CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Snap DSA Report Risk Assessment Results and Mitigations 25 August 2025 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Foreword.................................................................................................................................................16 What is New?.......................................................................................................................................... 18 Previous reports.............................................................................................................................................. 18 What is new in this Report?.......................................................................................................................... 19 Section 1 - Introduction........................................................................................................................... 19 Section 2 - DSA Risk Assessment Scope.......................................................................................... 19 Section 3 - DSA Risk Assessment Methodology............................................................................20 Section 4 - DSA Risk Assessment Results....................................................................................... 20 Section 5 - Specific Mitigations........................................................................................................... 22 Section 6 - Ongoing Risk Detection \& Management.....................................................................23 Annex - Explainer Series....................................................................................................................... 24 Conclusion................................................................................................................................................ 24 1\. Introduction........................................................................................................................................25 1.1 Snapchat 1.01.............................................................................................................................................. 25 1.2 Critical Changes in Functionality......................................................................................................... 28 1.3 Snapchat Community..............................................................................................................................28 2\. DSA Risk Assessment Scope.......................................................................................................... 32 2.1 Approach.................................................................................................................................................... 32 Scope in our previous Reports............................................................................................................ 33 Scope for this Report..............................................................................................................................33 2.2 Spotlight.................................................................................................................................................... 34 2.3 Discover.....................................................................................................................................................35 2.4 Public Profiles...........................................................................................................................................36 2.5 Snap Map.................................................................................................................................................. 39 2.6 Lenses........................................................................................................................................................ 44 2.7 Advertising................................................................................................................................................ 46 3\. DSA Risk Assessment Methodology.............................................................................................. 47 3.1 Identification of Risks...............................................................................................................................47 3.2 Likelihood Analysis................................................................................................................................. 48 3.3 Severity Analysis..................................................................................................................................... 49 3.4 DSA Risk Factors.....................................................................................................................................50 3.5 Overall Potential Risk Prioritization Assessment............................................................................ 50 3.6 Snap's Mitigations.................................................................................................................................... 51 3.7 Conclusions...............................................................................................................................................52 3.8 Supporting Documentation.................................................................................................................. 53 4\. DSA Risk Assessment Results........................................................................................................ 54 4.1 Category 1 - Dissemination of content that is illegal or violates our terms and conditions.. 54 2 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 4.1.1 Dissemination of Child Sexual Abuse Material....................................................................... 56 Harm Description............................................................................................................................. 56 Likelihood...........................................................................................................................................57 Severity...............................................................................................................................................59 DSA Risk Factors............................................................................................................................. 60 Overall potential risk prioritization.............................................................................................. 63 Snap's Mitigations............................................................................................................................ 63 Conclusion.........................................................................................................................................66 4.1.2 Dissemination of illegal hate speech........................................................................................67 Harm Description............................................................................................................................. 67 Likelihood.......................................................................................................................................... 68 Severity...............................................................................................................................................69 DSA Risk Factors..............................................................................................................................70 Overall potential risk prioritization...............................................................................................72 Snap's Mitigations............................................................................................................................ 73 Conclusion......................................................................................................................................... 76 4.1.3 Dissemination of information related to the sale of prohibited products or services..76 Harm Description............................................................................................................................. 76 Likelihood........................................................................................................................................... 77 Severity............................................................................................................................................... 78 DSA Risk Factors..............................................................................................................................79 Overall potential risk prioritization.............................................................................................. 82 Snap's Mitigations............................................................................................................................ 83 Conclusion.........................................................................................................................................86 4.1.4 Dissemination of Terrorist Content............................................................................................86 Harm Description............................................................................................................................. 86 Likelihood...........................................................................................................................................87 Severity...............................................................................................................................................89 DSA Risk Factors..............................................................................................................................89 Overall potential risk prioritization.............................................................................................. 92 Snap's Mitigations............................................................................................................................92 Conclusion.........................................................................................................................................96 4.1.5 Dissemination of content that infringes on intellectual property rights.......................... 97 Likelihood...........................................................................................................................................97 Severity...............................................................................................................................................98 DSA Risk Factors..............................................................................................................................98 Overall potential risk prioritization.............................................................................................100 Snap's Mitigations........................................................................................................................... 101 Conclusion....................................................................................................................................... 103 3 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 4.1.6 Dissemination of Adult Sexual Content..................................................................................104 Harm Description............................................................................................................................104 Likelihood......................................................................................................................................... 104 Severity............................................................................................................................................. 106 DSA Risk Factors............................................................................................................................ 108 Overall potential risk prioritization..............................................................................................110 Snap's Mitigations........................................................................................................................... 110 Conclusion.........................................................................................................................................114 4.1.7 Dissemination of Content regarding Harassment and Bullying........................................ 115 Likelihood.......................................................................................................................................... 115 Severity...............................................................................................................................................117 DSA Risk Factors............................................................................................................................. 118 Overall potential risk prioritization.............................................................................................120 Snap’s Mitigations........................................................................................................................... 121 Conclusion........................................................................................................................................124 4.1.8 Dissemination of content that glorifies Self-Harm, including Suicide............................ 124 Harm Description............................................................................................................................124 Likelihood......................................................................................................................................... 125 Severity..............................................................................................................................................127 DSA Risk Factors............................................................................................................................ 127 Overall potential risk prioritization.............................................................................................130 Snap's Mitigations............................................................................................................................131 Conclusion........................................................................................................................................135 4.1.9 Dissemination of content relating to violent or dangerous behavior.............................136 Harm Description............................................................................................................................136 Likelihood......................................................................................................................................... 136 Severity............................................................................................................................................. 138 DSA Risk Factors............................................................................................................................ 139 Overall potential risk prioritization............................................................................................. 142 Snap's Mitigations...........................................................................................................................142 Conclusion........................................................................................................................................147 4.1.10 Dissemination of Harmful False Information........................................................................ 147 Harm Description............................................................................................................................ 147 Likelihood......................................................................................................................................... 148 Severity............................................................................................................................................. 149 DSA Risk Factors............................................................................................................................ 149 Overall potential risk prioritization.............................................................................................152 Snap's Mitigations.......................................................................................................................... 152 Conclusion....................................................................................................................................... 155 4 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 4.1.11 Dissemination of Fraud and Spam.......................................................................................... 155 Harm Description........................................................................................................................... 155 Likelihood......................................................................................................................................... 156 Severity............................................................................................................................................. 159 Overall potential risk prioritization.............................................................................................160 Snap's Mitigations.......................................................................................................................... 160 DSA Risk Factors............................................................................................................................ 167 Conclusion....................................................................................................................................... 169 4.1.12 Dissemination of information related to Other Illegal Activities..................................... 169 Harm Description............................................................................................................................170 Likelihood......................................................................................................................................... 170 Severity...............................................................................................................................................171 DSA Risk Factors............................................................................................................................. 171 Overall potential risk prioritization............................................................................................. 173 Snap's Mitigations...........................................................................................................................174 Conclusion........................................................................................................................................176 4.2 Category 2: Negative Effects on Fundamental EU Rights.......................................................... 177 4.2.1 Right to Human Dignity............................................................................................................... 178 Likelihood......................................................................................................................................... 179 Severity..............................................................................................................................................179 DSA Risk Factors............................................................................................................................ 180 Overall potential risk prioritization.............................................................................................180 Snap's Mitigations............................................................................................................................181 Conclusion........................................................................................................................................183 4.2.2 Right to Freedom of Expression and Assembly..................................................................184 Likelihood......................................................................................................................................... 184 Severity............................................................................................................................................. 185 DSA Risk Factors............................................................................................................................ 185 Overall potential risk prioritization............................................................................................. 188 Snap's Mitigations.......................................................................................................................... 188 Conclusion....................................................................................................................................... 192 4.2.3 Right to Private Life.................................................................................................................... 193 Likelihood......................................................................................................................................... 193 Severity............................................................................................................................................. 194 DSA Risk Factors............................................................................................................................ 194 Overall potential risk prioritization............................................................................................. 197 Snap's Mitigations...........................................................................................................................197 Conclusion...................................................................................................................................... 200 4.2.4 Right to Data Protection...........................................................................................................200 5 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Likelihood.........................................................................................................................................201 Severity............................................................................................................................................ 202 DSA Risk Factors........................................................................................................................... 203 Overall potential risk prioritization............................................................................................203 Snap's Mitigations......................................................................................................................... 203 Conclusion.......................................................................................................................................207 4.2.5 Right to Non-Discrimination and Freedom of Religion.................................................... 207 Likelihood........................................................................................................................................ 207 Severity............................................................................................................................................ 208 DSA Risk Factors...........................................................................................................................209 Overall potential risk prioritization............................................................................................209 Snap's Mitigations.......................................................................................................................... 210 Conclusion....................................................................................................................................... 216 4.2.6 Children’s Rights......................................................................................................................... 216 Likelihood......................................................................................................................................... 217 Severity..............................................................................................................................................217 DSA Risk Factors............................................................................................................................ 218 Overall potential risk......................................................................................................................218 Snap's Mitigations.......................................................................................................................... 218 Conclusion...................................................................................................................................... 222 4.2.7 Right to Consumer Protection.................................................................................................223 Likelihood........................................................................................................................................ 223 Severity............................................................................................................................................ 225 DSA Risk Factors........................................................................................................................... 226 Overall potential risk prioritization............................................................................................226 Snap's Mitigations..........................................................................................................................227 Conclusion...................................................................................................................................... 230 4.2.8 Right to Property........................................................................................................................ 230 4.3 Category 3: Negative effects on Public Security...........................................................................231 4.3.1 Negative Effects on Democratic and Electoral Processes................................................ 231 Likelihood........................................................................................................................................ 232 Severity............................................................................................................................................ 233 DSA Risk Factors........................................................................................................................... 233 Overall potential risk prioritization............................................................................................236 Snap's Mitigations......................................................................................................................... 236 Conclusion....................................................................................................................................... 251 4.3.2 Negative Effect on Civic Discourse........................................................................................251 Likelihood......................................................................................................................................... 251 Severity............................................................................................................................................ 252 6 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT DSA Risk Factors........................................................................................................................... 253 Overall potential risk prioritization............................................................................................253 Snap's Mitigations......................................................................................................................... 254 Conclusion...................................................................................................................................... 258 4.3.3. Negative Effect on Public Security....................................................................................... 258 Likelihood........................................................................................................................................259 Severity............................................................................................................................................ 259 DSA Risk Factors............................................................................................................................ 261 Overall potential risk prioritization.............................................................................................261 Snap's Mitigations......................................................................................................................... 262 Conclusion.......................................................................................................................................267 4.4 Category 4: Negative Effects on Public Health.............................................................................267 4.4.1 Negative Effects on Public Health.......................................................................................... 269 Likelihood........................................................................................................................................269 Severity............................................................................................................................................ 270 DSA Risk Factors........................................................................................................................... 270 Overall potential risk prioritization............................................................................................. 