Polar Bear Dreams

This blog post is part 1 of a 2-part series. The second part will set out recommendations for companies and policymakers.

Six years ago—one month into a global pandemic—we argued that the automated moderation processes many platforms were rapidly adopting should be highly transparent, easily appealable, and temporary. We warned that "protocols adopted in times of crisis often persist when the crisis is over."

That warning proved prescient. The use of automation and artificial intelligence (AI) to identify, flag, and moderate content has become the new norm—a permanent feature of how platforms govern speech online. In this two part series, we’re take stock of this new norm, and considering what platforms can and should do to ensure that AI serves online expression rather than stifling it.

A brief history of automated content moderation

From spam filtering and keyword blacklists to the hash-matching technologies used to identify child sexual abuse material and terrorist content, automated technologies have been used in commercial content moderation for many years. While these tools have long posed risks to freedom of expression, their use was, for quite some time, relatively limited in scope.

Then, in 2017, a blog post published by Facebook (now Meta) described the company's "fairly recent" use of artificial intelligence to identify, classify, and remove violent extremist content. At the same time, Facebook emphasized caution, noting that it did not want to suggest there was "any easy technical fix."

Just one year later, Mark Zuckerberg appeared before the U.S. Senate's Commerce and Judiciary Committees and disclosed that "99 percent of the ISIS and Al Qaida content" removed by Facebook was flagged by AI "before any human sees it." He also stated that Facebook was "developing A.I. tools that can identify certain classes of bad activity proactively and flag it for our team at Facebook." At the time, we raised concerns about the ethical implications of using AI in this manner.

Then came 2020. The sudden reduction of the human moderation workforce, combined with a dramatic increase in social media use—and with it, a surge in misinformation—created the perfect conditions for platforms to expand their reliance on AI-driven moderation. It quickly became apparent that companies'—and particularly Meta's—approach to moderation during the pandemic represented a backslide in transparency, freedom of expression, and access to remedy. The increased reliance on automation was a significant factor.

The costs and benefits of AI content moderation

We knew in 2020 that the use of AI to moderate content would present problems for online freedom of expression. Today, those problems are well-documented. A 2025 joint declaration by special rapporteurs and representatives of the United Nations (UN), Organization for Security and Co-operation in Europe (OSCE), Organization of American States (OAS), and African Commission on Human and Peoples’ Rights (ACHPR) states:

“The use of AI content moderation can lead to over-removal, discrimination and censorship. Reliance on inherently biased datasets and opaque training processes can amplify pre-existing inequalities, risking homogenisation of expression, and erasure of linguistic and cultural diversity.”

EFF and many of our allies have documented these impacts. For example, our 2019 paper co-authored with Witness and Syrian Archive examined the impact of extremist content regulations—and their implementation through automation and AI—on human rights documentation. A 2020 report from Human Rights Watch highlighted the consequences of these removals, noting: "There is no way of knowing how much potential evidence of serious crimes is disappearing without anyone's knowledge."

The Center for Democracy and Technology's recent series on content moderation in the Global South demonstrates persistent inequities in content moderation of four “low-resource” languages—so-called because the relative scarcity of training data makes it more difficult to develop equitable and accurate AI models for them. 

Content moderation often disproportionately impacts vulnerable and historically marginalized groups, and AI content moderation is no different. GLAAD recognizes the role AI plays in scaling content moderation but notes that “when moderation systems lack nuance, transparency, and human oversight, they can fail to curb harassment and wrongly suppress legitimate LGBTQ content.”

These failures are not incidental. They are a predictable consequence of deploying automated systems to make complex judgments about language, culture, context, and identity at scale.

All of that said, automated content moderation can offer important benefits. The primary one: helping to spare human content moderators who must review content that varies from whimsical to horrific, often for little pay and with devastating mental health consequences. Outsourcing this work to the bots can offer some relief—though it’s worth noting that the humans hired to train the AI models face a similar dynamic.

In addition, AI models could potentially be trained over time to be more precise, accurate, and dynamic, helping to mitigate over-censorship and disinformation. The jury is still out on whether this potential will be realized; what we do know is that new approaches to the persistent problem of over and under-enforcement are desperately needed.

Automated moderation is no longer an experiment

Getting the balance between real costs and potential benefits depends a lot on the details: how automated systems are designed, trained, implemented, and audited.  

Despite advances in the sophistication and scale of automated moderation systems, many of the transparency, accountability, and due process safeguards advocated by civil society, researchers, and human rights experts have yet to be fully realized. At the same time, automated systems have become increasingly central to how platforms enforce their rules and govern online speech.

The question today is not whether companies will use AI to moderate content, but under what conditions they should do so. And now as ever, the answer is not that the public should just trust that platforms’ deployment of increasingly powerful systems will serve, rather than inhibit online expression. In fact, as automated systems become more sophisticated and more deeply embedded in platform governance, the need for transparency and accountability becomes more urgent.