CREATOR INITIATIVE

The Petition

On the transparency of algorithmic moderation and the protection of creators’ digital rights on YouTube

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Open Letter on the Transparency and Substantiation of YouTube’s Decisions Regarding Demonetization and Channel Restrictions

To: YouTube LLC (Google LLC) — service operator
EU contact point: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
Copy: Coimisiún na Meán (Ireland’s Digital Services Coordinator); European Commission (DG CNECT)
From: Independent creators and creative collectives who have signed this letter through the URBAN STUDIO platform
Coordinator: URBAN STUDIO
Date: May 9, 2026

Preamble

This letter is submitted in connection with the situation that has emerged in 2025–2026, involving widespread demonetization, distribution restrictions, and termination of channels’ participation in the YouTube Partner Program. The vast majority of cases known to the signatories concern content that shows no objective signs of spam, deception, mass-produced repetitive material, or inauthenticity — these are works in genres such as 2D animation, 3D animation, CGI, VFX, hybrid productions, projects using AI as an auxiliary tool, as well as ordinary authored content (vlogs, gaming streams, educational and informational videos) created by real people on camera.

The signatories acknowledge YouTube’s right to establish and apply monetization rules and to combat genuine abuse. However, in accordance with EU Regulation 2022/2065 (Digital Services Act, hereinafter “DSA”) and EU Regulation 2019/1150 (Platform-to-Business Regulation, hereinafter “P2B Regulation”), such measures must be lawful, verifiable, proportionate, based on specific facts, and accompanied by an effective appeal mechanism.

The subject of this letter is not the fact of automated moderation as such, but rather that in its current form it:

  • lacks genuine transparency regarding the specific grounds for decisions;
  • systematically conflates good-faith authored content with spam and fraud;
  • deprives creators of a real opportunity to appeal;
  • is accompanied by the withholding of funds already earned by creators, and in some cases — the withholding of direct viewer donations through “Super Thanks” / “Super Chat”;
  • is combined with continued advertising display on the very same channels for which the creator has been denied monetization.

Part A · Section 4. Requests and Demands

In view of the situation that has arisen, the signatories ask YouTube to:

  1. Cease the mass application of formulaic automated decisions with respect to good-faith authored content and ensure that disputed cases are reviewed by real qualified personnel — humans, not automated systems imitating “human” appeal review.
  2. Ensure full compliance with DSA Article 20 — i.e. guarantee that appeals are reviewed not by the same or similar automated system that issued the original decision, but by specialists with relevant qualifications. Templated automated responses to appeals must cease.
  3. Clearly distinguish in policy and enforcement:
    • genuine spam and fraud (user deception schemes, clickbait fraud, impersonation of others’ channels, phishing, etc.);
    • standard audience engagement elements (calls to subscribe, like, comment), which YouTube itself provides as part of the normal user experience and which cannot be qualified on equal footing with spam or fraud;
    • mass-produced template content without substantial authorial input;
    • reused content with minimal transformation;
    • original content with substantial authorial transformation;
    • content using AI as an auxiliary tool while preserving authorial intent.
  4. Establish and publicly disclose maximum terms for applied restrictions (basis: spam and scams). The current practice, under which a sanction is perceived as indefinite and the creator has neither a term for its end nor a mechanism for review, does not meet the principle of proportionality.
  5. Guarantee the right of appeal in all cases, including cases of YPP termination and channel blocking. Situations in which the interface explicitly informs the creator that no further action is possible contradict DSA Article 20 and P2B Regulation Article 11.
  6. Restore monetization following substantive human review in cases where such review does not confirm an actual policy violation.
  7. Disclose and regulate the fate of funds already earned by creators when sanctions are imposed:
    • confirm or deny the practice of withholding accumulated but unpaid funds;
    • if confirmed — provide verifiable information about the actual return of such funds to advertisers (broken down by period, e.g. 30/60/90 days), or pay these funds to the creator, since in the absence of an actual return to third parties, the withholding of funds by the intermediary objectively creates a situation of unjust enrichment.
  8. Separately regulate the fate of funds received via “Super Thanks” / “Super Chat” and other direct viewer payments. By their economic and legal nature, these funds are not the platform’s advertising revenue and should not be withheld by the platform when sanctions are imposed against the creator. The signatories ask either to pay such funds to the creator or to refund them to the viewer, but not to retain them with the platform.
  9. Disclose information about ad display on demonetized channels. If ads continue to be displayed on materials for which the creator has been denied monetization, this must be expressly indicated in the terms of service and in the individual notification to the creator, with disclosure of the economic consequences and grounds for such practice.
  10. Generally — transition to a transparent, reasoned, and human-oriented enforcement model consistent with the letter and spirit of the DSA and P2B Regulation, rather than imitating compliance with these requirements through formal automated procedures.

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