271 Snap's Mitigations...........................................................................................................................271 Conclusion.......................................................................................................................................275 4.4.2 Negative Effects on Gender-Based Violence.....................................................................275 Likelihood........................................................................................................................................ 275 Severity............................................................................................................................................ 276 DSA Risk Factors............................................................................................................................277 Overall potential risk prioritization............................................................................................ 277 Snap's Mitigations..........................................................................................................................278 Conclusion.......................................................................................................................................284 4.4.3 Negative Effects on Minors..................................................................................................... 284 Likelihood........................................................................................................................................286 Severity............................................................................................................................................ 288 DSA Risk Factors........................................................................................................................... 292 Overall potential risk prioritization............................................................................................294 Snap's Mitigations......................................................................................................................... 295 Conclusion.......................................................................................................................................304 4.4.4 Serious Negative Consequences on Physical and Mental Well-Being........................304 Likelihood........................................................................................................................................ 304 Severity.............................................................................................................................................. 311 DSA Risk Factors............................................................................................................................ 312 Overall potential risk prioritization............................................................................................. 312 Snap’s Mitigations...........................................................................................................................313 7 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Conclusion........................................................................................................................................318 5\. Specific Mitigations........................................................................................................................320 5.1 Snapchat Design and Function..........................................................................................................320 5.1.1 Introduction.................................................................................................................................... 320 5.1.2 Oversight and Administration.................................................................................................. 320 Roles and Responsibilities.......................................................................................................... 320 5.1.3 Adaptations and Mitigations......................................................................................................321 Friending, Chat and Private Stories........................................................................................... 321 Spotlight and Discover.................................................................................................................322 Spotlight....................................................................................................................................322 Discover.................................................................................................................................... 323 Public Profile................................................................................................................................... 323 Snap Map.........................................................................................................................................325 Lenses.............................................................................................................................................. 328 Advertising...................................................................................................................................... 328 5.1.4 Integrations with other mitigations......................................................................................... 328 Terms................................................................................................................................................ 328 Content Moderation......................................................................................................................328 Content Distribution......................................................................................................................328 5.1.5 Online Interface Design Process............................................................................................ 329 5.1.6 Conclusion......................................................................................................................................331 5.2 Terms....................................................................................................................................................... 332 5.2.1 Introduction...................................................................................................................................332 5.2.2 Oversight and Administration.................................................................................................332 Change Management...................................................................................................................332 Roles and Responsibilities...........................................................................................................334 5.2.3 Terms and Conditions............................................................................................................... 335 Terms of Service............................................................................................................................ 335 Community Guidelines.................................................................................................................339 Privacy Policy.................................................................................................................................. 344 Product Specific Terms................................................................................................................ 345 Advertising...................................................................................................................................... 345 5.2.4 Accessing Terms and Conditions.......................................................................................... 346 5.2.5 Support Site................................................................................................................................. 347 5.2.6 Languages................................................................................................................................... 348 5.2.7 Readability....................................................................................................................................348 5.2.8 Conclusion................................................................................................................................... 349 5.3 Transparency......................................................................................................................................... 349 5.3.1 Information we provide on our website................................................................................ 349 8 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Privacy, Safety, and Policy Hub..................................................................................................350 Policy Center....................................................................................................................................351 Privacy Center................................................................................................................................. 351 Safety Center..................................................................................................................................352 Parents............................................................................................................................................. 355 Transparency Center.................................................................................................................... 356 News Page...................................................................................................................................... 357 5.3.2 Information provided in app stores.......................................................................................358 5.3.3 Information we provide in our application...........................................................................359 Onboarding process.....................................................................................................................359 Just-in-time notifications..............................................................................................................363 Thematic awareness and notices............................................................................................. 366 5.3.4 Languages................................................................................................................................... 369 5.3.5 Conclusion...................................................................................................................................369 5.4 Content Moderation.............................................................................................................................369 5.4.1 Approach....................................................................................................................................... 369 Snapchat Design and Function..................................................................................................370 Community Guidelines and Terms of Service........................................................................ 370 Content Moderation......................................................................................................................370 Enforcement.....................................................................................................................................371 5.4.2 Oversight and Administration.................................................................................................. 371 Roles and Responsibilities............................................................................................................371 Human Content Moderators....................................................................................................... 372 Content Moderator Teams................................................................................................... 372 Selection of Moderators....................................................................................................... 374 Recruitment of Moderators.................................................................................................. 374 Content Moderator Processes............................................................................................ 374 Moderator Wellness as a Priority........................................................................................ 377 Automated Moderation................................................................................................................ 378 Training and Testing...............................................................................................................378 Quality Assurance.................................................................................................................. 378 Continuous Improvement.....................................................................................................379 5.4.3 Broadcast Content - Proactive Moderation.........................................................................379 Detection..........................................................................................................................................379 Proactive Safety Detection System...........................................................................................379 CSEAI................................................................................................................................................380 Abusive Language Detection.....................................................................................................380 Content Reviews.............................................................................................................................381 5.4.4 Product-Specific Moderation................................................................................................... 381 9 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Spotlight............................................................................................................................................381 Discover........................................................................................................................................... 382 Media Partnered Content............................................................................................................ 383 Public Profiles................................................................................................................................. 384 Snap Map.........................................................................................................................................385 Lenses.............................................................................................................................................. 386 Advertising.......................................................................................................................................387 5.4.5 Reactive Moderation (Reporting)........................................................................................... 389 Content-level in app reporting...................................................................................................389 Discover...........................................................................................................................................390 Snap Map........................................................................................................................................ 390 Lenses.............................................................................................................................................. 390 Messages..........................................................................................................................................391 Reporting on the web...................................................................................................................393 Account level in-app reporting.................................................................................................. 394 Illegal Content Notice (Art. 16)....................................................................................................398 5.4.6 Conclusion................................................................................................................................... 402 5.5 Enforcement.......................................................................................................................................... 402 5.5.1 Introduction...................................................................................................................................402 5.5.2 Review \& Enforcement.............................................................................................................402 Severe Harms.................................................................................................................................403 Strike System..................................................................................................................................403 Transparency.................................................................................................................................. 404 5.5.3 Notification of Criminal Offenses (Art. 18)............................................................................405 Proactive referrals to law enforcement and governmental agencies............................. 405 Law enforcement takedown and information requests (Articles 9 and 10)................... 405 Law enforcement orders to provide information (Article 10)............................................. 405 5.5.4 Notice and Appeals System....................................................................................................406 Notice to Reporter.........................................................................................................................406 Account-Level Notice and Appeals..........................................................................................408 Content-Level Notice and Appeals............................................................................................415 5.5.5 Effectiveness of Enforcement..................................................................................................419 5.5.6 Protections against Misuse (Art. 23)..................................................................................... 420 Suspending the Processing of Notices and Complaints.................................................... 420 5.5.7 Conclusion................................................................................................................................... 420 5.6 Algorithmic Systems............................................................................................................................. 421 5.6.1 Introduction....................................................................................................................................421 5.6.2 Content Recommendation Systems...................................................................................... 421 5.6.3 How do our Content Recommender Systems work?....................................................... 422 10 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Benefits............................................................................................................................................ 424 5.6.4 Adaptation of Snap Algorithmic Systems to Mitigate Systemic Risk............................424 Enabling user choice in content prioritization....................................................................... 424 5.6.5 Oversight and Administration.................................................................................................425 Roles and Responsibilities.......................................................................................................... 425 Algorithmic System Review........................................................................................................ 425 Documentation Standards.......................................................................................................... 426 5.6.6 Model Development and Deployment.................................................................................426 Development Guidelines.............................................................................................................426 Common Infrastructure................................................................................................................ 426 Pre-Launch Testing........................................................................................................................427 Pre-Launch Legal Review............................................................................................................ 427 5.6.7 Adaption and Testing.................................................................................................................427 Summary.......................................................................................................................................... 427 Illegal or violating content...........................................................................................................429 Lack of user understanding......................................................................................................... 431 Intrusive personalized recommendations................................................................................431 Discrimination.................................................................................................................................432 Rapid and Widespread illegal or false content \& crisis exposure.................................... 432 Filter bubbles..................................................................................................................................432 Erroneously excluding content.................................................................................................. 433 Viewers could be watching our content but not enjoying content.................................. 433 5.6.8 Change Management............................................................................................................... 435 5.6.9 Monitoring and Quality Assurance........................................................................................435 Performance Monitoring.............................................................................................................. 435 Quality Assurance......................................................................................................................... 435 5.6.10 Conclusion..................................................................................................................................435 5.7 Advertising Systems.............................................................................................................................436 5.7.1 Introduction....................................................................................................................................436 5.7.2 How do our Advertising Systems Work?.............................................................................. 436 5.7.3 Benefits.......................................................................................................................................... 437 5.7.4 Adaptation and Testing............................................................................................................. 439 Summary.......................................................................................................................................... 439 Invasion of Privacy – Reasonable and Proportionate Targeting........................................441 Special category data – No sensitive data use..................................................................... 442 Discrimination – Special Targeting Models............................................................................ 442 Harmful or illegal content – Advertising policies.................................................................. 442 Policy-violating or illegal content – Advertising Review..................................................... 443 Bypassing Moderation Controls – Advertising Reporting.................................................. 444 11 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Unclear Commercial Intent – Ad Markers...............................................................................444 Political ads – Transparency Safeguards................................................................................ 446 Personal Data Use for Targeting – User Choice................................................................... 447 Lack of visibility – Ads Gallery................................................................................................... 449 Freedom of Expression................................................................................................................452 5.7.5 Conclusion....................................................................................................................................452 5.8 Protection of Minors.............................................................................................................................453 5.8.1 Introduction...................................................................................................................................453 5.8.2 Administration and Oversight.................................................................................................453 Roles and Responsibilities.......................................................................................................... 453 5.8.3 Overview and Approach.......................................................................................................... 454 Age Appropriate Design Code.................................................................................................. 456 Privacy, Safety, and Security of Minors on Snapchat........................................................... 457 Advertisements for Minors..........................................................................................................458 Identifying Minors..........................................................................................................................458 Registration and access to Snapchat................................................................................458 Access to certain content / features.................................................................................. 461 Oversight.................................................................................................................................. 464 Ongoing evaluation............................................................................................................... 465 European Commission Art 28 DSA Guidelines..................................................................... 466 Transparency to Minors............................................................................................................... 470 5.8.4 Safeguards.................................................................................................................................... 471 App Store Level Safeguards........................................................................................................ 471 Device-Level Safeguards..............................................................................................................471 Platform-Level Safeguards.......................................................................................................... 473 Product-Level Safeguards........................................................................................................... 474 Lenses........................................................................................................................................474 Public Content......................................................................................................................... 475 Public Profiles.......................................................................................................................... 475 Creating Public Content........................................................................................................475 Viewing Public Content.........................................................................................................475 Discover.................................................................................................................................... 475 Spotlight.................................................................................................................................... 476 Snap Map..................................................................................................................................476 Advertisements....................................................................................................................... 477 Reporting and Blocking........................................................................................................ 479 Private Messaging..................................................................................................................480 Friending...................................................................................................................................480 Family Center / Parent Tools................................................................................................ 481 12 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 5.8.5 Conclusion...................................................................................................................................485 5.9 Content Authenticity............................................................................................................................486 5.9.1 Introduction...................................................................................................................................486 5.9.2 Risk Assessment Results......................................................................................................... 