Comment and content moderation

Legal basis and our role

New European Strategies provides a space in which users publish their own contributions. Under Regulation (EU) 2022/2065 (the Digital Services Act, DSA) we are a hosting service provider in respect of content supplied by users.

We do not monitor content generally and are under no obligation to do so (Article 8 DSA). We act on reports and on what we detect ourselves.

We are not liable for third-party content until we know it is unlawful; once we obtain such knowledge we act expeditiously (Article 6 DSA).

The national procedural framework is supplemented by the act amending the Act on Providing Services by Electronic Means, which designates the President of the Office of Electronic Communications (UKE) as the Digital Services Coordinator. The Sejm passed it on 31 July 2026 and adopted it together with a Senate amendment on 4 September 2026; it enters into force after publication. Until then we apply the DSA directly.

What we do not publish

The list below is closed as to categories and open as to form - what counts is the substance of a contribution, not how it was written.

• Unlawful content: incitement to violence or hatred, threats, defamation, infringement of personal rights, copyright infringement, content prohibited by criminal law.
• Harassment and personal attacks: attacking the person instead of the argument, disclosing another person's data without consent, impersonating a person or institution.
• Spam and manipulation: unlabelled advertising, mass-duplicated content, artificial amplification, accounts created to evade a block.
• Harmful disinformation: knowingly spreading false factual claims about security, public health or electoral processes. We distinguish an assessment from a factual claim - you may disagree with an opinion and that is not a reason for removal.
• Content harmful to minors and any material depicting sexual abuse.
• Revealing the identity or affiliation of a speaker from a discussion held under the Chatham House Rule.

Measures we apply

We match the measure to the seriousness of the breach, starting with the mildest one that actually resolves the problem.

• Held for review - the content awaits assessment and is not yet publicly visible. A transitional state, not a penalty.
• Hiding content - the contribution is no longer publicly visible but remains available to its author and to moderators. Reversible.
• Marking as spam - applied to bulk and advertising content.
• Removing content - irreversible; applied to unlawful content and flagrant breaches.
• Account restriction - temporary suspension of the ability to comment.
• Account suspension or deletion - for repeated breaches or a single serious one. In line with Article 23 DSA we give prior warning of a suspension, unless the content is unlawful and criminal in nature.
• Notifying law enforcement - where content gives rise to a suspicion of a criminal offence threatening the life or safety of persons (Article 18 DSA).

How to report content (the Article 16 DSA mechanism)

Anyone may submit a report - including people without an account. The reporting channel is office@neweuropeanstrategies.com with "content report" in the subject line. Signed-in users can report content directly from the contribution.

• For a report to be effective, provide: the address (link) of the content, an explanation of why you consider it unlawful or contrary to our rules, and your contact details.
• A statement of good faith is not formally required, but we treat manifestly false reports as misuse of the mechanism (Article 23(2) DSA) and may suspend the ability to submit them.
• We confirm receipt promptly and inform you of the decision together with its reasons.
• A report that contains contact details and is precise enough to establish illegality without a detailed legal examination gives us knowledge of the content within the meaning of Article 6 DSA - and we then act expeditiously.
• We will consider an anonymous report, but we will have no way to send you the decision or to accept an appeal.

Statement of reasons (Article 17 DSA)

The author of content subjected to a measure receives clear and specific reasons. We do not send messages of the kind the content breached our terms without saying what the allegation concerns.

• Which measure we applied and its territorial and temporal scope.
• The facts and circumstances we relied on - including whether the decision followed a report or our own detection.
• Whether automated means were used in reaching the decision.
• The basis: the legal provision (where we found the content unlawful) or the specific clause of our rules (where we found it contrary to those rules).
• Information about the possibility of appeal and about other available routes of redress.

Appeals

Every moderation decision can be appealed. We run an internal complaint-handling procedure VOLUNTARILY: as a micro-enterprise we are exempt from Section 3 of Chapter III DSA under Article 19 DSA, but we consider a decision without an appeal route to be a decision without review.

• Submit an appeal to office@neweuropeanstrategies.com within 6 months of receiving the statement of reasons.
• The appeal is handled by a person who did not take the original decision. The outcome is not reached by automated means alone - a human approves the decision.
• We handle appeals in a timely, non-discriminatory and diligent manner. If an appeal is well founded we promptly reverse the measure and restore the content.
• We communicate the outcome with reasons. Upholding a decision also requires an explanation of why.
• Appealing to us does not close off judicial proceedings or a complaint to the competent authority - you may use either independently and at any time.

Automation and human involvement

• We use automated filters that detect spam, mass duplication and obvious abuse. A filter may hold content for review - it does not remove it on its own.
• Decisions to remove content, restrict or suspend an account are taken by a human. We do not operate fully automated removal of contributions.
• Where automated means were used in a given case, we always disclose it in the statement of reasons.
• The extent to which we use artificial intelligence tools is described in a separate document (/przejrzystosc-ai).

Transparency and statistics

• We keep an internal record of reports, measures applied and appeals, together with the basis for each decision.
• The reporting obligations in Articles 15 and 24 DSA do not apply to us at our current scale (Article 19 DSA). If we cross that threshold we will start publishing transparency reports and will say so on this page.
• Moderation operations in discussion clubs are recorded in a log visible to the club's board. Revealing the author of an anonymous contribution requires a written reason and is recorded separately.
• We use no dark patterns: deciding to report, appeal or opt out is exactly as easy as deciding the opposite.

Point of contact

The point of contact for users and for authorities in matters relating to content moderation is office@neweuropeanstrategies.com. We accept correspondence in Polish and English.

We execute authorities' orders to act against content or to provide information in accordance with Articles 9 and 10 DSA and inform the affected user about them, unless a legal provision or the order itself prohibits it.