I am a huge fan of transparency about platform content moderation. I’ve considered it a top policy priority for years, and written about it in detail (with Paddy Leerssen, who also wrote this great piece about recommendation algorithms and transparency). I sincerely believe that without it, we are unlikely to correctly diagnose current problems or arrive at wise legal solutions.

So it pains me to admit that I don’t really know what “transparency” I’m asking for. I don’t think many other people do, either. Researchers and public interest advocates around the world can agree that more transparency is better. But, aside from people with very particular areas of interest (like political advertising), almost no one has a clear wish list. What information is really important? What information is merely nice to have? What are the trade-offs involved?

That imprecision is about to become a problem, though it’s a good kind of problem to have. A moment of real political opportunity is at hand. Lawmakers in the US, Europe, and elsewhere are ready to make some form of transparency mandatory. Whatever specific legal requirements they create will have huge consequences. The data, content, or explanations they require platforms to produce will shape our future understanding of platform operations, and our ability to respond — as consumers, as advocates, or as democracies. Whatever disclosures the laws don’t require, may never happen.

It’s easy to respond to this by saying “platforms should track all the possible data, we’ll see what’s useful later!” Some version of this approach might be justified for the very biggest “gatekeeper” or “systemically important” platforms. Of course, making Facebook or Google save all that data would be somewhat ironic, given the trouble they’ve landed in by storing similar not-clearly-needed data about their users in the past. (And the more detailed data we store about particular takedowns, the likelier it is to be personally identifiable.)

For any platform, though, we should recognize that the new practices required for transparency reporting comes at a cost. That cost might include driving platforms to adopt simpler, blunter content rules in their Terms of Service. That would reduce their expenses in classifying or explaining decisions, but presumably lead to overly broad or narrow content prohibitions. It might raise the cost of adding “social features” like user comments enough that some online businesses, like retailers or news sites, just give up on them. That would reduce some forms of innovation, and eliminate useful information for Internet users. For small and midsized platforms, transparency obligations (like other expenses related to content moderation) might add yet another reason to give up on competing with today’s giants, and accept an acquisition offer from an incumbent that already has moderation and transparency tools. Highly prescriptive transparency obligations might also drive de facto standardization and homogeneity in platform rules, moderation practices, and features.

None of these costs provides a reason to give up on transparency — or even to greatly reduce our expectations. But all of them are reasons to be thoughtful about what we ask for. It would be helpful if we could better quantify these costs, or get a handle on what transparency reporting is easier and harder to do in practice.

I’ve made a (very in the weeds) list of operational questions about transparency reporting, to illustrate some issues that are likely to arise in practice. I think detailed examples like these are helpful in thinking through both which kinds of data matter most, and how much precision we need within particular categories. For example, I personally want to know with great precision how many government orders a platform received, how it responded, and whether any orders led to later judicial review. But to me it seems OK to allow some margin of error for platforms that don’t have standardized tracking and queuing tools, and that as a result might modestly mis-count TOS takedowns (either by absolute numbers or percent).

I’ll list that and some other recommendations below. But these “recommendations” are very tentative. I don’t know enough to have a really clear set of preferences yet. There are things I wish I could learn from technologists, activists, and researchers first. The venues where those conversations would ordinarily happen — and, importantly, where observers from very different backgrounds and perspectives could have compared the issues they see, and the data they most want — have been sadly reduced for the past year.

So here is my very preliminary list:

• Transparency mandates should be flexible enough to accommodate widely varying platform practices and policies. Any de facto push toward standardization should be limited to the very most essential data.
• The most important categories of data are probably the main ones listed in the DSA: number of takedowns, number of appeals, number of successful appeals. But as my list demonstrates, those all can become complicated in practice.
• It’s worth taking the time to get legal transparency mandates right. That may mean delegating exact transparency rules to regulatory agencies in some countries, or conducting studies prior to lawmaking in others.
• Once rules are set, lawmakers should be very reluctant to move the goalposts. If a platform (especially a smaller one) invests in rebuilding its content moderation tools to track certain categories of data, it should not have to overhaul those tools soon because of changed legal requirements.
• We should insist on precise data in some cases, and tolerate more imprecision in others (based on the importance of the issue, platform capacity, etc.). And we should take the time to figure out which is which.
• Numbers aren’t everything. Aggregate data in transparency reports ultimately just tell us what platforms themselves think is going on. To understand what mistakes they make, or what biases they may exhibit, independent researchers need to see the actual content involved in takedown decisions. (This in turn raises a slough of issues about storing potentially unlawful content, user privacy and data protection, and more.)

It’s time to prioritize. Researchers and civil society should assume we are operating with a limited transparency “budget,” which we must spend wisely — asking for the information we can best put to use, and factoring in the cost. We need better understanding of both research needs and platform capabilities to do this cost-benefit analysis well. I hope that the window of political opportunity does not close before we manage to do that.