486 5.9.3 Mitigations.................................................................................................................................... 487 Guidelines, policies, and practices........................................................................................... 487 Creation............................................................................................................................................488 Dissemination.................................................................................................................................489 User Guidance on Generative AI features...............................................................................491 Enforcement....................................................................................................................................493 Partnerships.................................................................................................................................... 493 5.9.4 Conclusion................................................................................................................................... 495 5.10 Trusted Flaggers..................................................................................................................................495 5.10.1 Trusted Flagger Program......................................................................................................... 495 5.10.2 Onboarding a new trusted flagger.......................................................................................496 5.10.3 DSA Trusted Flaggers..............................................................................................................496 5.10.4 Trusted Flagger Program Trends..........................................................................................496 5.10.5 Conclusion..................................................................................................................................503 5.11 Dispute Settlement Bodies................................................................................................................503 5.11.1 Overview and Approach........................................................................................................... 503 5.11.2 Enquiries...................................................................................................................................... 504 5.11.3 Further considerations............................................................................................................. 504 5.11.4 Conclusion...................................................................................................................................505 5.12 Codes and Crisis Protocols.............................................................................................................. 505 5.12.1 Cooperation................................................................................................................................ 505 5.12.2 Codes of Practice..................................................................................................................... 507 EU hate speech Code..................................................................................................................508 FSM Code of Conduct................................................................................................................. 509 EU disinformation code............................................................................................................... 509 Article 28 DSA Guidance............................................................................................................. 510 5.12.3 Crisis Protocols.......................................................................................................................... 510 Crisis Protocol Case Study – October 7 and Israel-Hamas Conflict.................................. 511 6\. Ongoing Risk Detection and Management................................................................................. 514 6.1 Platform Principles-based Framework.............................................................................................. 514 6.2 DSA Compliance Team and Cross-Functional Working Groups...............................................515 6.2.1 Introduction....................................................................................................................................515 6.2.2 Roles and Responsibilities........................................................................................................516 6.2.3 DSA Independent Compliance Function..............................................................................516 6.2.4 Independent Compliance Function Collaboration............................................................. 517 13 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 6.2.5 Compliance Officer Designation............................................................................................ 518 6.2.6 Compliance Officer Qualifications..........................................................................................518 6.2.7 Operation of the Independent Compliance Function........................................................519 Responsibilities of the Independent Compliance Function................................................ 519 Oversight and Monitoring of Snap’s DSA Compliance........................................................ 519 DSA Management Body..............................................................................................................520 Organization of the Independent Compliance Function.................................................... 520 Independence Requirements.................................................................................................... 520 Communication of DSA Obligations to Snap Employees....................................................521 6.2.8 DSA Cross-Functional Governance Team............................................................................521 Responsibilities of the DSA Governance Team......................................................................521 6.2.9 Points of Contact....................................................................................................................... 522 Designation, Publication, and Change Management.......................................................... 522 Point of Contact for the Authorities.......................................................................................... 523 Point of Contact for Users...........................................................................................................523 Legal Representative....................................................................................................................524 6.2.10 DSA Supervisory Fee.............................................................................................................. 524 6.3 Privacy and Safety by Design............................................................................................................524 6.3.1 DSA Risk Management.............................................................................................................. 524 6.3.2 Privacy and Safety by Design review process...................................................................525 6.3.3 Holistic Digital Risk Management.......................................................................................... 527 6.3.4 Digital and Data Impact Assessment (DDIA) Template.................................................... 528 6.3.5 DSA Critical Impact Check...................................................................................................... 530 6.4 Prevalence Testing................................................................................................................................531 6.5 External Request Monitoring and Review......................................................................................540 6.6 Digital Well-Being Index (DWBI) Initiative........................................................................................541 6.7 Snap Advisory Groups.........................................................................................................................542 6.7.1 Safety Advisory Board............................................................................................................... 542 6.7.2 Snap Council for Digital Well-Being......................................................................................543 6.7.3 Regular External Engagement................................................................................................545 6.7.4 Dedicated DSA Risk Assessment Workshop..................................................................... 545 6.8 Audit.........................................................................................................................................................546 7\. Conclusion....................................................................................................................................... 547 8\. Final Words...................................................................................................................................... 551 Annex................................................................................................................................................... 552 Community Guidelines............................................................................................................................... 553 Overview.................................................................................................................................................553 Community Guidelines: Explainer Series.............................................................................................. 555 Sexual Content......................................................................................................................................555 14 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Threats, Violence \& Harm.................................................................................................................. 557 Hateful Content, Terrorism and Violent Extremism..................................................................... 559 Harassment and Bullying.................................................................................................................... 561 Illegal or Regulated Activities............................................................................................................563 Harmful False or Deceptive Practices............................................................................................ 565 Severe Harm..........................................................................................................................................568 Snapchat Moderation, Enforcement, and Appeals......................................................................568 15 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Foreword This Risk Assessment Results and Mitigations Report (Report) has been prepared to comply withSnap’s obligations under Article 42.4.(a), (b) and (e) of Regulation (EU) 2022/2065 on a SingleMarket For Digital Services and amending Directive 2000/31/EC (the “Digital Services Act” or“DSA”). This Report is divided into eight sections: (1) Introduction; (2) DSA Risk Assessment Scope; (3)DSA Risk Assessment Methodology; (4) DSA Risk Assessment Results; (5) Specific Mitigations; (6)Ongoing Risk Detection and Management; (7) Conclusion; and (8) Final Words. Since our 2024 Report, we have made a number of updates and these are summarized in a“What is New?” section that we have added to this Report. At a high level, these updates reflectthree themes that we have observed during the last year: ● European Commission’s Risk Assessment Recommendations: On 7 May, the Commissionheld a DSA Multi-Stakeholder Workshop on Systemic Risks. At the end of this Workshop,the Commission explained what it expected to see in the next reports from Very LargeOnline Platforms and Very Large Search Engines. We have assessed our Report againstthese recommendations as follows: Commission Request Covered inSnap’sReport? Enhancements in this Report? 1. Transparency: The reports need toprovide methodologies and coverall risks in the DSA. Yes None. We already include our methodologyand cover all risks in the DSA. 2. Design: The reports need to explainhow the design of the serviceimpacts risk, in addition to theimpact from the content itself. Yes Yes. Our reports already include extensiveanalysis of the design of our serviceand how this impacts our riskassessment. To make this clearer, thisyear we have included explicitreferences to the impact of the DSA’sspecific risk factors, including servicedesign, on each harm in Section 4. 3. Evidence: The reports must explainthe data and other evidence reliedon and explain how effectiveness isassessed. Yes None. Our reports already include data andother evidence to support theirconclusions and explain how 16 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT effectiveness is assessed. 4. Mitigations: The reports mustprovide sufficient descriptions of themitigations deployed and how theyimpact the assessment. Yes None. We already include extensivedescriptions of our mitigations in Section 5 (Mitigations) and explain howthese mitigations impact our riskassessment in Section 4 (RiskAssessment Results). 5. AI: The reports must assess theimpact and mitigations for AIcontent. Yes None. We already assess the impact of AIcontent in Section 4 (Risk AssessmentResults), particularly with respect to thedissemination of harmful falseinformation in Section 4.1.10. We providedetailed descriptions of our mitigationsfor AI content in Section 5.9 (ContentAuthenticity). 6. CSO Engagement: The reportsmust rely on available evidence.Must explain expert evidence reliedon and engagement with CSOs isexpected. Must take into accountfeedback on risk assessmentsprovided by CSOs. Yes Yes. Our previous reports already explainedthe research and other evidence werely on. This includes our regularengagement with Snap’s SafetyAdvisory Board, external Civil SocietyOrganisations and other experts. Thisyear, we also organised a dedicatedrisk assessment workshop with CSOs toobtain specific feedback on our riskassessment. In response to theirfeedback, amongst other things, wehave also included additional violativeview rate data to further evidence ourconclusions especially with respect tominors. See Section 3 (Methodology)and Section 4 (Risk AssessmentResults).See Section 6.7 (Snap AdvisoryGroups). ● Minors - This year has seen the publication of the European Commission’s Guidance onArticle 28 to ensure a high level of privacy, safety and security for minors. This guidance isthe result of extensive work from the Commission and other stakeholders. We have beenworking proactively to support the Commission’s efforts to introduce this guidance andstrongly support its goals. We are currently working to assess Snapchat’s in-scopeservices against the recommendations in the guidance. We have included a summary ofour initial assessment in Section 5.8 (Protection of Minors), and also referred to this 17 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT assessment in Sections 4.2.6 (Children’s Rights), 4.4.3 (Negative Effects on Minors) and5.12 (Codes and Crisis Protocols). ● Out of Court Dispute Settlement - This year has seen a significant increase in the numberof out of court settlements received by Snap. While the numbers are still very low,reflecting Snap’s effective terms, moderation and enforcement measures, responding tothese cases requires extensive resources. This is despite the fact that the majority ofcases are decided in Snap’s favour. We feel strongly that improvements must be made tohow out of court settlement works to ensure only valid and justified cases are broughtforward and costs are minimised. We consider this further in Section 5.11 (DisputeSettlement Bodies). As with last year, we look forward to continuing our constructive dialogue with Commission, ourDigital Service Coordinator and other stakeholders to further the objectives of the DSA, as well asencouraging continued close collaboration with regulators and other organisations covering theGeneral Data Protection Regulation, Audio Visual Media Services Directive and the DigitalMarkets Act to ensure a holistic approach to privacy, safety and security across these digitalplatform laws. What is New? Snap is required to complete a report every year setting out the results of its risk assessment anddetails of its mitigations pursuant to Article 42(4). Previous reports Snap has prepared two previous risk assessment and mitigation reports pursuant to Article 42(4): ● Our first report was completed in August 2023 (the “2023 Report”) and was published onSnap’s website here within 3 months of Snap having received its final auditors report forthe corresponding period (the “2023 Public Report”). ● Our second report was completed in August 2024 (the “2024 Report”) and was sent tothe Commission without undue delay as required by Article 42(4). Snap’s reports arepublished on its European Union Transparency page within 3 months of Snap havingreceived its final auditors report (as this includes an audit of Snap’s compliance with itsrisk and mitigation assessment and reporting obligations) pursuant to Article 42(4) i.e.approximately 1 year and 3 months after each report is completed. We are working topublish our second report, taking account feedback from civil society organisations on theextent of our redactions following our first dedicated DSA Risk Assessment Workshopearlier this year. 18 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT What is new in this Report? Section 1 - Introduction ● Snapchat 101 - ○ In all material respects, Snapchat’s in-scope services remain as described in ourprevious reports. Our data shows that the vast majority of our users are stillprimarily using the messaging aspects of our platform, and we continue to believethis is an important lens through which to view Snapchat. ○ We deployed one functionality that was considered likely to have a criticalimpact on the risks identified pursuant to Article 34 of the DSA. This was thelaunch of additional posting options for 16-17 years olds. This new functionalityunderwent extensive testing and evaluation, and presentation to the Commissionand other regulators, prior to launch. Our monitoring of key safety metrics showedthat the EU launch performed in line with expectations. ○ We chose not to launch the Simple Snapchat change that was flagged in our 2024Report. This was primarily a cosmetic change and was not expected to have anycritical impact on our risk assessment. ● Snapchat Community \- We continue to observe positive growth in our user base globally.In the European Union (“EU”) we grew to 93.7 million average monthly active recipients ofour Snapchat app (as at 1 January 2025). Our community demographics have not seenany significant changes since our previous reports. Section 2 - DSA Risk Assessment Scope ● Scope Assessment \- Since the 2024 Report: (i) our Snapchat designation has notchanged; (ii) the Commission has not issued any new guidance relating to scope and (ii)the functionality of Snapchat has not significantly changed. We have therefore confirmedthat Snap still considers the Spotlight, Discover, Public Profiles, Snap Map, Lenses, andAdvertising services of Snapchat to fall within the scope of our risk assessment andmitigation obligations in Articles 34 and 35. We have confirmed that Snap continues toconsider My AI and other similar generative AI tools made available by Snap to be out ofscope of Snapchat’s designation except for one advertising case identified below. ● In our short descriptions of the in-scope aspects of Spotlight, Discover, Public Profiles, Snap Map, Lenses, and Advertising services of Snapchat, we have noted the followingchanges since our previous report: 19 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ○ As previously communicated to the Commission, we have decided not to proceedwith the potential simplification of Spotlight and Discover tabs known as SimpleSnapchat. ○ We have updated our summary of Public Profiles features to incorporate the newpublic posting options available for 16-17 year olds. This new feature was subjectto extensive testing and evaluation, and was presented to the Commission andother regulators, prior to launch. Our monitoring of key safety metrics showed thatthe EU launch performed in line with expectations. We have provided more detailson the specific mitigations for this feature in Section 5. Section 3 - DSA Risk Assessment Methodology ● DSA Risk Assessment Methodology - ○ We have not made any material changes to our risk assessment methodologysince our 2024 Report. ○ We have added an additional paragraph to explain the inclusion of ‘violative viewrate’ (VVR) data as additional evidence of the likelihood of adult and minorrecipients of Snapchat’s in-scope services being exposed to illegal or otherwiseviolating content. This has been included to address civil society feedback in ourfirst Snapchat risk assessment workshop that organisations would like us toinclude more specific information on the extent to which users, especially minors,may be exposed to illegal or violative content disseminated on Snapchat. ○ We have also added an additional paragraph to explain how we have consideredthe specific risk factors set out in Article 34(2) of the DSA. Our previous reportsalready explained how these factors, such as the design of our recommendersystems, impact each harm and how increased risks, if any, have been addressed.In this Report, we have more explicitly set this out and included a dedicatedsub-section on DSA risk factors for each harm in Section 4. This has been includedto ensure that we meet a Commission recommendation to clearly demonstrate theDSA’s specific risk factors had been considered. Section 4 - DSA Risk Assessment Results ● We have updated the likelihood, severity, overall potential risk prioritization assessments,mitigation assessments. We have confirmed that there have been no changes to theconclusions we reached in our 2024 Report that we have reasonable, proportionate andeffective mitigation measures for each systemic risk identified in Article 34 of the DSA: ○ Category 1 - Dissemination of content that is illegal or violates our terms andconditions i.e. dissemination of CSAM, Illegal Hate Speech, Sale of ProhibitedGoods and Services, Terrorist Content, IP Infringement, Adult Sexual Content, 20 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Harassment and Bullying, Self-Harm and Suicide, Violent and DangerousBehaviour, Harmful False Information, Fraud and Spam, and Other Illegal Activities. ○ Category 2 - Negative Effects on Fundamental EU Rights i.e. Human Dignity, Freedom of Expression and Information, Private Life, Data Protection, Non-Discrimination and Freedom of Religion, Children’s Rights, ConsumerProtection and Property. ○ Category 3 - Negative Effects on Democratic and Electoral Processes, CivicDiscourse and Public Security. ○ Category 4 - Negative Effects on Public Health, Gender-Based Violence, Minors and Physical and Mental Well-Being. ● In line with updates to our Methodology (Section 3 above), we have included additionalinternal evidence (i.e. violative view rate data minors and adults) in response to feedbackfrom civil society organisations and more explicitly identified how we have assessed thespecific risk factors identified in Article 34 of the DSA in response to a Commissionrecommendation. ● We have seen a substantial reduction in prevalence rates across all of the illegal andother violating content categories that we monitor (see our update on prevalence testingbelow) and observed low violative view rates across all harm categories. Evidence of alow number of reports regarding violative ads also demonstrates the effectiveness of ourpre-publication ad review and rejection processes. As a result, we have been able tolower the relative likelihood of three of our risk categories from medium relative likelihoodto our lowest relative likelihood category: ○ Adult Sexual Content ○ Bullying \& Harassment ○ Fraud and Spam We had identified all three categories as a focus for our ongoing monitoring andmanagement of risk in the conclusion of our 2024 Report. We have noted that we willcontinue to monitor these categories, but are very pleased with the progress. ● We have added to our assessment concerning the dissemination of information relating tothe Sale of Prohibited Goods and Services to include information relating to vaping. Wehave been made aware of a particular issue in the Netherlands regarding the sale ofprohibited vaping products. This related to the private functionality of Snapchat which isout of scope of this Report. Nevertheless, we note that we had existing measures in placeto mitigate this risk and have made further improvements to better detect and takeenforcement action against accounts and content involved in this illegal activity. ● We have added a specific paragraph to reference to the new Article 28 Guidelines in ourassessment of the risk of Negative Effects on Minors. We cross-referred to Section 5.8 (Protection of Minors) where we have outlined our initial assessment of the 21 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT recommendations with respect to the in-scope services of Snapchat. We have continuedto conclude that Snapchat’s in-scope services have reasonable, proportionate andeffective measures to mitigate negative impacts on minors. ● General - We have also made a few more minor enhancements in response to feedbackfrom civil society organisations at our recent risk mitigation workshop: ○ We have updated the harm descriptions to provide additional clarity on the scopeof each risk category in Section 4. ○ We have also merged the ‘highlights’ paragraphs into the specific mitigations tableunder the ‘Snap’s mitigations’ heading for each harm in Section 4. This was doneto streamline the Report and make it easier for readers to locate thecorresponding detail we have provided about our specific mitigations in Section 5. Section 5 - Specific Mitigations ● Snapchat Design and Function \- We have not noted any significant changes to Snapchat’sDesign and Function mitigations. We have removed reference to Simple Snapchat as wedecided not to launch this change. We have also made adjustments to reflect the launchof additional public posting options for 16-17 year old accounts. ● Terms and Transparency \- We have not noted any significant changes to our terms ortransparency mitigations. ● Moderation and Enforcement \- We have not noted any significant changes to ourmoderation and enforcement mitigations. We have made some further adjustments tostreamline the information for easier presentation and efficiency reasons. ● Algorithmic Systems and Targeted Advertising \- We have provided some additionalinformation regarding algorithmic systems used for the personalization of Maps andLenses. We have also provided additional information regarding political advertising. ● Protection of Minors \- We have added a specific section on the new Article 28 Guidelines.In this section, we have provided a summary of our initial analysis comparing the in-scopeservices of Snapchat with the measures recommended in the Guidelines to ensure a highlevel of privacy, safety and security. We have continued to conclude that Snapchat’sin-scope services have reasonable, proportionate and effective measures to mitigatenegative impacts on minors, but continue to assess the Guidelines and monitor this areato determine if any changes are needed. ● Content Authenticity \- We have updated this section with further information relating toour transparency safeguards both in respect to the use of generative AI in content 22 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT creation (which we continue to consider to be out of scope of Snap’s designation (save forcertain commonplace ad creation tools) and are providing for context) and indissemination to the public on Snapchat’s inscope services. ● Trusted flaggers \- We have provided additional information regarding Snap’s trustedflagger program, as updating our statistics and trend analysis. ● Dispute Settlement Bodies - We have provided updates regarding our ongoingengagement with out-of-court settlement bodies. Although we are receiving relatively lownumbers of dispute settlement body escalations, these are still placing a significantburden on legal and operational teams. ● Codes and Crisis Protocols \- We have added a specific paragraph to refer to the newArticle 28 Guidelines. We have cross-referred to Section 5.8 (Protection of Minors) wherewe have outlined our initial assessment of the recommendations with respect to thein-scope services of Snapchat. Section 6 - Ongoing Risk Detection \& Management ● Platform Principles Framework and DSA Compliance Team and Cross-Functional WorkingGroups and Privacy and Safety by esign: There have been no significant updates tothese sections. We have provided some updated information regarding the DSACompliance Team. ● Prevalence Testing \- We continue to be extremely pleased with the progress we haveobserved from our prevalence testing over the last year. This demonstrates that theeffectiveness of our proactive detection mechanisms, agent training and other contentmoderation and enforcement efforts has continued to increase significantly since our2024 Report. In particular: ○ We have observed an additional significant decrease in our overall ‘PolicyViolating Prevalence’ (PVP) rate. ○ All violating content categories in the top ten have significantly reduced PVP rates. ○ All illegal or other violating content categories now fall within our lowest in ourlikelihood category 23 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT We also observed a moderate increase in the percentage of distinct violating Snaps. Thisis determined to be caused by Snap expanding its prevalence testing to cover new areas.Feedback from these new areas will result in further adjustments to the moderationsystems and we expect to see a gradual decrease in these levels in due course. ● External Request Monitoring and Review \- We have confirmed that we continue toproduce transparency reports and monitor content moderation and enforcement data,advertising review rejections, reporting and enforcements, ‘privacy, data protection andDSA’ requests and general community support requests. We continue to use this data tosupport the conclusions reached in this Report. ● Digital Well-Being Index (DWBI) Initiative \- We have updated this section to report on anevent we hosted on March 19, 2025 to share the latest findings from the DigitalWell-Being Index (DWBI), followed by an informal discussion with subject-matter experts. ● Snap Advisory Groups \- We have provided further information on the progress of our workwith the Snap Safety Advisory Board and Snap Council for Digital Well-Being. We havealso provided additional information on our external engagement with experts and civilsociety organizations. In particular, we have shared a report on our first dedicated DSARisk Assessment and Mitigation workshop in Brussels and online on July 10, 2024 and thesteps we have taken to address their feedback. ● Audit \- We have noted the completion of our second external DSA audit of Snap’scompliance with its obligations under Chapter 3 of the Digital Services Act for the auditperiod between 1 July 2024 and 30 June 2025 pursuant to Article 37. We have noted thatthe conclusion of the 2025 Audit Report is expected to indicate that Snap complied withall DSA obligations within the audit period. Annex - Explainer Series ● Annex - Explainer Series \- There have been a number of minor updates to our ExplainerSeries and the new versions are included. Conclusion ● Conclusion - We note that we have carried out a risk assessment of Snapchat’sin-scope services and continued to confirm that we have in place reasonable,proportionate and effective mitigation measures, tailored to the specific systemic risksidentified. We have also reflected on the progress with the areas for improvementidentified in our 2024 Report, as well as identifying new areas for improvement over thecoming year. 24 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Camera Snapchat opens into a camera, making it an easy and visual way for people to share what’s ontheir mind with the people that matter most to them. Snapchatters can Snap a quick video orphoto with our augmented reality Lenses to put fun and educational layers on the world, and getcreative by overlaying text, stickers, and more. Chat To the left of the Camera is Chat, where Snapchatters can talk with their friends and family usingtext and pictures. Chats will show when both friends are there at the same time. They’ll alsoindicate when a friend has opened and viewed a Snap. Snaps and Chats delete-by-default to mirror real life conversations, where what one says or doesisn't recorded forever and shared with a bunch of strangers. This helps people feel morecomfortable expressing themselves, the same way they would if they were just hanging out withfriends in person. While Chats and Snaps delete by default, Snapchatters do have the option tosave Chats – simply by tapping on the ones they want to save. In Chat, you can also make voice and video calls and join group conversations and chat with MyAI, our chatbot powered by OpenAI’s ChatGPT technology. Map Swipe to the left of Chat for the Map. Our Map is an interactive way for Snapchatters to sharetheir favorite spots, discover new places, and see what their friends are up to – but only if theychoose to share their location with their friends. Profile My Profile features a user’s Snapchat info, like their Bitmoji (which is an avatar representation ofthe user), location on the Map, friend info, and more. My Profile is also where Snapchatters canmanage their friendships, and report, block, or remove a friend. Public Profile Public Profiles enable Snapchatters to be discovered in the app. If Snapchatters want a PublicProfile, they will need to create one first. Once they have created a Public Profile, they canshowcase their favorite public Snaps and share Lenses and other information. Discover Swipe to the right of the Camera for Stories. Snapchatters can add Snaps to their Stories to sharemore of their day with friends and family, and scroll down to discover new Stories and contentabout the world — produced by trusted media publishers and popular creators. 