Report illegal content to Reddit under the EU Digital Services Act (Article 16)

The EU Digital Services Act (Regulation (EU) 2022/2065) requires every provider of hosting services to give people a way to tell it about content they think is illegal. Article 16(1) says providers must put in place mechanisms that allow "any individual or entity" to notify them, that those mechanisms must be "easy to access and user-friendly", and that they must allow notices to be submitted "exclusively by electronic means". Reddit stores content posted by its users, so it is a hosting service and this duty applies to it.

Illegal content has a specific meaning. Article 3(h) defines it as "any information that, in itself or in relation to an activity, including the sale of products or the provision of services, is not in compliance with Union law or the law of any Member State which is in compliance with Union law, irrespective of the precise subject matter or nature of that law". The Act does not create new offences. It sets up a process for flagging content that another law already makes unlawful, such as incitement to violence, certain hate speech, fraud, counterfeit sales, or child sexual abuse material, depending on the member state.

The notice matters because of what it can trigger. Under Article 16(3), a notice that allows a diligent provider to identify the illegality without a detailed legal examination is treated as giving the provider actual knowledge or awareness for the purposes of Article 6. Article 6 is the rule that protects a host from liability for stored content only if it does not have actual knowledge of illegal content, or acts expeditiously to remove it once it does. A precise, well-evidenced notice therefore puts the platform in a position where it has to decide what to do.

Reddit's status under the Act. The European Commission announced on 31 August 2026 (press release IP/26/1772) that it had designated Reddit, together with Roblox, as a Very Large Online Platform. The release says Reddit was already subject to the general obligations that apply to online platforms, and that Reddit has four months, that is until January 2027, to comply with the additional obligations for very large platforms. The notice route described here is one of the general obligations and does not depend on the designation. The release also names the Netherlands authority ACM as the Digital Services Coordinator for Reddit, working with the Commission.

Article 16(2) says the mechanism must facilitate notices that are "sufficiently precise and adequately substantiated" and must let people submit notices containing all of four elements. Each is quoted below, followed by what it means in practice.

Element (a) is "a sufficiently substantiated explanation of the reasons why the individual or entity alleges the information in question to be illegal content". In plain words, say which law you think is broken and why this content breaks it. Naming the law, and the country if it is a national law, helps. Quote the relevant words from the post rather than describing it vaguely.

Element (b) is "a clear indication of the exact electronic location of that information, such as the exact URL or URLs, and, where necessary, additional information enabling the identification of the illegal content adapted to the type of content and to the specific type of hosting service". Give the full web address of each post or comment, not just the community name. If the content is an image or a video inside a longer thread, say where it appears.

Element (c) is "the name and email address of the individual or entity submitting the notice, except in the case of information considered to involve one of the offences referred to in Articles 3 to 7 of Directive 2011/93/EU". That Directive is the EU law on combating the sexual abuse and sexual exploitation of children and child pornography, and Articles 3 to 7 cover offences on sexual abuse, sexual exploitation, child pornography, solicitation of children, and incitement, aiding and abetting, and attempt. For everything else you should give a real name and a working email address, because that is what lets the platform confirm receipt and tell you its decision.

Element (d) is "a statement confirming the bona fide belief of the individual or entity submitting the notice that the information and allegations contained therein are accurate and complete". This is a good-faith statement. Only make it if you honestly believe what you have written is accurate and complete, and keep to facts you can support.

Article 16(4) says that where the notice contains your electronic contact information, the provider must, "without undue delay", send you a confirmation of receipt. Article 16(5) says the provider must also, without undue delay, notify you of its decision about the information and give you information on the possibilities for redress. Keep both messages.

Article 16(6) says providers must process notices and take decisions "in a timely, diligent, non-arbitrary and objective manner". Where automated means are used for that processing or decision-making, the notification of the decision must include information on that use. The Act does not set a number of days for the decision, so a slow answer is not automatically a breach, but a decision that is arbitrary, or ignores the substance of your notice, can be challenged.

If Reddit removes or restricts the content because of your notice, the person who posted it is entitled to a statement of reasons under Article 17. Article 17(3)(b) says that statement must include the facts and circumstances relied on, including, where relevant, "information on whether the decision was taken pursuant to a notice submitted in accordance with Article 16 or based on voluntary own-initiative investigations and, where strictly necessary, the identity of the notifier". In practice, expect the poster to be told that a notice was involved, and be aware that your identity can be disclosed to them where the platform considers that strictly necessary. Think about that before you file a notice about someone you fear.

There are three steps beyond the first decision. The first is Reddit's internal complaint system. Article 20(1) requires online platforms to give people, including those who submitted a notice, "for a period of at least six months" after the decision, access to an effective internal complaint-handling system that allows complaints "electronically and free of charge", including against the decision taken on a notice. Article 20(4) requires complaints to be handled "in a timely, non-discriminatory, diligent and non-arbitrary manner", and Article 20(6) requires the decisions to be taken under the supervision of appropriately qualified staff and not solely on the basis of automated means.

The second step is out-of-court dispute settlement. Article 21(1) entitles people addressed by those decisions, including people who submitted notices, to select a certified out-of-court dispute settlement body to resolve the dispute. Two limits are worth knowing. The body "shall not have the power to impose a binding settlement of the dispute on the parties". And Article 21(1) leaves your right to take the matter to court untouched. Under Article 21(5), dispute settlement must be available to you free of charge or at a nominal fee, and if the body decides in your favour the platform bears the fees. Article 21(8) says the Commission publishes a list of the certified bodies.

The third step is a complaint to the authorities. Article 53 gives recipients of the service the right to lodge a complaint alleging an infringement of the Regulation with the Digital Services Coordinator of the member state where they are located or established. The coordinator assesses it and, where appropriate, passes it to the coordinator of the country where the provider is established. This route addresses the platform's compliance with the Act. It is not an appeal on one piece of content.

Finally, Article 23(2) is a safeguard for the platform, and you should know it applies to you. After a prior warning, providers must suspend, for a reasonable period, the processing of notices from people who frequently submit notices that are manifestly unfounded. A genuine, well-reasoned notice is not at risk. Repeated, manifestly unfounded reporting is.