The Fisher Family Summer Fellows on Democracy and Development Program at Stanford University's Center on Democracy, Development and the Rule of Law is now accepting applications for our summer 2027 program, which will run from Sunday, July 18, to Friday, August 6, 2027. The deadline to apply is 11:59 pm PST on Tuesday, January 12, 2027.

The program brings together an annual cohort of approximately 30 mid-career practitioners from countries in political transition who are working to advance democratic practices and enact economic and legal reform to promote human development. Launched by CDDRL in 2005, the program was previously known as the Draper Hills Summer Fellows Program. The new name reflects an endowment gift from the Fisher family — Sakurako (Sako), ‘82, and William (Bill), MBA ‘84 — that secures the future of this important and impactful program.

From Afghanistan to Zimbabwe, we select our program participants from among hundreds of applicants each year for the significant contributions they have already made to their communities and their potential to make an even greater impact with some help from Stanford. We aim to give them the opportunity to join a global network of over 500 alumni from 96 countries who have all faced similar sets of challenges in bringing change to their countries.

The Fisher Family Summer Fellows Program provides an intensive 3-week on-campus forum for civil society leaders to exchange experiences and receive academic and policy training to enrich their knowledge and advance their work. Delivered by a leading Stanford faculty team composed of Michael McFaul, Kathryn Stoner, Francis Fukuyama, Larry Diamond, Erik Jensen, and more, the program allows emerging and established global leaders to explore new institutional models and frameworks to enhance their ability to promote good governance, accountable politics, and find new ways to achieve economic development in their home countries.

Prospective fellows from Ukraine are also invited to apply for our Strengthening Ukrainian Democracy and Development (SU-DD) Program, which runs concurrently with the Fisher Family Summer Fellows Program. The SU-DD program provides a unique opportunity for mid-career practitioners working on well-defined projects aimed at strengthening Ukrainian democracy, enhancing human development, and promoting good governance. Applicants to the SU-DD program will use the Fisher Family Summer Fellows Program application portal to apply and indicate their interest there. You will then be directed to a series of supplemental questions specific to the SU-DD program, including requiring a detailed description of your proposed project.

At a CDDRL research seminar held on October 1, 2026, Frances Cayton, the Einstein-Moos Postdoctoral Fellow at the Stanford Center on Democracy, Development and the Rule of Law, presented research from her book project on civil society in backsliding democracies.

Her presentation centered on the democratic potential of informal, apolitical civil society groups in resisting democratic erosion. She argued that autocrats devote little attention to these groups, leaving them with greater autonomy and the ability to decide when and whether to engage with the government. At the outset, these groups often have low civic consciousness, meaning they do not recognize the social capital and civic resources they hold. However, as autocratization threatens their independence, they become more aware of those resources and more committed to defending them, which makes them more likely to mobilize democratically and across partisan divides. 

Cayton began by noting that current scholarship often focuses on two ways autocratic regimes interact with civil society. First, they work alongside and reward groups that share their views as a source of support, and second, they crack down on opponents through repression and bureaucratic pressure. What this picture overlooks, Cayton argues, are the apolitical and informal groups that make up much of civic life, such as biking clubs and mushroom hunters, who often do not consider themselves part of civil society at all. 

To account for these groups, Cayton organizes civic life into a two-by-two framework of formal and informal organizations with political and apolitical missions. Formal groups have internal structures such as membership and dues, making them easy for the state to see. Informal groups have looser arrangements, such as friends who help stray dogs in their neighborhood. Political groups have an explicit political mission, such as human rights, labor, religious, or left-and right-wing causes, while apolitical groups focus on areas like sports, education, and the arts. 

Her argument therefore suggests that the less visible nature of these informal, apolitical groups makes them an almost blind spot in the autocrat's agenda, allowing them to maintain their autonomy. Cayton hypothesizes that, relative to formal pro-regime civil society, aspiring autocrats will target formal apolitical and opposition groups more often, but will not treat informal civil society differently. 

She then tests this through the case of Poland, drawing on a panel dataset covering the universe of Polish civil society, a survey of civic organizations, and interviews. Her analysis of public funding shows that after the Law and Justice party (PiS) took power in 2015, formal apolitical and formal opposition groups lost public funding relative to formal pro-regime groups, while informal groups saw no significant change. Informal and apolitical groups also became less likely to file optional financial disclosures, which she reads as a choice to remain less visible to the state. 

In her survey experiment, Cayton reminded civic groups of government threats to civil society. Informal and apolitical groups became more open to meeting groups with different political views and hosting cross-partisan events, while showing no greater willingness to work with PiS. Together, these results suggest that the regime's pressure largely bypassed informal and apolitical groups, and that the threat to civil society strengthened their commitment to independence and pluralism. 

Ultimately, Cayton's research shows that informal, apolitical civil society is a powerful tool for democratic resilience. As one interviewee put it, these groups often "become political in order to maintain apoliticality," which leads them to defend their independence by mobilizing in support of democracy.