27 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Spotlight Right next to Stories is our entertainment platform, Spotlight. This is where Snapchatters cansubmit and watch short, fun, and creative videos for our community. In Section 2 of this report we provide more details on the products and services that are in scopeof the DSA Risk Assessment. 1.2 Critical Changes in Functionality Since our 2024 Report, we have not deployed functionalities that were likely to have a criticalimpact on the risks identified pursuant to Article 34 of the DSA. However, as envisioned in theprior report, Snap introduced a change allowing older teenagers (ages 16–17) in the EU, EEA, andUK to access Public Profiles and public posting options. This enables them to create or update apublicly accessible profile, share Public Stories, and submit content for Spotlight. Before launch, Snap conducted a risk assessment and added mitigations. For example, PublicStories from 16–17 year olds are only shown to friends, followers, or mutual connections - not tothe wider community through Discover. Teens can receive Story replies but cannot start directchats from them, and replies are moderated more strictly for this age group. They can also turnoff replies or block certain terms, and all users retain easy reporting tools. Data from outside the European Union, where the feature was already available, suggests thesemeasures are effective. Consequently, Snap concludes that the residual risk of this change is low, with safeguardsproving effective in protecting older teenagers while allowing them access to public postingfeatures. 1.3 Snapchat Community We reach over 932 million3 monthly active users around the world, and we have over 469 million4 daily active users globally. We provide information on the average monthly active recipients of our Snapchat app, across theEU and per EU Member State, in our European Union transparency page on our website. 4 Snap Inc. public data Q2 2025, see https://investor.snap.com . 3 Snap Inc. public data Q2 2025, see https://investor.snap.com. 28 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 2\. DSA Risk Assessment Scope 2.1 Approach Articles 34 and 35 apply to Very Large Online Platforms designated by the EuropeanCommission. Snapchat was designated as a Very Large Online Platform by the Commission on25 April 2023 because the Average Monthly Active Recipients of Snapchat exceeds 45 million. The Commission Decision to designate Snapchat as a Very Large Online Platform states that itonly applies to services provided as part of Snapchat that meet the definition of online platformlaid down in Article 3, point (i), of Regulation (EU) 2022/2065. The designation does not apply toservices that are provided together with Snapchat, such as a private messaging service, and that,based on their technical functionalities, do not in themselves meet the definition of onlineplatform laid down in Article 3, point (i), of Regulation (EU) 2022/2065. Article 3.(i) of the DSA defines ‘online platform’ as: “a hosting service that, at the request of a recipient of the service, stores and disseminatesinformation to the public, unless that activity is a minor and purely ancillary feature of anotherservice or a minor functionality of the principal service and, for objective and technical reasons,cannot be used without that other service, and the integration of the feature or functionality intothe other service is not a means to circumvent the applicability of this Regulation”. Recital 14 explains that: “The concept of ‘dissemination to the public’, as used in this Regulation, should entail the makingavailable of information to a potentially unlimited number of persons, meaning making theinformation easily accessible to recipients of the service in general without further action by therecipient of the service providing the information being required, irrespective of whether thosepersons actually access the information in question. Accordingly, where access to information requires registration or admittance to a group ofrecipients of the service, that information should be considered to be disseminated to the publiconly where recipients of the service seeking to access the information are automaticallyregistered or admitted without a human decision or selection of whom to grant access.Interpersonal communication services, as defined in Directive (EU) 2018/1972 of the EuropeanParliament and of the Council (24), such as emails or private messaging services, fall outside thescope of the definition of online platforms as they are used for interpersonal communicationbetween a finite number of persons determined by the sender of the communication. However, the obligations set out in this Regulation for providers of online platforms may apply toservices that allow the making available of information to a potentially unlimited number ofrecipients, not determined by the sender of the communication, such as through public groups or 32 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT open channels. Information should be considered disseminated to the public within the meaningof this Regulation only where that dissemination occurs upon the direct request by the recipientof the service that provided the information.” Scope in our previous Reports Taking account of the above DSA definition and guidance, and that fact that Snapchatters areautomatically registered without a human decision or selection of whom to grant access, for ourprevious Reports, Snap considered the Spotlight, Discover, Lenses, Public Profiles, Snap Map,and Advertising services of Snapchat to fall within the scope of risk assessment and mitigationobligations in Articles 34 and 35. These services entailed making information published byrecipients of those services easily accessible to other recipients of Snapchat in general withoutfurther action by the recipients publishing the information in question. Scope for this Report For this Report, (i) the DSA definitions and guidance remain the same and (ii) the functionality ofSnapchat has not significantly changed and Snapchatters are still automatically registeredwithout a human decision or selection of whom to grant access. Therefore, Snap still considersthe Spotlight, Discover, Lenses, Public Profiles, Snap Map, and Advertising services ofSnapchat to fall within the scope of risk assessment and mitigation obligations in Articles 34and 35. These services still entail making information published by recipients of those serviceseasily accessible to other recipients of Snapchat in general without further action by therecipients publishing the information in question. When we refer to “Snapchat” or “Snapchat’s in-scope services” in this Report, therefore, we arereferring to those six services in Snapchat unless the context is clear that it is referring toSnapchat as a whole. As explained to the Commission in our response to its Gen AI RFI, we continue to assess My AI tobe out of scope of Snapchat’s designation as it concerned content creation rather thandissemination and was not system related to Snapchat’s inscope services. In particular, asconfirmed to the Commission in subsequent discussions, Snap does not use My AI data relatingto European Union users for advertising within Snapchat’s inscope services. Snap continues toconsider My AI and other similar generative AI tools made available by Snap to be out of scope ofSnapchat’s designation, except where identified otherwise in this Report. The six in scope services of Snapchat are described in more detail in the following sections. 33 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 2.2 Spotlight What is Spotlight? Spotlight is the Snapchat community’s destination for entertaining short-form video content.Launched in November 2020, Spotlight provides users a simple way to view short-form videoscreated and submitted by the Snapchat community via a personalized feed. All users can postvideos to Spotlight either via the Snapchat app or on the website, and videos on Spotlight arepublic and visible to users on the Snapchat app, on the web, and a link to the Spotlight video canbe shared to other platforms. Users can also add Comments to Spotlight videos, which gothrough moderation before being shown to the creator to either accept or reject, orauto-approve. If accepted or auto-approved, the Comment is publicly visible on the Spotlightvideo. Spotlight Comments may be deleted or reported, and viewers can also indicate fondnessby clicking on a heart icon. In addition to compliance with Spotlight Terms, users must also comply with the CommunityGuidelines and the Spotlight Guidelines. How does Spotlight work? Spotlight provides a content experience that is intended to entertain and delight users in thesame app they use to communicate with their friends and family. It offers creators at all stages oftheir career a variety of opportunities and tools to help them grow their audiences, buildsustainable businesses and make content creation a full-time career. Spotlight is an easy entrypoint to start your creator journey and is a source of relevant cultural trends and credible partnerto the industry (media, music, sports, fashion, etc.) that offers meaningful reach, relevance andrevenue. The content shown in Spotlight is personalized to provide the user with a more relevantexperience. Spotlight’s ranking algorithm is described here. Users may opt out of personalizationas described here. Spotlight content is moderated using a combination of auto-moderation andhuman moderation, and all Spotlight content is human moderated before being widelydistributed. Spotlight also uses various engagement and metadata to determine eligibility toreceive revenue from their content. Snapchat+ Features relevant to Spotlight None. As explained in Section 1 (Snapchat 1.01), we decided not to proceed with our plans tosimplify the application from 5 to 3 tabs (known as Simple Snapchat). 34 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Gen AI Features being used by Spotlight None. Snap recognises that content created by generative AI tools (whether on third partyplatforms or Snapchat) could be disseminated via Spotlight. Snap has taken this into account inthis Report, including explaining how this activity impacts our risk assessment and what measureswe have taken to address risks relating to the dissemination of content created by generative AI. 2.3 Discover What is Discover? Discover is part of the 4th tab in the Snapchat app, below your friends’ Stories. Note that thisproduct has at times been known as “For You” and any reference to For You that remains in thisReport or previous Reports should be interpreted as a reference to Discover. Discover is dedicated to Creator Stories, which includes Media Partner content, and some usergenerated content (“UGC”) created from Snaps by popular users (“Creator Content”). The UGCthat appears on Discover includes the Public Stories from Snap Stars and other users who meet afollower count threshold. The videos in Discover are accessible to all users including thosebetween 13-17 years old. How does Discover work? Discover displays personalized content to users. Discover achieves this using its rankingalgorithm, which is described here. The intended purpose of this processing is to personalizeDiscover and make it easy for users to discover new content that is relevant to their interests. Theintended effect/impact on users is that they enjoy what they are watching and remain engagedusers of Snapchat. Users may opt out of personalization as described here. Discover content is moderated using a combination of auto-moderation and human moderation,and all Discover content is human moderated before being widely distributed. Discover also generates information about how Snapchatters interact with the content inDiscover. It achieves this by generating ‘event’ metadata each time a user does somethingnoteworthy, like viewing or skipping a video. The intended purpose of this processing is to selectcontent the user is likely to be interested in, in order to further personalize content on Discoverand elsewhere in Snapchat (such as other content areas like Spotlight and also Advertising - therevenue from which is used to pay for Snapchat). The intended effect/impact on users is that theyenjoy their experience and remain engaged users of Snapchat. Snapchat+ Features relevant to Discover None. As explained in Section 1 (Snapchat 1.01), we decided not to proceed with our plans tosimplify the application from 5 to 3 tabs (known as Simple Snapchat). Gen AI Features being used by Discover 35 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT None. Snap recognises that content created by generative AI tools (whether on third partyplatforms or Snapchat) could be disseminated via Discover. Snap has taken this into account inthis Report, including explaining how this activity impacts our risk assessment and what measureswe have taken to address risks relating to the dissemination of content created by generative AI. 2.4 Public Profiles What are Public Profiles? Public Profiles enable Snapchatters to be discovered and followed in the app and showcase theirfavorite public Snaps, Lenses and other information. Snapchatters (including businesses) cancreate and access Public Profiles and grow an audience with their public identity. Public Profilesenables Snapchatters to showcase Stories, Spotlights and Lenses. For more information, see here. How do Public Profiles work? 36 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Snapchatter accounts aged 16 and over can choose to use a Public Profile to share a bit moreabout themselves with a wider audience (beyond their immediate friends) under their PublicProfile. To create a public profile an eligible Snapchatter is required to: (i) tap their Bitmoji or Storyicon at the top to go to My Profile; (ii) Scroll down to the 'Public Profile' section and Tap 'CreatePublic Profile' and (iii) then follow the simple instructions to create their Public Profile. We providea dedicated guide for teen accounts that is displayed before they can create a Public Profile. A Snapchatter can then choose to add information to their Public Profile, including a Photo, Bio,Description. Users can choose to display their Spotlight and Public Story content on their publicprofile. Users can also be followed by other Snapchatters. Lenses published by users can also bedisplayed on their Public Profile. They will be able to show their Follower Count and view PublicStory, Lens, and Audience Insights. Snapchatters with a Public Profile that are particularly active can have their accounts upgraded toa Creator Account. These have advanced features that are designed to enable professionalCreators to connect and grow with their audience. Creator Accounts are eligible to have theircontent shown in the Discover section of Snapchat. When older teenagers (16-17 accounts) first interact with their Public Profile page, post toSpotlight or Snap Map, or share a Public Story, they are shown a dedicated notice explainingwhat Public Profiles are and how to use them appropriately. This notice links to the support pages providing more information on Public Profiles. 37 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT As explained in Section 1 (Snapchat 101), before the launch of public profiles for older teens, Snapconducted a risk assessment and added mitigations. For example, Public Stories from 16–17 yearolds are only shown to friends, followers, or mutual connections - not to the wider communitythrough Discover. Teens can receive Story replies but cannot start direct chats from them, andreplies are moderated more strictly for this age group. They can also turn off replies or blockcertain terms, and all users retain easy reporting tools. Data from outside the EU, where the feature was already available, suggests these measures areeffective. All changes to Public Profiles undergo moderation, and only 0.01% of profiles failedchecks. For Public Stories, just 0.5% were rejected and 6% were subject to restrictions. Moreover,internal analysis shows no significant increase in contact risks for 16–17 year olds. They receiveroughly the same share of adult friend requests, show no rise in chat reports, and are not seeingpredatory patterns such as aggressive adult adds. Their connections’ median age and friendshipduration are consistent with those of peers without Public Profiles. Consequently, Snap concludes that the residual risk of this change is low, with safeguardsproving effective in protecting older teenagers while allowing them access to public postingfeatures. Snapchat+ Features relevant to Public Profiles None Gen AI Features being used by Public Profiles None 2.5 Snap Map What is Snap Map? Snap Map is designed to open up a world of possibilities for our community, enabling friends toexperience something new in the world every day. Through an interactive map interface, SnapMap shows users what’s happening nearby and around the world, anchored by the context offriends’ Bitmojis. It’s a personal map that starts with the user at the center and reflects the people,places, and activities they care about, and helps users meet up with friends, express themselves,find things to do, and explore places elsewhere. Snap Map has been developed with the privacyand safety of our community of Snapchatters in mind. How does Snap Map work? 38 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Snapchatters can share their Snaps to the Map by selecting “Snap Map” on the “Send To” page. Ifthe Snapchatter has a Public Profile or is sharing their My Story with everyone, they may alsohave their Snap shared on Snap Map when it's tagged to a place or venue. Snapchatters can alsochoose to share their location on the Map with friends while the Snapchat app is actively beingused, or share their live location with them even when the app is backgrounded. Location sharing is with Friends, rather than the public, and out of scope of Snapchat’sdesignation and this Report. Nevertheless, we have outlined safeguards we have implementedfor location sharing in the Mitigations section below (Sections 5.1 and 5.3 specifically). Snap Map features five types of user-generated content that can be served: 1. Map Stories include thumbnails on the map that highlight interesting events and popularplaces on the Map. 2. Place Stories appear on Place profiles. They contain Public Stories snaps explicitlytagged with the place, using either venue filters or place stickers. 39 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 3. City Stories appear in the header of the Map and display the best snaps in that localityfrom the last 7 days. They can appear in cities and neighborhoods. 40 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 4. The Heat Map is used to visualize the volume and recency of content that’s submitted toPublic Stories. Content up to seven days old can be accessed by the heatmap. Heat spotsrepresent areas where there is recent, high volume content. 5. Friend Stories tagged with Places presents a view of snaps that have been tagged withPlaces by a user’s friend, along with the Bitmoji of the friend, that would appear with thePlace on the basemap. This helps to personalize places on the user’s Map, highlightingthe places friends have recently visited. Snap Map submissions may be stored for a while and may be visible on Snapchat for longperiods of time as explained to Snapchatters in privacy notices. Snapchatters can remove a Snapthey submitted to Snap Map or place-tagged in Spotlight at any time via their profile. 41 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Snapchat+ Features relevant to Snap Map Customizations - Snap Map offers a couple of customization features for Snapchat+ usersincluding the ability to customize your home on the Map and adding your pet on the Map (eithervia a preselected group of pets or by creating a generative AI version of your pet). Footsteps - Snap Map also lets SC+ users see how much of the world they’ve explored. Thiscontent is only made available to the user, and we have assessed it to be out of scope ofSnapchat’s designation. 42 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Gen AI Features being used by Snap Map Gen AI Pet - Snap Map offers a Gen AI pet feature as described above. Note however that whilethis feature is integrated into the Snap Map, the content is only available to Friends with whomthe user chooses to share their location. It does not disseminate content to the broader public,and we have assessed it to be out of scope of Snapchat’s designation. Nevertheless we haveoutlined our approach to both Gen AI creation and dissemination in the Mitigations section (inparticular Section 5.9 (Content Authenticity)). 2.6 Lenses What are Lenses? Snapchat Lenses are augmented reality (“AR”) experiences designed to transform the way userslook and the world around them. Snapchatters frequently use Lenses for entertainment purposes, 43 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT for example by creating Snaps with added 3D effects, digital objects, characters, andtransformations to their image and voice. For example, Lenses can be used to add a layer ofmake-up to the user’s face, to distort the user’s face, to add a different background or certainelements to the surroundings. The most popular Lenses at the moment can be found here.Snapchatters can interact with Lenses in the Carousel, via Search, and via Lens Explorer. Inaddition, we offer advertisers the possibility of creating Sponsored Lenses. How do Lenses work? Lenses (in popular language often dubbed as ‘filters’) are created by a relatively limited numberof community developers, and Snap’s internal Lens Team. The transformational effects of Lensesare often accomplished through object detection, which is an algorithm designed to help acomputer generally understand what objects are in an image. For example, it lets us know that anose is a nose or an eye is an eye. There are numerous AR development tools Snap has madepublicly available through Lens Studio, Snaps’ Lens development platform and there are alsointernal tools that only the Lens Team can use to develop Lenses. Snap’s AR development toolsare reviewed by privacy engineering and legal before being used in Lenses. Some examples ofAR development tools are object detection, text to speech, location landmarks and ML modelsand algorithms to support AR effects like tools for depth and context understanding, all designedto help a computer generally understand what objects are in an image. We provide provided further information about how Lenses works in product specific supportpages: ● How to use lenses ● Create Your Own Filters \& Lenses • Snapchat Snapchatters can create or develop Lenses in the desktop application ‘Lens Studio’. There is aPublic version and an internal Snap version of Lens Studio. Lens developers may publish Lensesthrough ‘My Lenses’, a web based portal. Lenses built by Snap’s Lens Team are organic Lenses. Snapchat+ Features relevant to Lenses Certain Lenses are only available to Snapchat+ subscribers. Gen AI Features being used by Lenses Lens Studio features a GenAI Suite which lets developers take advantage of our generative AItechnology to create assets (such as text, effects and backgrounds) for Lenses. Note howeverthat Lens studio is only a creation tool. It does not disseminate content to the broader public, andwe have assessed it to be out of scope of Snapchat’s designation. Nevertheless we haveoutlined our approach to both Gen AI creation and dissemination in the Mitigations section (inparticular Section 5.9 (Content Authenticity)). 44 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 2.7 Advertising What is Snap’s Advertising product? Snap relies on online advertising to support its business. Snap has digital ad products created foradvertisers who would like to easily create and manage ads that target relevant audiences onSnapchat (“Snapchat Ads Manager”). We process user information about Snapchatters to servethem with ads within Snapchat that we think they might be interested in. An overview of Snap’s ads services can be found here and here. Some of Snap’s advertisingtools allow advertisers to provide Snap with data about their customers to improve theiradvertising campaigns. These tools are explained here: ● Custom List Audiences ● Snap Pixel ● Conversion API ● Advanced and Estimated Conversion In addition, we offer advertisers the possibility of creating Sponsored Lenses. How does Advertising Work? Our ad ranking algorithm determines which ads are displayed to a Snapchatter who is in theselected audience for those ads. The ad ranking algorithm uses various signals, including prior adinteractions and social signals, to determine which ads that user is more likely to interact with andthen combines this with the results of advertiser ad action for that Snapchatter, to select an ad todisplay. Snap analyzes prior ad interactions to target advertisements. For example, we maydetermine that a user is likely to swipe up on certain types of ads or download certain types ofgames when they see an ad on Snapchat. We may then use this information to show that usersimilar ads. Snapchatter interactions with the ad (i.e. impression data) is then logged to (a) attributeimpressions to conversion events (such as a purchase on an advertiser website or download ofan advertiser app) to demonstrate the performance of the ad and (b) to further train the adranking algorithm. Snapchat+ Features relevant to Advertising None Gen AI Features being used by Advertising Advertisers can take advantage of generative AI tools during ad creation (such as texttranslations and background image creation). These are in systems directly related to thedissemination of content (advertising) to the public on Snapchat (although they are common toolsand minor in nature). We have taken the use of generative AI tools into account in this Report (inparticular Section 4.3.1 (Democracy/Elections) and Section 5.9 (Content Authenticity)). 