for establishing monetization transparency as a consumer right, comparable to current advertising transparency requirements. See also: WHAT TO FIX’s Recommendations for the Digital Fairness Act proposal, Open Letter: Influencer Marketing Rules Must Encompass All Platform Monetization Services and Monetization Principles.

5. Key Open Questions Raised During the Discussion

First, the question was raised as to how monetization transparency requirements should be calibrated across platforms, given that current practices and redistribution rates vary significantly by platform (it is estimated that Meta redistributes 1.5% of relevant revenue and Snapchat 15%). This gap illustrates the scale of the issue and does not constitute a proposed uniform industry standard. See: De-Risking Social Media Monetization: Rating Platforms’ Coverage of Monetization-Related Risks.

Second, doubts were raised about the adequacy of a transparency approach limited to disclosure: it was noted that meaningful accountability should go far beyond a simple monetization label, toward more structured and substantive disclosure requirements.

6. Discussion with the Public

Participants discussed how unpredictable monetization terms can lead to self-censorship, and cited examples of creators who publicly tone down their criticism of platforms for fear of losing access to monetization. The role of the out-of-court dispute resolution bodies provided for in the DSA in addressing monetization disputes was raised; reportedly, some of these bodies have begun to treat monetization as part of their jurisdiction, although the results remain limited.

The discussion also addressed where regulatory priorities should lie. Transparency was identified as a more accessible starting point than a more comprehensive reform, along with concerns about conflicts of interest inherent in the monetization of government and political accounts.

Participants raised concerns about whether a single, comprehensive regulatory framework would be more effective than coordination among existing sector-specific regulators (competition, data protection, anti-corruption, taxation), and noted the limited regulatory interest to date in a new, specific framework. The limited scope of the DMA was discussed, and it was clarified that the issue is not a restrictive definition of “publisher,” but rather the platforms’ abandonment of the advertising intermediation model for in-platform payments. The possibility of regulating by commercial service rather than by platform as a single entity was also raised, with reference to related discussions taking place in Germany regarding intermediary liability and monetization services—discussions noted as an emerging and unresolved issue in any jurisdiction.

Finally, participants discussed the public’s understanding of monetization. They noted that it might be more intuitive for ordinary users than general debates about platform accountability, though they cautioned that this understanding often assumes a one-to-one correspondence between an account and a person, without considering accounts operated as part of larger networks.

7. Clarifications

Chatham House Rule: This summary fully adheres to the Chatham House Rule. The substantive content, including the data, findings, and positions presented, comes primarily from research conducted by the guest speaker’s organization; comments and questions raised during the discussion are reported without individual attribution.

Clarification on the Use of AI: Artificial intelligence tools were used to assist in the preparation of this summary. The text was reviewed prior to circulation.

Summary written by Josefina Gálvez, Research Assistant, CELE.