45 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 3\. DSA Risk Assessment Methodology Update: There have been no major changes to our risk assessment methodology since our 2023and 2024 Reports. In this Report, Snap has enhanced its approach by incorporating additionalinternal evidence, specifically ‘violative view rate’ data, and more explicitly specifying how Snaphas taken into account the specific risk factors references in Article 34 of the DSA. In order to meet its obligations under Articles 34 and 35 of the DSA, Snap has applied a standardrisk methodology adapted from that commonly used to assess risks in other contexts, includingthe EU general risk assessment methodology for product safety7 and the ICO’s DPIA guidelines.Ofcom’s guidance for completion of the illegal harms risk assessment and protection of childrenrisk assessments under the UK Online Safety Act proposed a similar methodology in its riskassessment guidance documents.8 The risk assessment methodology used by Snap has several steps: 3.1 Identification of Risks As a first step, Snap identified potential systemic risks for each of the four categories outlined inthe DSA:a. Category 1 (Article 34.1.(a) / DSA Recital 80): Dissemination of illegal or violating content,particularly rapidly and widely or as a result of intentional / automated manipulation,including:i. Child sexual abuse materialii. Illegal hate speechiii. Criminal offenses and the conduct of illegal activities, such as the sale ofprohibited products or services, dangerous or counterfeit products, orillegally-traded animals.b. Category 2 (Article 34.1.(b) / DSA Recital 81): Impact on fundamental EU rights, includingin particular rights for:i. Human dignityii. Freedom of expression and of information, including media freedom and pluralismiii. Private lifeiv. Data protectionv. Non-discriminationvi. Childrenvii. Consumer protectionc. Category 3 (Article 34.1.(a) / DSA Recital 82): Negative effects on:i. Democratic and electoral processes 8 Illegal Harms Risk Assessment Guidance (url) and Protection of Children Risk Assessment Guidance (url), Ofcom. 7 EU general risk assessment methodology (Action 5 of Multi-Annual Action Plan for the surveillance of products in theEU (COM(2013)76)), url. 46 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ii. Civic discourseiii. Public securityd. Category 4 (Article 34.1.(a) / DSA Recital 83): Negative effects, in particular from designand use/misuse such as a coordinated disinformation campaign, on:i. Public healthii. Gender-based violenceiii. Minorsiv. Physical and mental well-being (including addictions) 3.2 Likelihood Analysis As a second step, Snap analyzed the extent to which the identified risk(s) are likely to occur onSnapchat. In practice the prevalence of almost all of Snapchat’s risks are considered to be verylow, in part because of robust mitigations and the inherent design of relevant Snapchatfunctionality, so Snap used a measure of relative likelihood between each risk on Snapchat sowe can continue to prioritize and improve (as explained in the following table). Note: this is notmeasuring likelihood relative to other platforms; it is measuring likelihood relative to risksassessed by Snap.With this in mind, Snap used three levels of relative likelihood: Relative likelihood of riskoccurring on Snapchat Description Low Likelihood This means this risk has the highest chance of occurring on Snapchat vsother risks: ● where Prevalence Testing data is available, this risk has apercent of policy-violating prevalence (PVP) of 0.5% or greater;and ● where VVR data is available, the violative view rate is 0.005 orgreater. Very Low Likelihood This means this risk has an average chance of occurring on Snapchat vsother risks: ● where Prevalence Testing data is available, this risk has apercent of policy-violating prevalence (PVP) of between 0.05%and 0.49%; and ● where VVR data is available, the violative view rate is between0.005 and 0.0049. Extremely Low Likelihood This means this risk has the lowest chance of occurring on Snapchat vsother risks: ● where Prevalence Testing data is available, this risk has apercent of policy-violating prevalence (PVP) of 0.049% or less;and ● where VVR data is available, the violative view rate is 0.00049or less 47 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT In order to assess likelihood, Snap uses a mix of internal information (such as Prevalence Testing data or illegal / violating content reporting data or complaint data, input from our safety advisoryboard and Snap commissioned research as well as VVR data) and external information (such asexternal research, news reports and government and NGO guidance). Where internal informationis required, this was obtained from the relevant teams responsible for maintaining thatinformation (for example, Customer \& Review Operations with respect to complaint data). 3.3 Severity Analysis As a third step, Snap analyzed the severity of the identified risk(s) by considering evidence of thepotential harm they have caused individuals or society in general. In practice the severity of allthe identified risks could cause at least significant harm (which is why they have beenidentified). So we used a measure of relative severity between each risk so it can continue toprioritize and improve. With this in mind, Snap used three levels of severity: Harm classificationindustry wide Description Severe harm industrywide This means this risk has the highest severity vs other risks. We considersevere harm to include both (1) harms that risk significant damage to thephysical or emotional well-being of Snapchatters and society at large e.g.external parties influenced by (other people’s use of) Snapchat, and (2) theimminent, credible risk of severe harm, including threats to human life, safety,and well-being. Serious harm industrywide This risk has a medium level of severity vs other risks. We consider theserisks not to be severe (as defined above) but still have the potential to causeserious harm. Significant harm industrywide This means this risk has the lowest severity vs other risks. While not the mostsevere or serious, these risks still have the potential to cause significantharm. The safety of Snapchatters is our top priority. We take behavior that threatens the safety of ourcommunity very seriously. We collaborate with experts, safety groups, and law enforcement onthese topics in order to better educate ourselves and our community, and to ensure we aresufficiently informed to analyze different levels of severity for each risk. 48 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 3.4 DSA Risk Factors Snap has also taken into account whether and how the following service risk factors referencedin Article 34(2) of the DSA influence the risk of each harm on Snapchat’s in-scope services: Service Risk Factor (a) the design of recommender systems and any other relevant algorithmic system; (b) content moderation systems; (c) the applicable terms and conditions and enforcement; (d) systems for selecting and presenting advertisements; and (e) our data related practices. We have also analysed whether and how the risk of each harm category is influenced by thefollowing general factors: General Risk Factor Intentional manipulation, including inauthentic use or inauthentic use or automated exploitation of theservice. Amplification and potentially rapid and wide dissemination of illegal content and of information that isincompatible with their terms and conditions. Specific regional or linguistic aspects, including when specific to a Member State. 3.5 Overall Potential Risk Prioritization Assessment As a fourth step, Snap confirmed an overall potential risk prioritization for each identified risktaking account of the likelihood and severity analysis outlined above. This prioritization helps usto assess whether the mitigations we have put in place (as described in Snap's Mitigations) areproportionate, reasonable and effective as required by Article 35. As a guide we use thefollowing matrix that is commonly used in risk assessment methodologies to determine theoverall potential risk. However, this is only an approximation and we make a decision on theoverall potential risk, and therefore the prioritization, of a particular issue on a case by case basis.As a result, there are instances where we deviated from the overall potential risk prioritizationmatrix below. Overall Potential Risk Prioritization Matrix 49 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Harmclassificationindustrywide Severe harmindustry wide Level 3 Level 1 Level 1 Serious harmindustry wide Level 3 Level 2 Level 1 Significant harmindustry wide Level 3 Level 3 Level 2 Extremely low Very low Low Relative likelihood of risk occurring on Snapchat 3.6 Snap's Mitigations As a fifth step, Snap considered the mitigation measures that it has taken to address each of therisks identified in the overall potential risk prioritization assessment. When considering thesemitigations, Snap has taken into account in particular the list of possible mitigations set out inArticle 35.1. For ease of reference, we have set out a table below that maps the Article 35.1 list ofmitigations to the corresponding section of this report where Snap has explained how it is usingthat mitigation measure on Snapchat. # DSA Mitigation Relevant Report Section a Adapting the design, features or functioning of their services,including their online interfaces. Snapchat Design andFunction b Adapting their terms and conditions and their enforcement. Terms and Enforcement c Adapting content moderation processes, including the speed andquality of processing notices related to specific types of illegalcontent and, where appropriate, the expeditious removal of, or thedisabling of access to, the content notified, in particular in respect ofillegal hate speech or cyber violence, as well as adapting anyrelevant decision-making processes and dedicated resources forcontent moderation. Moderation d Testing and adapting their algorithmic systems, including theirrecommender systems. Algorithmic Systems e Adapting their advertising systems and adopting targeted measuresaimed at limiting or adjusting the presentation of advertisements inassociation with the service they provide. Advertising Systems 50 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT f Reinforcing the internal processes, resources, testing,documentation, or supervision of any of their activities in particularas regards detection of systemic risk. Ongoing Risk Detectionand Management g Initiating or adjusting cooperation with trusted flaggers inaccordance with Article 22 and the implementation of the decisionsof out-of-court dispute settlement bodies pursuant to Article 21. Trusted Flaggers h Initiating or adjusting cooperation with other providers of onlineplatforms or of online search engines through the codes of conductand the crisis protocols referred to in Articles 45 and 48respectively. Codes and Crisis Protocols i Taking awareness-raising measures and adapting their onlineinterface in order to give recipients of the service more information. Transparency j Taking targeted measures to protect the rights of the child, includingage verification and parental control tools, tools aimed at helpingminors signal abuse or obtain support, as appropriate; Protection of Minors k Ensuring that an item of information, whether it constitutes agenerated or manipulated image, audio or video that appreciablyresembles existing persons, objects, places or other entities orevents and falsely appears to a person to be authentic or truthful isdistinguishable through prominent markings when presented ontheir online interfaces, and, in addition, providing an easy to usefunctionality which enables recipients of the service to indicate suchinformation. Content Authenticity 3.7 Conclusions As a final step, Snap confirmed whether the mitigation measures it has taken were reasonable,proportionate and effective for each risk identified. To determine this, Snap considered if themitigations it has in place were effective to address the risk, given its overall potential riskprioritization category, by considering available evidence from its Prevalence Testing data, VVRdata or illegal / violating content reporting data or complaint data, input from our safety advisoryboard and Snap commissioned research) and external information (such as external research,news reports and government and NGO guidance). Where there was evidence that the existing measures risks may need some improvement toensure reasonable, proportionate and effective measures had been taken, Snap identified this inits conclusion and explained what steps it would be taking to achieve the improvement. 51 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 3.8 Supporting Documentation The data and documentation supporting the risk and mitigation assessment report is retained fora minimum of 3 years. 52 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 4\. DSA Risk Assessment Results In this Section of the Report, we explain the result of the risk assessment of Snapchat’s in-scopeservices that Snap has carried out pursuant to Article 34 of the DSA. This risk assessment wasconducted in accordance with the scope and methodology explained in Section 1 of this Report.One general point to note is that these risks impact a wide range of individuals, including ourSnapchatter community, victims of crime, the general public and the moderators that review thecontent on Snapchat. The results of this risk assessment apply to all such individuals, and whereappropriate we have noted impacts that extend beyond Snapchat (including the wellness of ourmoderators). It is Snap’s mission to reduce virtually all harmful content on our platform. To that end, we arecontinually improving our systems every single day, and are investing into (machine learning)technology, human moderation, and other measures to make our platform safer for ourcommunity. As described in the Ongoing Risk Management section below, Snap has reasonable,proportionate and effective measures to detect and manage risks on an ongoing basis. 4.1 Category 1 - Dissemination of content that is illegal or violatesour terms and conditions (Article 34.1.a / DSA Recital 80) In this first part we report on our assessment of the risk of illegal content or content that isincompatible with our Terms being disseminated on Snapchat as required by Article 34.1.a(“Category 1”), including in particular the illegal content identified in Recital 80. In our assessment,we have taken account of the extent to which these risks are influenced by intentionalmanipulation, including by inauthentic use or exploitation of the service, as well as the extent towhich Snapchat allows for amplification and potentially rapid and wide dissemination. The table below provides a summary of the results of our assessment of likelihood, severity andoverall potential risk prioritization, together with our conclusions given the mitigations that Snaphas put in place for each Category 1 risk. Note that for all harms, where there is (1) a risk ofsignificant damage to the physical or emotional well-being of Snapchatters, and (2) imminent,credible risk of severe harm, including threats to human life, safety, and well-being, we treat thisas a severe harm and an Level 1 overall risk prioritization. 53 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Category 1 - Dissemination of content that is illegal or violates our terms and conditions (including ourCommunity Guidelines) Category Relativelikelihoodof riskoccurringonSnapchat Harmclassificationindustry wide RiskPrioritization Conclusion 4.1.1 Dissemination of Child SexualAbuse Material ExtremelylowLikelihood Severe harmindustry wide Level 1 Low Risk /Reasonable,proportionate andeffective mitigations 4.1.2 Dissemination of Illegal HateSpeech ExtremelylowLikelihood Significantharm industrywide Level 3 Low Risk /Reasonable,proportionate andeffective mitigations 4.1.3 Dissemination of informationrelated to the Sale of ProhibitedProducts or Services (such asdangerous products, counterfeitproducts or illegally-tradedanimals) ExtremelylowLikelihood Severe harmindustry wide(Drugs) Level 1 (Drugs) Low Risk /Reasonable,proportionate andeffective mitigations ExtremelylowLikelihood Serious harmindustry wide(Weapons) Level 2(Weapons) Low Risk /Reasonable,proportionate andeffective mitigations ExtremelylowLikelihood Significantharm industrywide (Othergoods) Level 3 (Othergoods) Low Risk /Reasonable,proportionate andeffective mitigations 4.1.4 Dissemination of TerroristContent ExtremelylowLikelihood Serious harmindustry wide Level 2 Low Risk /Reasonable,proportionate andeffective mitigations,which are beingclosely monitoreddue to a further slightincrease inprevalence. 4.1.5 Dissemination of Contentthat infringes on IntellectualProperty Rights ExtremelylowLikelihood Significantharm industrywide Level 3 Low Risk /Reasonable,proportionate andeffective mitigations 4.1.6 Dissemination of AdultSexual Content Extremelylow Serious harmindustry wide Level 2(Sexual crimes) Low Risk /Reasonable, 54 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Likelihood (Sexualcrimes) proportionate andeffective mitigations Significantharm industrywide (OtherAdult SexualContent) Level 3 (OtherAdult SexualContent) Reasonable,proportionate andeffective mitigations,which are beingmonitored to confirmprevalence continuesto decline. 4.1.7 Dissemination of contentregarding Harassment andBullying ExtremelylowLikelihood Serious harmindustry wide Level 2 Low Risk /Reasonable,proportionate andeffective mitigations. 4.1.8 Dissemination of contentthat glorifies Self-Harm, includingthe promotion of Self-Injury,Suicide or Eating Disorders ExtremelylowLikelihood Serious harmindustry wide Level 2 Low Risk /Reasonable,proportionate andeffective mitigations 4.19 Dissemination of contentencouraging or engaging inviolent or dangerous behavior ExtremelylowLikelihood Significantharm industrywide Level 3 Low Risk /Reasonable,proportionate andeffective mitigations 4.1.10 Dissemination of HarmfulFalse Misinformation ExtremelylowLikelihood Significantharm industrywide Level 3 Low Risk /Reasonable,proportionate andeffective mitigations 4.1.11 Dissemination of Fraud andSpam ExtremelylowLikelihood Significantharm industrywide Level 3 Low Risk /Reasonable,proportionate andeffective mitigations. 4.1.12 Dissemination ofinformation related to OtherIllegal Activities ExtremelylowLikelihood Significantharm industrywide Level 3 Low Risk /Reasonable,proportionate andeffective mitigations 4.1.1 Dissemination of Child Sexual Abuse Material This Section 4.1.1 (CSEA) considers the risk of harm arising from child sexual exploitation andabuse (as described in the Harm Description below) on Snapchat’s in-scope services. Harm Description CSEA refers to content and activity involving taking advantage of a vulnerability, trust, or animbalance of power to coerce, manipulate or deceive a minor (i.e. a person under the age of 18) 55 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT into sexual activity or any activity for the sexual gratification of another, online or in person,including grooming and dissemination of child sexual abuse material (“CSAM”): ● Grooming refers to building trust, establishing a relationship, and developing anemotional connection with a minor in order to manipulate, exploit, and/or abuse them.This includes any communication or behavior that attempts to persuade or coerce a minorwith the intent of sexual abuse or exploitation, or which leverages fear or shame to keep aminor silent. ● CSAM includes still images, videos, and illustrated, computer-generated or other forms ofrealistic depictions, as well as live streaming broadcasts of a child in a sexually explicitcontext, or engaging in sexually explicit acts. CSEA may involve the generation,possession, distribution, promotion, or solicitation of such material, including both ‘knownCSAM’ (previously hashed and catalogued by organisations like NCMEC), and ‘newCSAM’ (not previously hashed or catalogued), whether authentic or AI-generated. It mayalso involve the sharing or promotion of hyperlinks that direct users to CSAM hostedoff-platform. These URLs may lead to: ○ Known CSAM-hosting sites or darknet marketplaces; ○ Cloud drives, encrypted messaging channels, or file dumps; or ○ Evasion techniques (e.g., obfuscated links, shorteners). ● CSEA may also include: ○ Accounts dedicated to sexually harassing, intimidating or extorting minors; ○ Teens or adults requesting/encouraging/enticing/coercing minors to engage insexual acts or produce sexual images; ○ Content that facilitates a sex act with a minor; ○ Content that promotes the sale of commercial sex with a minor; and ○ Any threats to share, exploit, or expose a minor’s intimate images or videoswithout their consent (i.e., sextortion), whether by an adult or a fellow minor. We provide a summary and explanation of ‘CSEA’ in our explainer on Sexual Content and our Transparency Report Glossary. Note that we also prohibit content that, while not reaching the level of CSEA, includes minors inan inappropriate manner. This may include images of naked minors absent any sexually explicitcontext or sexual suggestiveness, such as nude babies or toddlers playing in bathtubs orswimming pools or minors engaged in sexually suggestive behaviour. Likelihood We have considered the likelihood of this harm in line with Section 3 (Methodology) andobserved the following for 2025: 56 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ● In order to better understand how we might combat this harm, Snapbegan efforts to measure Policy Violating Prevalence (PVP) via random sampling of PublicStories to estimate the percent of policy-violating views.9 ○ ○ In our 2023 Report, we noted that CSEAI content represented an extremely lowpercentage of total views found to be violating,We also noted that in the second half of 2022, the proactive moderation detectedand actioned 94% of the total child sexual exploitation and abuse violationsreported in our Transparency Reports. ○ By 30 July 2024 and as a result of our continued focus, the percentage of CSEAIviolating views saw a further, substantial fall to an extremely low rate: The steps Snap took to mitigate this risk diminished the likelihood thatSnapchatters would encounter CSEAI on Snapchat’s in-scope services, such thatCSEAI has dropped out of the top 10 harm list entirely. ○ As of 30 April 2025, we have successfully maintained this extremely lowprevalence rate on Snapchat’s in-scope services in 2025, ● Where CSEA content was identified (either proactively via automated tools or reactivelyfollowing a report), our median turnaround time was rapid. Our latest European UnionTransparency Report, which covers the second half of 2024, observed a medianturnaround time for our Safety teams to take enforcement action in response to proactiveor reactive detections of CSEA content of 322 minutes10. ● As a result of this rapid turnaround time: ○ the violative view rate for EU users for CSEA content across the followingSnapchat in-scope services is very low in the first half of 2025: ○ the violative view rate for EU minors for CSEA content across the followingSnapchat in-scope services is also very low in the first half of 2025: 10 Our CSEA turnaround time is higher than in other policy areas because some CSEA content is subject to aspecialized process that includes double-review with a select team of specially trained agents. This does not apply todetected CSEA content matching hashes of known, verified CSEA material, which will be actioned more swiftly. 9 See Section 6.4 (Prevalence Testing). 57 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ● In February 2024 by prominent Finnish NGO Protect Children published a study on theuse of tech platforms by online child sexual abuse offenders, funded by the Tech Coalitionand Safe Online.11 Snapchat ranks last among the social media platforms used to search,view, and share CSAM (10%), compared to Instagram (29%), Twitter/X (26%), Discord (23%),TikTok (21%), Facebook (20%), Youtube (18%), Reddit (17%). ● Although Snap is aware of concerns regarding the dissemination of CSEAI created usinggenerative AI tools in the wider industry, Snap has not identified this as being a materialissue on Snapchat’s in-scope services. As a result, Snap continues to place CSEAI into the lowest likelihood category. Severity For this Report, as in our previous Reports, Snap still considers all CSEAI to have a risk of severeharm. This includes sexual images of minors aged 13-17 and grooming activities (e.g. enticing aTeen to produce sexual images). There is still no doubt that child sexual exploitation and abuse isone of the most serious crimes which violates Children’s Rights and has far-reaching and seriousdetrimental lifelong consequences for its victims.12 As well as the obvious severe harm caused byCSEAI, the distribution of images online has been found to cause ongoing harm. A study led bythe Canadian Centre for Child Protection in 201713, noted that 67% of CSAM survivors said thedistribution of their images impacts them differently than the hands-on abuse they sufferedbecause the distribution never ends and the images are permanent. InHope notes14 that childrenwho have been victimised and experienced grooming are likely to suffer from serious long-termmental health issues such as anxiety, depression, post-traumatic stress, and suicidal thoughts.Especially children who have been solicited into creating and sharing intimate content ofthemselves tend to experience shame and blame themselves for the abuse, regardless ofwhether the abuse took place offline or if all interaction between the perpetrator and child tookplace online. Children can be seriously impacted by grooming even when no personal contacthas occurred, which is why it is crucial to intervene as soon as possible. 14 InHope, Grooming, as at June 2025, URL. 13 https://protectchildren.ca/pdfs/C3P SurvivorsSurveyExecutiveSummary2017 en.pdf. 12 European Commission, EU strategy for a more effective fight against child sexual abuse (COM(2020)607 final), url,24 July 2020; Council of Europe, European Day on the Protection of Children against Sexual Exploitation and SexualAbuse’, url, updated October 2016. 11 Tech Platforms Used by Online Child Sexual Abuse Offenders, url, February 2024. 58 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Figures released by the Internet Watch Foundation (IWF) show that 91% of assessed reports ofCSAM in 2024 were self-generated—often involving children aged 7–13, sometimes as young as3–10. Between 2020–21, instances for ages 7–10 soared from 8,000 to 27,000—a 235% jump.Further research15 from the IWF also reveals 14% of UK young adults (18–24) accidentallyencountered CSAM, while the 25–34 age group reported 10%. Figures released by the IWF alsoshow that Europe remains a global hub for CSEA. The percentage of child sexual abuse reportswere traced to hosting services in Europe (including Russia and Turkey) has remainedconsistently high (59% of global cases in 202216, 64% in 202317 and 62% in 2024.18 The IWFrecorded year-on-year increases in both the number of URLs and direct reports which containCSAM, with a 6% increase between 2023 and 2024. Unfortunately, this shows that the severeharm caused by CSEAI is still growing. According to updated figures from NCMEC19, it received reports relating to 29.2 million incidentsof suspected child sexual exploitation via its CyberTipline in 2024. While this is a significantnumber, the overall number of reports declined from 36.2 million reports received in 2023.NCMEC also noted in its report two trends which have continued to rise since its 2023 report: (i) acontinued increase in online enticement reports, fueled in part by the crime of sextortion withNCMEC receiving nearly 100 reports of financial sextortion a day; and (ii) an increase in reportsrelating to generative AI, from 4700 in 2023 to 67,000 in 2024. While these are still relativelysmall compared to other categories of CSEAI, these are trends that Snap is very conscious of andis monitoring. DSA Risk Factors In accordance with Section 3 (Methodology), we have also taken into account, in particular,whether and how the following service risk factors referenced in Article 34(2) of the DSAinfluence the risk of this harm on Snapchat’s in-scope services. As set out below, while thefollowing risk factors could in principle influence this systemic risk, their overall impact is limitedgiven Snap’s existing mitigations, which are described later in this chapter and in Chapter 5. Service Risk Factor How does it apply to Snapchat and this harm? (a) the design of recommendersystems and any otherrelevant algorithmic system; Our recommender systems are designed not to knowinglyrecommend CSEA – i.e., there are no ‘CSEA’ interestcategories. Detailed information regarding the mitigationsrelating to our recommender systems can be found in Section5 (see the Algorithmic Systems sub-section). 19 NCMEC, CyberTipline Report 2024, https://www.missingkids.org/gethelpnow/cybertipline/cybertiplinedata 18 Internet Watch Foundation (IWF), Annual report 2024, url, 2024 17 Internet Watch Foundation (IWF), Annual report 2023, url, 2023. 16 Internet Watch Foundation (IWF), Annual report 2022, url, 2022. 15 IWF, More than one in 10 British young people exposed to online child sexual abuse, url. 59 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT (b) content moderation systems; Snap has implemented specific proactive and reactivemoderation procedures to prevent and remove CSEA. Asexplained in the Content Moderation Section (specifically, thesection on CSEA), Snap deploys a range of automated contentmoderation (which includes abusive language detection, otherkeyword-based detection, and machine-learning-basedproactive detection) to scan media uploads for CSEA,including: (i) PhotoDNA, CSAI Match, and other hash-baseddetection (including NCMEC’s Take It Down hashes) to detectknown CSAM; (ii) Google’s Content Safety API to detect novelCSAM and (iii) proprietary signal based tools to detectsextortion and other sexual harms against minors. We providemore information in Section 5 (see Content Moderationsub-section) (c) the applicable terms andconditions and enforcement; Our Community Guidelines (which form part of our terms ofservice) prohibit CSEA for all users (both adult and Teenaccounts) and they are strictly enforced given the risk ofsevere harm. We provide more information in Section 5 (seethe Terms and Enforcement sub-sections) (d) systems for selecting andpresenting advertisements;and Our advertising systems require agreement to advertisingpolicies and guidance that prohibit adverts from displayinginformation that violates the law or causes certain harms. Wecheck advertisers are complying with their obligations via ouradvertising review process. Our advertising systems use a mixof automation and human review to review adverts before theyare published. We provide easy mechanisms for users to hideand report advertisements that violate our policies or the law.We monitor ad rejection, reporting and enforcement data tomonitor the effectiveness of our approach. We provide moreinformation in Section 5 (see the Advertising Systemssub-section) (e) our data related practices We have strong data principles, practices and privacy, safetyand security by design processes. We provide moreinformation in Section 5 (see the Transparency sub-section)and Section 6 (see the Platform Principles Framework andPrivacy and Safety by Design subsections). We have also analysed whether and how the risk of CSEA is influenced by the following generalfactors: General Risk Factor How does it apply to Snapchat and this harm? 60 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Amplification and potentially rapid andwide dissemination of illegal contentand of information that is incompatiblewith their terms and conditions. Snapchat’s inscope services have a number of features anddesign configurations that act to limit the amplification andpotentially rapid and wide dissemination of CSEA content, inparticular: 1. Snapchat is not an attractive platform for spreadingCSEA, in particular because it is difficult to reach abroad audience and content is deleted by default. Weprovide more information in Section 5 (see SnapchatDesign / Function subsection) 2. Snap has implemented specific proactive and reactivemoderation procedures to prevent and remove CSEA.As explained in the Content Moderation Section(specifically, the section on CSEA), Snap deploys arange of automated content moderation (whichincludes abusive language detection, otherkeyword-based detection, andmachine-learning-based proactive detection) to scanmedia uploads for CSEA, including: (i) PhotoDNA,CSAI Match, and other hash-based detection(including NCMEC’s Take It Down hashes) to detectknown CSAM; (ii) Google’s Content Safety API todetect novel CSAM and (iii) proprietary signal basedtools to detect sextortion and other sexual harmsagainst minors. We provide more information inSection 5 (see Content Moderation) 3. Content recommended to users on Spotlight andDiscover, our video sharing platforms, is moderatedusing a combination of auto-moderation and humanmoderation, and is human moderated before beingwidely distributed. Lens and Ads are subject to review 61 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT In the table below we indicate the specific measures we have taken to mitigate this risk in respectof Snapchat’s in-scope services. These are organised into Snap’s risk assessment mitigationcategories. Note that the primary purpose of the below table is to indicate whether each specificmitigation category applies to this risk and the descriptions are illustrative rather than exhaustive.As many of our mitigations apply to all of the risks assessed in this Report, to reduce duplicationin this Report, each row in the tables provides a link in the left hand column to a full summary ofthe specific mitigation in Section 5 of this Report which explains in more detail how eachmitigation operates to reduce the risk. MitigationCategory Applies to this risk? Snapchat Design and Function Adapting the design, features orfunctioning of their services,including their online interfaces. Yes, several aspects of Snapchat’s design and function reduce therisk that teens will come into contact with strangers. For example, bydefault users need to accept bi-directional friend requests or alreadyhave each other in their contact book to start communicatingdirectly with each other. This is an important mitigation to preventstrangers from contacting users on Snapchat. Friend lists remainprivate. Snapchat does not disclose the friend lists of users to otherusers, nor do we expose the total number of friends that a user has.There is also no option to share location with strangers. Terms and Enforcement Adapting their terms andconditions and their enforcement. Yes, our Community Guidelines (which form part of our terms ofservice) prohibit CSEA and they are strictly enforced given the riskof severe harm. When Snap becomes aware that CSEA is present onour platform, we remove the content from the platform or takeenforcement action on the user account as appropriate. Uponidentifying any CSEA on Snapchat, Snap also reports the contentand the user’s account to NCMEC. Moderation Adapting content moderationprocesses, including the speedand quality of processing noticesrelated to specific types of illegalcontent and, where appropriate,the expeditious removal of, or thedisabling of access to, thecontent notified, in particular inrespect of illegal hate speech orcyber violence, as well asadapting any relevantdecision-making processes and Yes, Snap has implemented specific proactive and reactivemoderation procedures to prevent and remove CSEA. As explainedin the Content Moderation Section (specifically, the section onCSEA), Snap deploys a range of automated content moderation(which includes abusive language detection, other keyword-baseddetection, and machine-learning-based proactive detection) to scanmedia uploads for CSEA, including: (i) PhotoDNA, CSAI Match, andother hash-based detection (including NCMEC’s Take It Downhashes) to detect known CSAM; (ii) Google’s Content Safety API todetect novel CSAM and (iii) proprietary signal based tools to detectsextortion and other sexual harms against minors. We enforceagainst accounts found to be engaging in CSEA. Snapchatters canalso report CSEA to us via in-app reporting options and anyone can 63 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? dedicated resources for contentmoderation. submit a report through the Snapchat Support Site. Algorithmic Systems Testing and adapting theiralgorithmic systems, includingtheir recommender systems. Yes, our algorithmic systems do not knowingly recommend CSEA –i.e., there are no ‘CSEA’ interest categories. Advertising Systems Adapting their advertisingsystems and adopting targetedmeasures aimed at limiting oradjusting the presentation ofadvertisements in associationwith the service they provide. Yes, other mitigations listed here also apply to our AdvertisingSystems. Ongoing Risk Detection andManagement Reinforcing the internalprocesses, resources, testing,documentation, or supervision ofany of their activities in particularas regards detection of systemicrisk. Yes, for example we have specific prevalence testing andmonitoring moderation and enforcement data which we use to helpdetect and manage CSEA-related risk. Trusted Flaggers Initiating or adjusting cooperationwith trusted flaggers inaccordance with Article 22 andthe implementation of thedecisions of out-of-court disputesettlement bodies pursuant toArticle 21. Yes, we cooperate with trusted flaggers in relation to CSEA. Codes and Crisis Protocols Initiating or adjusting cooperationwith other providers of onlineplatforms or of online searchengines through the codes ofconduct and the crisis protocolsreferred to in Articles 45 and 48respectively. Yes, we cooperate with other providers through various groups –e.g. EUIF, the Technology Coalition, WeProtect Global Alliance, IWF(Report Remove). We are members of StopNCII.org in the UK and weuse their hashes to help detect and remove NCII. Snap works with NCMEC and other safety experts to learn aboutharms relating to CSEA and how they may manifest themselves onour platform, and to report such harms to the proper authorities.Snap also has trusted flaggers to bring these and other types of 64 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? harms to the attention of our safety teams. There are also industrywide initiatives such as the Tech Coalition’s Lantern Program whichwas launched on 10 November 2023.20 Transparency Taking awareness-raisingmeasures and adapting theironline interface in order to giverecipients of the service moreinformation. Yes, we provide guidance on our Terms, harms, moderation andenforcement practices, and how to get help in our Safety Center. Wealso have in-app resources on sexual content which educates andempowers users about these harms (including CSEA) and how toreport these in the UK, including law enforcement and ReportRemove. We have provided significant support resources for ourusers concerning financial sextortion21. Protection of Minors Taking targeted measures toprotect the rights of the child,including age verification andparental control tools, tools aimedat helping minors signal abuse orobtain support, as appropriate. Yes, we have protective measures to limit teen contact withstrangers, as well as provide warnings to teens when they first start chatting with someone who may be a stranger; we offer FamilyCenter where parents can see who their teen is friends with,speaking to and report any suspicious accounts for review; we makeavailable robust reporting. Our new parents site provides additionalguidance for parents and caregivers on risks and support.22 Content Authenticity Ensuring that an item ofinformation, whether it constitutesa generated or manipulatedimage, audio or video thatappreciably resembles existingpersons, objects, places or otherentities or events and falselyappears to a person to beauthentic or truthful isdistinguishable throughprominent markings whenpresented on their onlineinterfaces, and, in addition,providing an easy to usefunctionality which enablesrecipients of the service toindicate such information. We recognise there is growing concern regarding use of generativeAI tools for CSEA in general online. Snap has taken steps to mitigatethe risk that (i) its generative AI tools are used for creating illegal orotherwise violating content and (ii) illegal or otherwise violatingcontent created using generative AI tools on any online platform aredisseminated on Snapchat’s in-scope services. Snap has alsorequested that NCMEC share its hash list of AI generated CSEAcontent. While we are alive to the risk, we have not identified any materialissue with Snapchat being used to create or disseminate generativeCSEA materials. 22 Snapchat Family Safety Hub, url. 21 https://values.snap.com/safety/financial-sextortion 20 Tech Coalition, Announcing Lantern: The First Child Safety Cross-Platform Signal Sharing Program, url, 2023. 65 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Conclusion Given the severity of the harm industry-wide, Snap still treats CSEAI as a Level 1 risk priority Inresponse to which it has put in place a range of mitigation measures. This includes in particularour proactive content moderation which is designed to detect and prevent CSEAI from appearingon each of Snapchat’s in-scope services – for example, our automated and human review onSpotlight. Our prevalence testing has continued to help us to improve this proactive contentmoderation. As a result, we’ve seen the prevalence of CSEAI on Snapchat fall and be maintainedto an extremely low levelIn addition, while we are alive to the risk, we have not identified any material issue withSnapchat’s in-scope services being used for the dissemination of generative CSEAI materials. We have concluded therefore that Snapchat’s in-scope services have reasonable,proportionate and effective mitigation measures for the dissemination of CSEAI. There is nochange in this conclusion from our 2024 Report. 4.1.2 Dissemination of illegal hate speech This Section 4.1.2 (Illegal Hate Speech) considers the risk of harm arising from hate content andactivity (as described in the Harm Description below) on Snapchat’s in-scope services. Harm Description Snap describes ‘hate’ as content that demeans, or promotes discrimination towards, an individualor group of individuals on the basis of their race, color, caste, ethnicity, national origin, religion,sexual orientation, gender, gender identity, disability, veteran status, immigration status,socio-economic status, age, weight, or pregnancy status. Hate Speech may include references topeople that are dehumanizing or that compare humans to animals on the basis of these traits andcategories. Hate Speech also includes the valorization of perpetrators—or the denigration of thevictims—of hateful atrocities (e.g., genocide, apartheid, slavery, etc.), as well as the promotion ofhate symbols. We provide a summary and explanation of ‘hate’ in our explainer on Hateful Content ExplainerSeries, and our Transparency Report Glossary. Likelihood Snap is sensitive to the issue of hate speech on internet platforms,23 as well as the damagingeffects hate speech can have on a community. Thankfully, hate speech is rarely found on thepublic surfaces of Snapchat. In our 2024 Report, we highlighted that our prevalence testingshowed that hate speech accounted for an extremely low percentage of total views of Snaps inPublic Stories. In this Report, we are pleased to confirm that our prevalence testing has shown 23 Eurostat, 50% of young people encounter hostile messages online, 1 August 2024, url. 66 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT that the PVP for Hate Speech has continued to fall dramatically Moreover, when content related to this specific Harm was detected (whether proactively throughautomated tools or reactively following a user report) our Safety teams acted swiftly. According toour latest European Union Transparency Report (covering the second half of 2024), the medianturnaround time for enforcement action in response to proactive or reactive detections of thiscontent was 36 minutes. As a result of this rapid turnaround time: ● the violative view rate for EU users for this type of content across the following Snapchatin-scope services is very low in the first half of 2025: ● the violative view rate for EU minors for this type of content across the following Snapchatin-scope services is also very low in the first half of 2025: Finally, while we engage with Trusted Flaggers on hate speech, out of the 1,424 reports wereceived from Trusted Flaggers across all harm categories in the EU during the second half of2024 and the first half of 2025, none came from entities focused on hate speech. Therefore, the steps Snap has taken to mitigate this harm mean that it is very unlikely thatSnapchatters will encounter hate speech on Snapchat’s in-scope services, and Snap continues toplace Hate Speech in the lowest likelihood level of all our risks. Severity In prior reports, we noted that the Council of Europe acknowledged that “hate speech is a deeprooted, complex and multidimensional phenomenon, which takes many dangerous forms and canbe disseminated very quickly and widely through the internet, and that the persistent availabilityof hate speech online exacerbates its impact” and “realising that hate speech negatively affectsindividuals, groups and societies in a variety of ways and with different degrees of severity,including by instilling fear in and causing humiliation to those it targets and by having a chillingeffect on participation in public debate, which is detrimental to democracy”.24 The OSCE High 24 Council of Europe, ‘Recommendation CM/Rec(2022)16 of the Committee of Ministers to member States oncombating hate speech’, May 2022, url. 67 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Commissioner on National Minorities also recognised the dangers of hate speech and offeredguidance on how to create, nurture, and develop the role of the media and informationtechnologies for conflict prevention in its Tallinn Guidelines.25 Snap’s assessment of the severity of Hate Speech has not changed in this Report. Snap stillconsiders content that qualifies as hate speech to be significant in terms of severity. We continueto believe it is imperative for Snap to combat hate speech in all forms to cultivate a welcoming,positive, non-discriminatory online environment for all Snapchatters. This includes content thatdemeans, defames, or promotes discrimination towards an individual or group of individuals onthe basis of protected characteristics and the promotion of hate groups. Because of the widescope of the term, and the thin line with expressions that do fall within the scope of freedom ofexpression, we continue to include hate speech in the “significant” harms category. DSA Risk Factors In accordance with Section 3 (Methodology), we have also taken into account, in particular,whether and how the following service risk factors referenced in Article 34(2) of the DSAinfluence the risk of this harm on Snapchat’s in-scope services. As set out below, while thefollowing risk factors could in principle influence this systemic risk, their overall impact is limitedgiven Snap’s existing mitigations, which are described later in this chapter and in Chapter 5. Service Risk Factor How does it apply to Snapchat and this harm? (a) the design of recommendersystems and any other relevantalgorithmic system; Our recommender systems are designed to not knowinglyrecommend hate speech, i.e. there are no interest categoriesrelated to hate speech. Detailed information regarding themitigations relating to our recommender systems can befound in Section 5 (see the Algorithmic Systems sub-section). (b) content moderation systems; Snap has implemented specific proactive and reactivemoderation procedures to prevent and remove hate speech,including service-specific adaptations to address violatingcontent, such as hate speech. We provide more informationin Section 5 (see Content Moderation sub-section). (c) the applicable terms andconditions and enforcement; Our terms prohibit hate speech and are strictly enforced. Asexplained in Section 5 (see Terms and Enforcementsections), on our potentially high-reach surfaces, likeSpotlight and Discover, we take a proactive approach tomoderating any content that may violate our rules on hatespeech. Our in-app reporting tool also allows users to 25 OSCE, ‘The Tallinn Guidelines on National Minorities and the Media in the Digital Age’, February 2019, url. 68 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT directly report hateful content or activities that supportterrorism or violent extremism. When hateful content isreported, our teams will remove any violating content andusers who engage in repeated or egregious violations willhave their account access locked. Lenses identified withhate speech were rejected when found during submissionand disabled in Discover upon review if subsequentlyidentified. As an additional measure, we encourageSnapchatters to block any users who make them feel unsafeor uncomfortable. Snap removes violating hate speech assoon as we become aware of it, and will promptly disableaccounts dedicated to hate speech, hate symbols or groups,or the glorification of hate groups or members of a hategroup. (d) systems for selecting andpresenting advertisements; and Our advertising systems require agreement to advertisingpolicies and guidance that prohibit adverts from displayinginformation that violates the law or causes certain harms. Wecheck advertisers are complying with their obligations viaour advertising review process. Our advertising systems usea mix of automation and human review to review advertsbefore they are published. We provide easy mechanisms forusers to hide and report advertisements that violate ourpolicies or the law. We monitor ad rejection, reporting andenforcement data to monitor the effectiveness of ourapproach. We provide more information in Section 5 (see theAdvertising Systems sub-section) (e) our data related practices We have strong data principles, practices and privacy, safetyand security by design processes. We provide moreinformation in Section 5 (see the Transparency sub-section)and Section 6 (see the Platform Principles Framework andPrivacy and Safety by Design subsections). We have also analysed whether and how the risk of this harm is influenced by the followinggeneral factors: General Risk Factor How does it apply to Snapchat and this harm? Intentional manipulation, includinginauthentic use or inauthentic use orautomated exploitation of the service There are two key ways in which we consider our systemscould be manipulated: (1) Users could seek to share novel illegal andviolating material that is not detected by ourautomated systems. We are constantly working to 69 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT adjust our systems and policies to address this. Weprovide more information on our approach inSection 5 (in particular the Content Moderationsubsection) and Section 6 (Ongoing Risk Detectionand Management). (2) Users could abuse our content moderationprocesses and report non-violating content /accounts in bad faith. We have processes tocombat misuse and more information can be foundin Section 5 (Content Moderation and Enforcementsubsections). Amplification and potentially rapid andwide dissemination of illegal content andof information that is incompatible withtheir terms and conditions. Snapchat’s inscope services have a number of features anddesign configurations that act to limit the amplification andpotentially rapid and wide dissemination of illegal hatespeech, 1. Snapchat is not an attractive platform for spreadinghate speech, in particular because it is difficult toreach a broad audience and content is deleted bydefault. We provide more information in Section 5(see Snapchat Design / Function subsection) 2. Snap has implemented specific proactive andreactive moderation procedures to prevent andremove hate speech. We provide more informationin Section 5 (see Content Moderation). 3. Content recommended to users on Spotlight andDiscover, our video sharing platforms, is moderatedusing a combination of auto-moderation and humanmoderation, and is human moderated before beingwidely distributed. Lens and Ads are subject toreview processes before submission. We providemore information in Section 5 (see ContentModeration). Specific regional or linguistic aspects,including when specific to a MemberState. We recognise that our users may come from differentMember States and content may be shared in differentlanguages. To address this, ● Snapchat is provided in multiple EU languages andour Terms are available in all EU languages. Weprovide more information in Section 5 (see Terms). ● We deploy content moderation systems andmoderators work across multiple EU languages. Weprovide more information in Section 5 (see ContentModeration). 70 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? Terms and Enforcement Adapting their terms and conditionsand their enforcement. Yes, our terms prohibit hate speech and they are strictlyenforced. As explained in our Moderation and Enforcementsections in Section 5 of our report, on our potentially high-reachsurfaces, like Spotlight and Discover, we take a proactiveapproach to moderating any content that may violate our ruleson hate speech. Our in-app reporting tool also allows users todirectly report hateful content. When hateful content isreported, our teams will remove any violating content and userswho engage in repeated or egregious violations will have theiraccount access locked. Lenses identified with hate speechwere rejected when found during submission and disabled inDiscover upon review if subsequently identified. As anadditional measure, we encourage Snapchatters to block anyusers who make them feel unsafe or uncomfortable. Snapremoves violating hate speech as soon as we become aware ofit, and will promptly disable accounts dedicated to hate speech,hate symbols or groups, or the glorification of hate groups ormembers of a hate group. Specific rules26 apply to our Lenses. Moderation Adapting content moderationprocesses, including the speed andquality of processing notices relatedto specific types of illegal contentand, where appropriate, theexpeditious removal of, or thedisabling of access to, the contentnotified, in particular in respect ofillegal hate speech or cyber violence,as well as adapting any relevantdecision-making processes anddedicated resources for contentmoderation. Yes, specific proactive and reactive moderation procedures toprevent and remove hate speech. This includes service-specificadaptations to address violating content such as hate speech. If Lenses are found to be violating our rules and promotingmisogynist content, Snap takes enforcement action againstsuch Lenses (for example, we have removed a few Lensespromoting Andrew Tate). Algorithmic Systems Testing and adapting theiralgorithmic systems, including theirrecommender systems. Yes, our algorithmic systems do not knowingly recommend hatespeech – i.e., there are no interest categories relating to hatespeech. Advertising Systems Yes, other mitigations listed here also apply to our AdvertisingSystems. 26 https://businesshelp.snapchat.com/s/article/Lens-Restrictions?language=en 72 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? Adapting their advertising systemsand adopting targeted measuresaimed at limiting or adjusting thepresentation of advertisements inassociation with the service theyprovide. Ongoing Risk Detection andManagement Reinforcing the internal processes,resources, testing, documentation, orsupervision of any of their activities inparticular as regards detection ofsystemic risk. Yes, for example we have specific prevalence testing andmonitoring moderation and enforcement data which we use tohelp detect and manage hate speech. Trusted Flaggers Initiating or adjusting cooperationwith trusted flaggers in accordancewith Article 22 and theimplementation of the decisions ofout-of-court dispute settlementbodies pursuant to Article 21. Yes, we cooperate with trusted flaggers in relation to hatespeech. In the EU, this includes Licra (France), the GermanDepartment for Internet Services \& Social Media and Someturva(Finland). Codes and Crisis Protocols Initiating or adjusting cooperationwith other providers of onlineplatforms or of online search enginesthrough the codes of conduct andthe crisis protocols referred to inArticles 45 and 48 respectively. Yes, we cooperate with other providers through various groupsin relation to hate speech. This includes the Government’sCounter Disinformation Unit and more broadly, Snap remains asignatory of the EU Code of Conduct to counter hate speechonline and has worked hard to ensure Snap meets therequirements (including with respect to recent revision of thatCode). Transparency Taking awareness-raising measuresand adapting their online interface inorder to give recipients of the servicemore information. Yes, we provide guidance on harms and how to get help in our Safety Center. We make available robust reporting; and weprovide guidance to parents on the web. Protection of Minors Taking targeted measures to protectthe rights of the child, including ageverification and parental control Yes, we have protective measures to limit Teen contact withstrangers; we offer Family Center, reporting and guidance. Ournew parents site provides additional guidance for parents andcaregivers on risks and support.27 27 Snapchat Family Safety Hub, url. 73 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? tools, tools aimed at helping minorssignal abuse or obtain support, asappropriate. Content Authenticity Ensuring that an item of information,whether it constitutes a generated ormanipulated image, audio or videothat appreciably resembles existingpersons, objects, places or otherentities or events and falsely appearsto a person to be authentic or truthfulis distinguishable through prominentmarkings when presented on theironline interfaces, and, in addition,providing an easy to use functionalitywhich enables recipients of theservice to indicate such information. Yes, Snap has taken steps to mitigate the risk that (i) itsgenerative AI tools are used for creating illegal or otherwiseviolating content and (ii) illegal or otherwise violating contentcreated using generative AI tools on any online platform aredisseminated on Snapchat’s inscope services. Conclusion Snap considers illegal hate speech a Level 3 risk prioritization. In response it has put in place arange of mitigation measures. These include in particular our alignment to the EU Hate Speechcode of practice) and our proactive content moderation which is designed to detect and preventillegal hate speech from reaching a broad audience on Snapchat’s in-scope services. We monitorthe prevalence of hate speech in general via our Prevalence Testing and external reporting whichwe publish in our Transparency Reports. As a result of the mitigation measures Snap has taken,hate speech continues to be one of our lowest prevalence risks We have concluded therefore that Snapchat’s in-scope services have reasonable,proportionate and effective mitigation measures for the dissemination of illegal hate speech.There is no change in this conclusion from our 2024 Report. 4.1.3 Dissemination of information related to the sale of prohibited productsor services This Section 4.1.3 (Sale of Prohibited and Regulated Products or Services) considers the risk ofharm arising from the sale of prohibited products or services (as described in the Descriptionbelow) on Snapchat’s in-scope services. 74 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Harm Description This harm includes content or activity that promotes, facilitates, or enables the illegal supply,trade, or solicitation of drugs, weapons, and other prohibited or controlled goods and services. Itencompasses user-generated content, profiles, messages, and interactions which: ● Advertise or promote the sale of illicit drugs or controlled substances; ● Offer firearms, knives, weapons or promote illegal weapons trafficking; ● Enable or promote the trafficking of individuals, including content relating to therecruitment, transportation, or exploitation of people through force, fraud, or coercion. ● Facilitate the sale or procurement of other goods and services prohibited by law. Snap prohibits any content that encourages or enables engagement in illegal transactions oractivity relating to drugs, weapons or other controlled/prohibited goods. Further definitions onthis are set out in our Transparency Report Glossary and in our explainer on Illegal or RegulatedActivities. Likelihood We recognize that the sale of illegal products and services via social media is an issue ofincreasing concern among public health authorities, law enforcement, and regulators. Forexample, the WIRED article “Drug Dealers Have Moved On to Social Media”28 reflects broaderfindings from European institutions, including the European Union Drugs Agency (EUDA), whichhas documented the migration of drug markets onto online intermediary services. Similarly, areport commissioned by the EUDA29 highlights that digital drug dealing is active across severalEU member states, particularly in Northern Europe. However, these reports typically focus on theprivate messaging and limited broadcast features of online intermediary services, such asencrypted messaging. Please note that, while Snap takes these issues very seriously andcontinues to invest significant resources to combat this criminal and violative activity on theprivate and limited broadcast services of Snapchat, such activity is out of scope of this Report. With regards to Snapchat’s in-scope services, which concern how our online platformsdisseminate information to the general public, our testing shows that the prevalence ofinformation related to the sale of prohibited products or services continues to decrease year onyear. This is a further, significantdecrease from ) that we reported for July 2024in our 2024 Report. Moreover, when content related to this specific Harm was detected (whether proactively throughautomated tools or reactively following a user report) our Safety teams acted swiftly. Our latest 29 European Monitoring Centre for Drugs Addiction, ‘An Analysis of Drug Dealing via Social Media’, url, 2022. 28 Wired, ‘Drug Dealers Have Moved on to Social Media’, url, December 17, 2024. 75 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT European Union Transparency Report (covering the second half of 2024) recorded a medianenforcement turnaround time of 58 minutes for drug-related content, 3 minutes for contentrelated to weapons, and 10 minutes for content related to other regulated related goods,following either proactive detection or user reports. ● The likelihood of encountering such violating content on Snapchat’s in-scope services is now atits lowest level and falls within the lowest category in terms of likelihood. Severity Snap continues to consider this issue to be severe where a credible threat to human life, safety,or well-being existed. Snap also considers the depiction or use of, or attempts at buying, selling,exchanging, or facilitating sales of illegal drugs to be a severe harm. As noted in our 2024 Report,Snap has experienced bad actors trying to exploit our product architecture for the illicit sale ofdrugs, generally presenting acute risks.30 According to the European Monitoring Centre for Drugsand Drug Addiction, “the use of illicit drugs causes a range of acute and chronic harms and is arecognised contributor to the global burden of disease.” The 2023 European Drug Report states 30 New York Times, ‘Fentanyl Tainted Pills Bought on Social Media Cause Youth Drug Deaths to Soar’, url, 19 May2022\. Cf. Snap, ‘How Snap is responding to the fentanyl crisis’, url, 7 October 2021; Snap, ‘Continuing our Efforts toCombat the U.S. Fentanyl Crisis’, url, 12 October 2022 ; Snap, ‘National Fentanyl Awareness Day: Continuing OurEfforts to Combat the U.S. Fentanyl Crisis’, url, 9 May 2023. 76 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT chronic problems include “dependence and drug-related infectious disease, while there is arange of acute harms, of which drug overdose is the best documented.”31 Snap considers attempts to buy or sell weapons and depicting or brandishing weapons in athreatening or violent context to be a serious risk in terms of severity. As several reports show,gun trafficking is a major concern in the context of human security.32 Being instrumental in muchviolence, guns pose a significant threat to human life and well-being. Illicit firearms may be usedfor self-harm or domestic violence, or ultimately end up with criminals, supporting operationsrelated to armed conflicts and terrorism.33 Studies show that firearm manufacturers use socialmedia to attract audiences to their websites, contributing to the spread of gun violence.34 Forinstance, the European Parliamentary Research Service (EPRS) briefing “Understanding EU policyon firearms trafficking” highlights a concerning trend: illicit firearms are increasingly accessiblethrough online channels, enabling individuals, even without criminal ties, to procure weaponsmore easily than before. This marks a shift from traditionally closed illicit markets to more open,internet-enabled trafficking networks, facilitated by the availability of easily convertible or illegalcomponents online.35 Snap also tracks the dissemination of illegal or otherwise violating content that relates to otherregulated or prohibited goods as it recognises the use of online platforms for selling other illegalgoods or services online also places consumers at risk.36 For example, Snapchat has taken intoserious consideration the concerns raised by Dutch health experts and youth organizationsregarding the alleged illegal sale of vape related products to minors on the platform while furtherengaging with NGOs and law enforcement authorities to adopt measures aimed at preventingsuch illegal sale. We recognize that the sale and promotion of regulated products on social mediais an area of public and regulatory interest, and we continue to follow developments closely,reassess mitigations and implement further safeguards in response. Consequently, Snapconsiders the dissemination of violating content that relates to other regulated or prohibitedfoods to give rise to a significant risk of harm. DSA Risk Factors In accordance with Section 3 (Methodology), we have also taken into account, in particular,whether and how the following service risk factors referenced in Article 34(2) of the DSAinfluence the risk of this harm on Snapchat’s in-scope services. As set out below, while the 36J.P Kennedy and J.M. Wilson, ‘Clicking Into Harm’s Way: The Decision to Purchase Regulated Goods Online’,September 2017, url. 35 European Parliamentary Research Service, ‘Understanding EU policy on firearms trafficking’ url, 2024 34 L. Jordan e.a., “Characteristics of Gun Advertisements on Social Media: Systematic Search and Content Analysis ofTwitter and YouTube Posts”, J Med Internet Res (2020, 22(3)), March 2020 (url). 33 A. Neville, ‘European Parliamentary Research Service. Understanding EU policy on firearms trafficking’, url, February2022. 32 United Nations Office on Drugs and Crime, ‘Global Study on Firearms Trafficking 2020’, url, 2020. 31 European Monitoring Centre for Drugs and Drug Additions, ‘European Drug Report 2023’, url, 2023. 77 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT following risk factors could in principle influence this systemic risk, their overall impact is limitedgiven Snap’s existing mitigations, which are described later in this chapter and in Chapter 5. Service Risk Factor How does it apply to Snapchat and this harm? (a) the design of recommendersystems and any other relevantalgorithmic system; Our recommender systems are designed not to knowinglyrecommend content concerning the sale of prohibitedproducts or services content, i.e. there is no interest categoryfor this content. Detailed information regarding themitigations relating to our recommender systems can befound in Section 5 (see the Algorithmic Systems sub-section). (b) content moderation systems; Snap has implemented specific proactive and reactivemoderation procedures to prevent the sale of prohibitedproducts or services. As explained in the Content ModerationSection, Snap deploys a range of automated contentmoderationto detect andmoderate content relating to the sale of prohibited andregulated goods and services, and we have aggressivelyfocused on enforcement of severe and serious harms. Weprovide more information in Section 5 (see ContentModeration sub-section). (c) the applicable terms andconditions and enforcement; Terms prohibit the sale of prohibited products or services andthey are strictly enforced with the most seriousconsequences. Snap complies with relevant legalrequirements to remove content about the sale of prohibitedand regulated goods and services, and takes appropriateaction against egregious or repeat violators. Snap works withlaw enforcement, safety organizations, and subject matterexperts to continue to educate ourselves and our community,and to take appropriate action where these threats may ariseon our platform. (d) systems for selecting andpresenting advertisements; and Our advertising systems require agreement to advertisingpolicies and guidance that prohibit adverts from displaying 78 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT information that violates the law or causes certain harms. Wecheck advertisers are complying with their obligations via ouradvertising review process. Our advertising systems use amix of automation and human review to review advertsbefore they are published. We provide easy mechanisms forusers to hide and report advertisements that violate ourpolicies or the law. We monitor ad rejection, reporting andenforcement data to monitor the effectiveness of ourapproach. We provide more information in Section 5 (see theAdvertising Systems sub-section). (e) our data related practices We have strong data principles, practices and privacy, safetyand security by design processes. We provide moreinformation in Section 5 (see the Transparency sub-section)and Section 6 (see the Platform Principles Framework andPrivacy and Safety by Design subsections). We have also analysed whether and how the risk of this harm is influenced by the followinggeneral factors: Service Risk Factor How does it apply to Snapchat and this harm? Intentional manipulation, includinginauthentic use or inauthentic use orautomated exploitation of the service. There are two key ways in which we consider our systemscould be manipulated: (1) Users could seek to share novel illegal and violatingmaterial that is not detected by our automatedsystems. We are constantly working to adjust oursystems and policies to address this. We providemore information on our approach in Section 5 (inparticular the Content Moderation subsection) andSection 6 (Ongoing Risk Detection andManagement). (2) Users could abuse our content moderationprocesses and report non-violating content /accounts in bad faith. We have processes to combatmisuse and more information can be found inSection 5 (Content Moderation and Enforcementsubsections). Amplification and potentially rapid andwide dissemination of illegal content andof information that is incompatible withtheir terms and conditions. Snapchat’s in-scope services have a number of features anddesign configurations that act to limit the amplification andpotentially rapid and wide dissemination of contentconcerning the sale of prohibited products or services: 1. Snap makes it difficult for unvetted content to reach 79 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT a large audience on Snapchat, and Snap proactivelymoderates Snapchat’s in-scope services that providean opportunity to reach a larger audience. As aresult, this reduces the likelihood of our usersencountering content concerning the sale ofprohibited products or services on the platform. 2. Snapchat has also been designed to limit theprevalence of content concerning the sale ofprohibited products or services. Snap hasimplemented specific proactive and reactivemoderation procedures to prevent and remove AdultSexual Content. We provide more information inSection 5 (see Content Moderation). 3. Content recommended to users on Spotlight andDiscover, our video sharing platforms, is moderatedusing a combination of auto-moderation and humanmoderation, and is human moderated before beingwidely distributed. Lens and Ads are subject toreview processes before submission. We providemore information in Section 5 (see ContentModeration). Specific regional or linguistic aspects,including when specific to a MemberState. We recognise that our users may come from differentMember States and content may be shared in differentlanguages. To address this, ● Snapchat is provided in multiple EU languages andour Terms are available in all EU languages. Weprovide more information in Section 5 (see Terms). ● We deploy content moderation systems andmoderators work across multiple EU languages. Weprovide more information in Section 5 (see ContentModeration). Overall potential risk prioritization Thankfully, as reported in our 2024 Report, this is still not a common issue on Snap. Our Prevalence Testing revealed that communication around Illegal goods and activities now has onlya very small PVP rate However,due to the severity of some potential products and services (such as communication arounddangerous or illicit drugs), prevalence is not the determinative factor for Snap’s prioritization ofthis issue. Snap prioritizes severe harm and legal compliance over prevalence on the platform,and for this category has decided to deviate from the standard risk framework, as demonstratedin the below graph. 80 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Mitigation Category Applies to this risk? Adapting their terms and conditionsand their enforcement. and they are strictly enforced with the most seriousconsequences. As explained in the Enforcement section of Section 5 of ourReport, Snap complies with relevant legal requirements toremove content about the sale of prohibited and regulatedgoods and services, and takes appropriate action againstegregious or repeat violators. Snap works with lawenforcement, safety organizations, and subject matter expertsto continue to educate ourselves and our community, and totake appropriate action where these threats may arise on ourplatform. When we identify violators engaging in the attempted buying,selling, exchanging, or facilitating sales of dangerous and illicitproducts and services, we disable their accounts and, in someinstances, refer the conduct to law enforcement. For lesssevere harms, a user will be warned and their contentremoved. Repeat violations will result in violators’ accountsbeing disabled. Moderation Adapting content moderationprocesses, including the speed andquality of processing notices related tospecific types of illegal content and,where appropriate, the expeditiousremoval of, or the disabling of accessto, the content notified, in particular inrespect of illegal hate speech or cyberviolence, as well as adapting anyrelevant decision-making processesand dedicated resources for contentmoderation. Yes, specific proactive and reactive moderation procedures toprevent the sale of prohibited products or services. As explained in the Content Moderation Section of Section 5 ofthe Report, we have proactive and reactive moderationprocesses in place to detect and moderate content relating tothe sale of prohibited and regulated goods and services, andwe have aggressively focused on enforcement of severe andserious harms. Algorithmic Systems Testing and adapting their algorithmicsystems, including their recommendersystems. Yes, our algorithmic systems do not knowingly recommendcontent concerning the sale of prohibited products or servicescontent, i.e. there is no interest category for this content. Advertising Systems Adapting their advertising systems andadopting targeted measures aimed atlimiting or adjusting the presentation of Yes, other mitigations listed here also apply to our AdvertisingSystems. 82 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Mitigation Category Applies to this risk? advertisements in association with theservice they provide. Ongoing Risk Detection andManagement Reinforcing the internal processes,resources, testing, documentation, orsupervision of any of their activities inparticular as regards detection ofsystemic risk. Yes, for example, we have specific prevalence testing andmonitoring moderation and enforcement data which we use tohelp detect and manage information related to the sales ofprohibited products and services. Trusted Flaggers Initiating or adjusting cooperation withtrusted flaggers in accordance withArticle 22 and the implementation ofthe decisions of out-of-court disputesettlement bodies pursuant to Article21. Yes, we cooperate with trusted flaggers in relation to the saleof prohibited products or services, in particular the NationalCrime Agency (NCA - particularly in relation to the sale ofknives and drugs). Codes and Crisis Protocols Initiating or adjusting cooperation withother providers of online platforms orof online search engines through thecodes of conduct and the crisisprotocols referred to in Articles 45 and48 respectively. Yes, we cooperate with other providers through variousindustry groups and share signals, especially in relation todrug dealers. Snap spearheaded signal sharing with Metarelating to illicit drugs content, and also collaborates with lawenforcement to receive and share signals. Transparency Taking awareness-raising measuresand adapting their online interface inorder to give recipients of the servicemore information. Yes, we have protective measures to limit Teen contact withstrangers; we offer Family Center; we make available robustreporting; and we provide guidance to parents on the web. Across Snapchat, we offer a number of resources to users toraise awareness on safety topics and protect them. Asexplained in the Transparency section of the Report, one ofthe examples of this is our in-app tool, Heads Up. Thissurfaces educational content from experts to Snapchatters ifthey try to search for drug-related content. Protection of Minors Taking targeted measures to protectthe rights of the child, including age Yes, we have protective measures to limit teen contact withstrangers, Family Center, reporting, and guidance. Our parentssite provides additional guidance for parents and caregivers 83 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Mitigation Category Applies to this risk? verification and parental control tools,tools aimed at helping minors signalabuse or obtain support, asappropriate. on risks and support.37 Content Authenticity Ensuring that an item of information,whether it constitutes a generated ormanipulated image, audio or video thatappreciably resembles existingpersons, objects, places or otherentities or events and falsely appearsto a person to be authentic or truthful isdistinguishable through prominentmarkings when presented on theironline interfaces, and, in addition,providing an easy to use functionalitywhich enables recipients of the serviceto indicate such information. General content authenticity measures taken in respect of thesale of prohibited products or services. Conclusion Despite the continued very low prevalence, we still consider the overall risk of the disseminationof the sale of dangerous or illicit drugs, or any other prohibited products or services that pose athreat to human life, safety, or well-being, to be in the Level 1 category due to the level of severity.Snap continues to consider that the sale of weapons poses a Level 2 overall potential risk, and aLevel 3 potential overall risk in relation to other prohibited products and services. Snap continuesto take steps to mitigate these harms, which has further diminished the likelihood thatSnapchatters will find information related to prohibited products or services on Snapchat’sin-scope services. Snap continues to invest significant resources to further combat these harms,and are still looking to achieve further reductions in the likelihood of this risk where possible. We have concluded therefore that Snapchat’s in-scope services have reasonable,proportionate and effective mitigation measures for dissemination of information related tothe sale of prohibited products or services. There is no change in this conclusion since our2024 Report. 37 Snapchat Family Safety Hub, url. 84 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 4.1.4 Dissemination of Terrorist Content This Section 4.1.4 (Terrorism) considers the risk of harm arising from terrorism content and activity(as described in the Harm Description below) on Snapchat’s in-scope services defined in Section2 (Scope). We have assessed this risk in accordance with the Section 3 (Methodology) as follows. Harm Description Terrorism refers to content that promotes or supports terrorism or other violent, criminal actscommitted by individuals and/or groups to further ideological goals, such as those of a political,religious, social, racial or environmental nature. It includes any content that promotes or supportsany terrorist organisation, as well as content that advances recruitment for terrorist organisations.Terrorism content includes material that promotes, incites, glorifies, or facilitates terrorist activityor ideology. This may take the form of propaganda, symbols, video or text glorifying massviolence, or recruitment communications. We provide a summary and explanation of ‘terrorism’ in our explainer on Hateful Content,Terrorism and Violent Extremism and our Transparency Report Glossary. Likelihood We have considered the likelihood of this harm in line with Section 3 (Methodology) andobserved the following for 2025: ● As noted in our 2024 Report, online influences have been depicted as major drivers forthe propagation and adoption of extremist ideologies, which often contain an element ofcollective grievance, and subsequent acts of violence.38 Terrorist organisations continueto target young people, spreading propaganda especially on those social media platformsthat are particularly popular among younger users, and adapting content andcommunication strategies to these platforms and their audiences.39 It is conceivable thatbad actors could disseminate Terrorist Content on Snapchat, as with any other onlineplatform. This could include, in particular, Terrorist Content appearing in videos featuredon Spotlight / Discover and extremist content and individuals promoted via Public Profiles. ● Snap internal media report analysis has not identified significant terrorism-related mediareferring to Snapchat. A March 2024 article in The Guardian discussed social media andradicalisation, but Snapchat was not cited. Only a couple of articles did identify activity onSnapchat: 39 Europol, European Union Terrorism Situation and Trend Report 2025, page 10, url; Council of the European Union, Council conclusions on future priorities for strengthening the joint counterterrorism efforts of the European Union andits Member States - Council conclusions (12 December 2024), p. 14, url. 38 J.F. Bender and J. Kenyon, Terrorism and the internet: How dangerous is online radicalization?, Front. Psychol., 13October 2022, url. 85 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ○ Essex teenage ISIS plot exposed via Snapchat - In May 2023, a 19‑year‑old fromEssex named Matthew King used Snapchat to post an image of police officers withthe caption “Target Acquired”, as part of an Islamist-inspired plot to kill soldiers orpolice. He carried out surveillance at several sites in London and later received alife sentence for preparing terrorist acts40 ○ Spanish plane “joke” incident involving a British student - Although not prosecutedin the UK, an 18‑year‑old UK student made a disturbing “joke” on Snapchat in 2022 about being a Taliban member and bombing a plane. The messagetriggered a Spanish security response but did not result in terrorism charges in theUK (UNILAD) ● Similarly, CEP41 and Tech Against Terrorism42 focused on encrypted messaging platforms(e.g. Telegram), livestream services, and global video platforms. Snapchat was notreferenced in any current sector-wide studies. ● In the European Union, in response to the various events influencing violent extremismand terrorism online through 2023, about 349 removal orders were sent by 6 EU memberStates' competent authorities to 13 online platforms under the Regulation ondissemination of terrorism content online;43 none were directed at Snap.44 ● Tech against Terrorism’s 2022 report45 also noted that file-sharing platforms (rather thansocial media platforms or messaging services) are increasingly being exploited by terroristand violent extremist communities for content that is most likely to be moderated andremoved from social media or messaging apps. ● ● In the second half of 2024, for example, we also locked 4 accounts and removed 90content in the EU for violations of our policy prohibiting terrorist and violent extremistcontent, as recorded in our Transparency Reports. Where Terrorism related content wasidentified (either proactively via automated tools or reactively following a report), our 45 Tech Against Terrorism: The Threat of Terrorist and Violent Extremist Operated Websites, January 2022, url. 44 Violent Extremism and Terrorism Online in 2023: The Year in Review, April 2024, url. 43 Regulation (EU) 2021/784. 42 Report: Terrorist Use of End-to-End Encryption - Insights from a Year of Multi-Stakeholder Discussion 41 A. Hoffmann, A. Küsters \& P. Eckhardt, Security and Trust: An Unsolvable Digital Dilemma?, url, 11 May 2025. 40 The Standard, ‘Essex teenager planned murder of soldiers or police in Snapchat terror plot’, url, 12 May 2023. 86 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT median turnaround time was rapid. Our latest European Union Transparency Report,which covers the second half of 2024, observed a median turnaround time for our Safetyteams to take enforcement action in response to proactive or reactive detections ofterroristic content of 6 minutes. ● ● As reported in our 2024 Report, we have previously sought independent analysis via thirdparty intelligence vendors (SITE and MEMRI) that track extremist activity online who haveverified that Snapchat does not fall into the top 100 communications platforms used byextremist groups to communicate. These data indicate that, while there has been a slight increase in the likelihood of encounteringTerrorist Content on Snapchat, it remains extremely low and it still falls within the lowestlikelihood category. Severity The European Commission has stated that the presence of Terrorist Content online is a grave riskto citizens and to society at large. Terrorist and violent groups use the Internet and associatedtechnologies for radicalization, recruitment, dissemination of propaganda, communication andmobilization. They spread their messages to intimidate, radicalize, recruit, and facilitate carryingout terrorist attacks.46 In general, terrorist and violent content posted online can be disseminatedquickly and cheaply, amplifying dangerous views and reaching (and possibly desensitizing) broadaudiences.47 An emerging risk in this context is the use of generative AI, which could enableterrorist organizations to rapidly expand their reach and influence by producing large volumes ofpersuasive, and often false, content that amplifies extremist narratives.48 Security and safety, as 48 C. Anthony Pfaff (Centre of Excellence Defence Against Terrorism of NATO), The Weaponization of AI: the NextStage of Terrorism and Warfare, 2025, url. 47 OECD, Transparency Reporting on Terrorists and Violent Extremist Content Online, July 2021, No. 313, page 4, url. 46 European Commission, Terrorist Content Online, url. 87 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT well as the dignity of victims, are seriously threatened by this.49 As a result, Snap continues toconsider the severity of this issue to be serious due to the high threat to human life, safety, orwell-being. DSA Risk Factors In accordance with Section 3 (Methodology), we have also taken into account, in particular,whether and how the following service risk factors referenced in Article 34(2) of the DSAinfluence the risk of this harm on Snapchat’s in-scope services. As set out below, while thefollowing risk factors could in principle influence this systemic risk, their overall impact is limitedgiven Snap’s existing mitigations, which are described later in this chapter and in Chapter 5. Service Risk Factor How does it apply to Snapchat and this harm? (a) the design of recommendersystems and any otherrelevant algorithmic system; Our algorithmic systems do not knowingly recommend terrorismcontent – i.e., there is no ‘terrorism’ interest category. As explainedin Section 5 (see the Algorithmic Systems sub-section), on ourhigh-reach surfaces, like Spotlight and Discover, we take a proactiveapproach to moderating any content that may violate these rulesprior to the content being recommended to a wide audience (b) content moderation systems; Snap has implemented specific proactive and reactive moderationprocedures to prevent and remove Terrorist Content. Snap deploysa range of automated content moderation (which include abusivelanguage detection, other keyword-based detection, andmachine-learning-based proactive detection models) to scan Storiesand Spotlight submissions. Snapchatters can report TerroristContent to us via in-app reporting options and anyone can submit areport through the Snapchat Support Site. Our in-app reporting toolalso allows users to directly report hateful content or activities thatsupport terrorism or violent extremism. We provide moreinformation in Section 5 (see Content Moderation sub-section). (c) the applicable terms andconditions and enforcement; Our Community Guidelines (which form part of our terms of service)expressly prohibit terrorist organizations, violent extremists, andhate groups from using our platform. Terrorism is considered a“severe harm” in our Community Guidelines and we respond withswift and strict consequences against violators as explained in our Severe Harms explainer. We provide more information in Section 5(see the Terms and Enforcement sub-sections). 49 European Commission, Tackling Illegal Content Online Towards an enhanced responsibility of online platforms (COM(2017) 555 final), url, 28 September 2017; Europol, European Union Terrorism Situation and Trend Report 2025, page 11, url 88 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT (d) systems for selecting andpresenting advertisements;and Our advertising systems require agreement to advertising policiesand guidance that prohibit adverts from displaying information thatviolates the law or causes certain harms. We check advertisers arecomplying with their obligations via our advertising review process.Our advertising systems use a mix of automation and human reviewto review adverts before they are published. We provide easymechanisms for users to hide and report advertisements that violateour policies or the law. We monitor ad rejection, reporting andenforcement data to monitor the effectiveness of our approach. Weprovide more information in Section 5 (see the Advertising Systemssub-section) (e) our data related practices We have strong data principles, practices and privacy, safety andsecurity by design processes. We provide more information inSection 5 (see the Transparency sub-section) and Section 6 (see thePlatform Principles Framework and Privacy and Safety by Designsubsections). We have also analysed whether and how the risk of Terrorism is influenced by the followinggeneral factors: General Risk Factor How does it apply to Snapchat and this harm? Intentional manipulation,including inauthentic use orinauthentic use or automatedexploitation of the service There are two key ways in which we consider our systems could bemanipulated:(1) Users could seek to share novel illegal and violatingmaterial that is not detected by our automated systems. Weare constantly working to adjust our systems and policies toaddress this. We provide more information on our approachin Section 5 (in particular the Content Moderationsubsection) and Section 6 (Ongoing Risk Detection andManagement).(2) Users could abuse our content moderation processes andreport non-violating content / accounts in bad faith. We haveprocesses to combat misuse and more information can befound in Section 5 (Content Moderation and Enforcementsubsections). Amplification and potentiallyrapid and wide dissemination ofillegal content and of informationthat is incompatible with theirterms and conditions. Snapchat’s inscope services have a number of features and designconfigurations that act to limit the amplification and potentially rapidand wide dissemination of Terrorist Content, in particular: 1. Snapchat is not an attractive platform for spreading TerroristContent, in particular because it is difficult to reach a broadaudience and content is deleted by default. We provide 89 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? criminal acts committed by individuals or groups to furtherideological goals. These rules also prohibit any content thatpromotes or supports foreign terrorist organizations or extremisthate groups– as designated by credible, third-party experts–aswell as recruitment for such organizations or violent extremistactivities. We promptly enforce against accounts found to be sendingTerrorism content: ● Snap removes such content for all users. ● Accounts we discover engaging in prohibited terroristactivity will also be promptly disabled. ● Where appropriate, accounts engaging in violation ofthese policies may be reported to law enforcement. Moderation Adapting content moderationprocesses, including the speedand quality of processing noticesrelated to specific types of illegalcontent and, where appropriate,the expeditious removal of, or thedisabling of access to, the contentnotified, in particular in respect ofillegal hate speech or cyberviolence, as well as adapting anyrelevant decision-makingprocesses and dedicatedresources for content moderation. Yes, we have specific proactive and reactive moderationprocedures to prevent and remove Terrorism related content. As explained in the Moderation section in Section 5, Snapdeploys a range of automated content moderation (which includeabusive language detection, other keyword-based detection, andmachine-learning-based proactive detection models) to scanStories and Spotlight submissions. Snapchatters can reportTerrorist Content to us via in-app reporting options and anyonecan submit a report through the Snapchat Support Site. Ourin-app reporting tool also allows users to directly report hatefulcontent or activities that support Terrorism or Violent Extremism. Algorithmic Systems Testing and adapting theiralgorithmic systems, including theirrecommender systems. Yes, unlike many of our peers, Snapchat does not offer an opennews feed where unvetted publishers or individuals have anopportunity to broadcast Terrorist Content, does not offer a broad‘reshare’ functionality that would encourage virality, and does notallow user-generated content to be recommended to a wideaudience without going through review. Our algorithmic systems do not knowingly recommend Terrorismcontent – i.e., there is no ‘terrorism’ interest category. Asexplained in the Moderation section of our Existing Mitigations inSection 5, on our high-reach surfaces, like Spotlight and Discover,we take a proactive approach to moderating any content that mayviolate these rules prior to the content being recommended to a 92 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? wide audience. Advertising Systems Adapting their advertising systemsand adopting targeted measuresaimed at limiting or adjusting thepresentation of advertisements inassociation with the service theyprovide. Yes, other mitigations listed here also apply to our AdvertisingSystems. Ongoing Risk Detection andManagement Reinforcing the internal processes,resources, testing, documentation,or supervision of any of theiractivities in particular as regardsdetection of systemic risk. Yes, for example we monitor data to help detect and manageTerrorist Content, including data from our specific prevalencetesting and enforcements (which are summarised in ourTransparency Reports). Trusted Flaggers Initiating or adjusting cooperationwith trusted flaggers in accordancewith Article 22 and theimplementation of the decisions ofout-of-court dispute settlementbodies pursuant to Article 21. General trusted flagger group we currently work with to addressTerrorism content in the European Union. Codes and Crisis Protocols Initiating or adjusting cooperationwith other providers of onlineplatforms or of online searchengines through the codes ofconduct and the crisis protocolsreferred to in Articles 45 and 48respectively. Yes, we cooperate with other providers through various industrygroups, including the EU Internet Forum (EUIF), that considerTerrorist Content. Note, due to the low prevalence of TerroristContent on Snap, we do not participate in the primary multistakeholder organization: The Global Internet Forum to CounterTerrorism (GIFCT). We also consult the expertise and work of civil rightsorganizations, human rights experts, law enforcement agencies,NGOs, and safety advocates to help enforce our Guidelines. Suchexpert knowledge comes from sources such as theAnti-Defamation League, the Southern Poverty Law Center, theElection Integrity Partnership, the Atlantic Council, the StanfordCyber Policy Center, the members of Snap’s Safety AdvisoryBoard, and individual domain experts (including a formerAmbassador to the UN Human Rights Council, leading digitalrights scholars and advocates, former regulators andpolicymakers, and geopolitical experts). 93 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? We have an internal content crisis protocol that applies in theevent of major incidents that may give rise to significant elevatedrisk of Terrorism content on Snapchat. Transparency Taking awareness-raisingmeasures and adapting their onlineinterface in order to give recipientsof the service more information. Yes, we provide guidance on harms and how to get help in ourSafety Center. We make available robust reporting tools; and weprovide guidance to parents on the web (see below). Protection of Minors Taking targeted measures toprotect the rights of the child,including age verification andparental control tools, tools aimedat helping minors signal abuse orobtain support, as appropriate. Yes, we have protective measures to limit Teen contact withstrangers; we offer Family Center, reporting, and guidance. Ournew parents site provides additional guidance for parents andcaregivers on risks and support.50 Content Authenticity Ensuring that an item ofinformation, whether it constitutesa generated or manipulated image,audio or video that appreciablyresembles existing persons,objects, places or other entities orevents and falsely appears to aperson to be authentic or truthful isdistinguishable through prominentmarkings when presented on theironline interfaces, and, in addition,providing an easy to usefunctionality which enablesrecipients of the service to indicatesuch information. Yes, Snap has taken steps to mitigate the risk that (i) its generativeAI tools are used for creating illegal or otherwise violating contentand (ii) illegal or otherwise violating content created usinggenerative AI tools on any online platform are disseminated onSnapchat’s inscope services. Conclusion Despite terrorism falling within our lowest relative likelihood category, we consider the potentialrisk of the dissemination of Terrorist Content to be in the serious severity category due topotential for serious harm from exposure to Terrorist Content. As a result, terrorism falls within ourLevel 2 overall risk prioritisation category. 50 https://parents.snapchat.com. 94 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT We have traditionally considered that Snapchat’s design, deletion by default and proactivedetection measures make it a challenging environment for effective dissemination of TerroristContent on Snapchat’s in-scope services. We remain vigilant for any changes in use or increasedterrorism activity on our platform. We have concluded therefore that Snapchat’s in-scope services continue to have reasonable,proportionate and effective mitigation measures for dissemination of Terrorist Content, butwe will continue to closely monitor prevalence levels for this harm, amongst other indicators,to detect and manage any new or increased material terrorism threats on Snapchat. 4.1.5 Dissemination of content that infringes on intellectual property rights Section 4.1.5 (IP Infringement) addresses the risk of harm associated with users uploading anddistributing content that may infringe upon the intellectual property rights of others. Suchinfringing material could potentially surface on Snap’s public platforms, particularly within videosfeatured on Spotlight and Discover. Likelihood A joint EUIPO-Europol report in late 2024 highlighted that the widespread use of social mediaand influencers is acting as a catalyst for IP crime, by directly connecting consumers seekingcheap products with sellers of counterfeit or pirated goods.51 However, Snapchat’s platform architecture is fundamentally designed to limit the massdistribution of unauthorized copyrighted content. Unlike traditional content-sharing platforms thatemphasize public, persistent, and easily searchable content libraries, Snapchat prioritizesephemeral, user-to-user communication and short-lived public content. Stories and direct Snapsare time-limited and not easily redistributable, while public-facing features like Spotlight andDiscover are subject to content moderation, eligibility review, and recommendation algorithmsthat filter for originality and community standards. This architectural focus on transient, curatedsharing - combined with robust content detection and rights management mechanisms -significantly reduces the platform’s utility for large-scale copyright infringement. 51 EUIPO \& Europol, Uncovering the Ecosystem of Intellectual Property Crime - A focus on enablers and impact, url. 95 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Snap maintains a public Transparency Report which includes data on enforcement actions relatedto intellectual property infringement. According to our last Report covering the second half of2024: ● We received 1296 copyright notices; 96,8% of those requests led to the removal ofsome content. This compares with 1297 copyright notices - 57% of those requestsleading to the removal of some content - in the second half of 2024. ● We received 169 trademark notices; 60,9% of those requests led to the removal ofsome content. This compares with 203 trademark notices - 23% of those requestsled to the removal of some content - in the second half of 2024. This data shows no increases in reports of intellectual property issues and a consistently lowprevalence in absolute terms. Moreover, it is important to note that the percentage of requestsresulting in content removal is higher, which demonstrates Snap's prompt and effective responseto such reports. Considering the above, Snap continues to consider the likelihood ofencountering content that infringes intellectual property on Snapchat is within the lowestlikelihood category. Severity Intellectual property infringement does not generally involve (1) harms that risks significantdamage to the physical or emotional well-being of Snapchatters, or (2) imminent, credible risk ofsevere harm, including threats to human life, safety, and well-being. However, IP rights areprotected by international, EU and national laws. IP law provides protection to anyone whocreates works. This means that the creator of such a work is generally the only person allowed todecide on the exploitation of the works he has created. In addition, these works are protectedfrom misuse by others.52 Infringement upon trademarks or copyrights are considered to be illegalunder these laws and must therefore be prohibited. As per the findings of a 2021 reportpublished by the European Union Intellectual Property Office (EUIPO), instances of digital piracyhave demonstrated a decline across various content categories. However, it is noteworthy thatdespite this downward trend, the persistence of digital piracy continues to be a prevailing issuewithin the online domain.53 As a result, Snap tracks the dissemination of content that infringes onintellectual property rights to carry a risk of significant harm. DSA Risk Factors In accordance with Section 3 (Methodology), we have also taken into account, in particular,whether and how the following service risk factors referenced in Article 34(2) of the DSAinfluence the risk of this harm on Snapchat’s in-scope services. As set out below, while thefollowing risk factors could in principle influence this systemic risk, their overall impact is limitedgiven Snap’s existing mitigations, which are described later in this chapter and in Chapter 5. 53 EUIPO, ‘Online Copyright Infringement in the European Union’, December 2021, url. 52 See for example the Berner Convention, the Rome convention, TRIPS-agreement. 96 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Service Risk Factor How does it apply to Snapchat and this harm? (a) the design of recommendersystems and any other relevantalgorithmic system; Our recommender systems make it difficult for unvettedcontent to reach a broad audience without moderation.Snap’s algorithmic systems do not knowingly recommendcontent that infringes intellectual property rights, i.e. thereare no interest categories relating to specific intellectualproperty. Detailed information relating to our recommendersystems can be found in section 5 (see the AlgorithmicSystems sub-section). (b) content moderation systems; Snap has implemented specific proactive and reactivecontent moderation procedures to prevent and removecontent that infringes IP rights. Users can report copyrightand trademark infringement. We honor copyright laws andtake reasonable steps to expeditiously remove infringingmaterial from our Services, once we become aware of it. Seealso Section 5 on Moderation. (c) the applicable terms andconditions and enforcement; Our terms prohibit intellectual property infringements andSnap strictly enforces these terms. We provide moreinformation in section 5 (see the Terms and Enforcementsub-sections). (d) systems for selecting andpresenting advertisements; and Our advertising systems require agreement to advertisingpolicies and guidance that prohibit adverts from displayinginformation that violates the law (i.e. including copyright law)or causes certain harms. We check advertisers arecomplying with their obligations via our advertising reviewprocess. Our advertising systems use a mix of automationand human review to review adverts before they arepublished. We provide easy mechanisms for users to hideand report advertisements that violate our policies or the law.We monitor ad rejection, reporting and enforcement data tomonitor the effectiveness of our approach. We provide moreinformation in Section 5 (see the Advertising Systemssub-section). (e) our data related practices We have strong data principles, practices and privacy, safetyand security by design processes. We provide moreinformation in Section 5 (see the Transparency sub-section)and Section 6 (see the Platform Principles Framework andPrivacy and Safety by Design subsections). 97 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT We have also analysed whether and how the risk of this harm is influenced by the followinggeneral factors: General Risk Factor How does it apply to Snapchat and this harm? 98 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Terms and Enforcement Adapting their terms and conditionsand their enforcement. Yes, terms prohibit IP infringements and they are strictlyenforced. If someone believes that any content on Snapchat infringestheir intellectual property (IP), they can report it via Snap’sreporting menu or online forms for Copyright Infringement orTrademark Infringement. Snap takes reasonable steps to expeditiously remove fromour Services any infringing material that we become aware of. If Snap becomes aware that a user has repeatedly infringedcopyrights, we will take reasonable steps to enforce againstthe violator’s account, in accordance with our terms. Moderation Adapting content moderationprocesses, including the speed andquality of processing notices related tospecific types of illegal content and,where appropriate, the expeditiousremoval of, or the disabling of accessto, the content notified, in particular inrespect of illegal hate speech or cyberviolence, as well as adapting anyrelevant decision-making processesand dedicated resources for contentmoderation. Yes, specific reactive moderation procedures to expeditiouslyremove content that infringes intellectual property rights. Snap respects the doctrine of “fair use” (when applicable) i.e.,that there are certain circumstances (such as news reporting,social commentary on issues of public interest, criticism,parody, or education) where copyrighted material could bedistributed without permission from, or payment to, thecopyright holder. Algorithmic Systems Testing and adapting their algorithmicsystems, including their recommendersystems. Our algorithmic systems do not knowingly recommendcontent that infringes intellectual property rights, i.e. there areno interest categories relating to specific intellectual property. Advertising Systems Adapting their advertising systems andadopting targeted measures aimed atlimiting or adjusting the presentation ofadvertisements in association with theservice they provide. Yes, other mitigations listed here also apply to our AdvertisingSystems. Ongoing Risk Detection andManagement Reinforcing the internal processes,resources, testing, documentation, orsupervision of any of their activities in Yes, we have a notice procedure to flag and enable us torespond to intellectual property infringements. 100 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT particular as regards detection ofsystemic risk. Trusted Flaggers Initiating or adjusting cooperation withtrusted flaggers in accordance withArticle 22 and the implementation ofthe decisions of out-of-court disputesettlement bodies pursuant to Article21. In the EU, we have collaborated with the Austrian Institute forApplied Telecommunications, the Austrian ProtectionAssociation against unfair competition and LSGWahrnehmung von Leistungsschutzrechten GmbH. We also collaborate with The Copyright Information andAnti-Piracy Centre (CIAPC) in Finland, Rettigheds Alliancen inDenmark, ALPA (Association de Lutte Contra la PiraterieAudiovisuelle) in France. Codes and Crisis Protocols Initiating or adjusting cooperation withother providers of online platforms or ofonline search engines through thecodes of conduct and the crisisprotocols referred to in Articles 45 and48 respectively. Not applicable. We respond to reports of infringement on anindividual basis. Transparency Taking awareness-raising measuresand adapting their online interface inorder to give recipients of the servicemore information. Yes, we warn users not to publish content that infringes onintellectual property rights and we have an easily accessiblereporting tool. Protection of Minors Taking targeted measures to protectthe rights of the child, including ageverification and parental control tools,tools aimed at helping minors signalabuse or obtain support, asappropriate. General measures relating to the protection of minors for thisrisk. Content Authenticity Ensuring that an item of information,whether it constitutes a generated ormanipulated image, audio or video thatappreciably resembles existingpersons, objects, places or otherentities or events and falsely appears toa person to be authentic or truthful isdistinguishable through prominentmarkings when presented on theironline interfaces, and, in addition,providing an easy to use functionality Yes, Snap has taken steps to mitigate the risk that (i) itsgenerative AI tools are used for creating illegal or otherwiseviolating content and (ii) illegal or otherwise violating contentcreated using generative AI tools on any online platform aredisseminated on Snapchat’s inscope services. 101 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT which enables recipients of the serviceto indicate such information. Conclusion We consider the overall risk of the dissemination of IP infringing content to be significant. Snaphas taken steps to mitigate these harms, which has substantially diminished the likelihood thatSnapchatters will encounter IP infringing material. These mitigations include product and designmeasures like short content retention periods, some proactive moderation, andnotice-and-takedown procedures. We have concluded therefore that Snapchat’s in-scope services have reasonable,proportionate and effective mitigation measures for dissemination of content that infringesintellectual property rights. There is no change in this conclusion since our 2024 Report. 4.1.6 Dissemination of Adult Sexual Content This Section 4.1.6 (Adult Sexual Content) considers the risk of harm arising from Adult SexualContent (as described in the Harm Description below) on Snapchat’s in-scope services defined in Section 2 (Scope). We have assessed this risk in accordance with the Section 3 (Methodology) as follows. Harm Description This section addresses pornographic content as well as commercial activities that relate topornography or sexual interactions (whether online or offline), including the action of sendingunsolicited explicit images or videos. Breastfeeding and other depictions of adult nudity innon-sexual contexts are generally permitted. We provide a summary and explanation of ‘Adult Sexual Content’ in our explainer on SexualContent and in our Transparency Report Glossary. Likelihood We have considered the likelihood of this harm in line with Section 3 (Methodology) andobserved the following for 2025: ● Estimates as to the volume of Adult Sexual Content on the Internet vary, but somehistorical studies have considered that around 4% of websites, 13% of web searches and20% of mobile searches were related to Adult Sexual Content.54 As such it is conceivablethat this content could also appear on any of Snapchat’s in-scope services including in 54 Ogas, O. and S. Gaddam (2012), Boston University, A Billion Wicked Thoughts: What the Internet Tells Us About Sexand Relationships; and Google Inc, Columbia University and Carnegie Mellon University, A Large Scale Study ofWireless Search Behaviour, 2005. 102 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Severity The European Union Agency for Human Rights57 flagged that sexual offences – i.e., unlawful actsthat result in the sexual exploitation and sexual abuse of a person – pose a significant threat tohuman life and well-being. The United Nations Office58 stated that sexual offences represent anabuse of people’s fundamental rights and dignity and involve the criminal exploitation ofvulnerable people. Research on the effects of pornography has shown that pornographycontributes to shaping people’s mindsets on sexuality and on their perceptions of gender roles.Research has also suggested a link between online pornography consumption and increasedphysical and/or verbal violence against women59. The European Commission60 also flagged that,especially in relation to Teens, seeing pornography at early ages, online pornographic contentcan affect their views of what constitutes a healthy relationship. According to the Council ofEurope’s Parliamentary Assembly61, pornography often engenders and perpetuates stereotypesand that this undermines gender equality and women’s self-determination. The risk of harm to individuals that results from Adult Sexual Content varies considerably. Sexualoffences i.e. unlawful acts that result in the sexual exploitation and sexual abuse of a person62, pose a significant threat to human life and well-being, abusing people’s fundamental rights anddignity and involving the criminal exploitation of vulnerable people.63 Reports show thattraffickers misuse technology throughout all stages of human trafficking and for all types ofexploitation including sexual exploitation and forced labour.64 Eurostat reports an increase in thenumber of registered victims of human trafficking in the EU with a 10% increase in 2021 (7155).People who have not given consent to the sharing of their sexual or nude content are exposed tounique forms of abuse including the nonconsensual distribution of their content, doxing andbeing coerced into performing sexual acts.65 Snap therefore considers the severity risk of AdultSexual Content to be serious. We consider the spread of sexually explicit content or depictions of nudity in which the primaryintention is sexual arousal to be significantly harmful on our platform. Research on the effects ofpornography has shown that pornography contributes to shaping people’s mindsets on sexualityand on their perceptions of gender roles.66 Especially in relation to Teens, seeing pornography atearly ages, online pornographic content can affect their views of what constitutes a healthy 66 M. Guggisberg, Harms associated with online pornography consumption, url. 65 MCSA, Sex Workers in the Digital Era, url. 64 United Nations Office on Drugs and Crime, ‘Global report on trafficking in persons 2022’, url, 2022, p. 70. 63 Europol, ‘Trafficking in human beings’, url, retrieved on 8 August 2023. 62 European Union Agency for Human Rights, Sanctions for sexual offences, url. 61 Council of Europe, Parliamentary Assembly, Gender aspects and human rights implications of pornography(Resolution Resolution 2412 (2021)), url, 26 November 2021. 60 European Commission, A Digital Decade for children and youth: the new European strategy for a better internet forkids (BIK+) COM(2022) 212 final, p. 5. url, 11 May 2022. 59 G. M. Hald, N. M. Malamuth, and C. Yuen, Pornography and attitudes supporting violence against women: Revisitingthe relationship in nonexperimental studies. Aggressive Behavior 36 2010, url. Lamb \& Koven 2019, p. 4.https://pace.coe.int/en/files/29579/html. 58 Europol, ‘Trafficking in human beings’, url, retrieved on 8 August 2023. 57 European Union Agency for Human Rights, Sanctions for sexual offences, url. 105 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT relationship.67 In their resolution on violent and extreme pornography, the Council of Europe’sParliamentary Assembly has stated that pornography often engenders and perpetuatesstereotypes and that this undermines gender equality and women’s self-determination.68 Research has also suggested a link between online pornography consumption and increasedphysical and/or verbal violence against women.69 Content can depict the objectification,humiliation, and degradation of men and/or women, as well as explicit sex scenes involvingrape.70 As a result, we consider the severity risk of pornography to be significant. DSA Risk Factors In accordance with Section 3 (Methodology), we have also taken into account, in particular,whether and how the following service risk factors referenced in Article 34(2) of the DSAinfluence the risk of this harm on Snapchat’s in-scope services. As set out below, while thefollowing risk factors could in principle influence this systemic risk, their overall impact is limitedgiven Snap’s existing mitigations, which are described later in this chapter and in Chapter 5. Service Risk Factor How does it apply to Snapchat and this harm? (a) the design of recommendersystems and any otherrelevant algorithmic system; Our recommender systems are not designed to recommend AdultSexual Content – i.e., there is no ‘Adult Sexual Content’ interestcategory. Detailed information regarding the mitigations relating toour recommender systems can be found in Section 5 (see theAlgorithmic Systems sub-section). (b) content moderation systems; Snap has implemented specific proactive and reactive moderationprocedures to prevent and remove Adult Sexual Content. Asexplained in the Content Moderation Section, Snap deploys arange of automated content moderation (which includes abusivelanguage detection, other keyword-based detection, andmachine-learning-based proactive detection) to scan mediauploads. Text and symbol classifiers are trained on Adult SexualContent signals. We provide more information in Section 5 (seeContent Moderation sub-section). (c) the applicable terms andconditions and enforcement; Our Community Guidelines (which form part of our terms ofservice) prohibit Adult Sexual Content for all users (both adult andTeen accounts) and they are strictly enforced. We provide moreinformation in Section 5 (see the Terms and Enforcement 70 A.J. Bridges, ‘Pornography and sexual assault’, in W.T. O’Donohue \& P. A. Schewe (eds.), Handbook of Sexual Assaultand Sexual Assault Prevention, 2019, p. 129-150. 69 G. M. Hald, N. M. Malamuth, and C. Yuen, Pornography and attitudes supporting violence against women: Revisitingthe relationship in nonexperimental studies. Aggressive Behavior 36 2010, url. Lamb \& Koven 2019, p. 4. 68 Council of Europe, Parliamentary Assembly, Gender aspects and human rights implications of pornography (Resolution Resolution 2412 (2021)), url, 26 November 2021. 67 European Commission, A Digital Decade for children and youth: the new European strategy for a better internet forkids (BIK+) COM(2022) 212 final, p. 5. url, 11 May 2022. 106 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT sub-sections). (d) systems for selecting andpresenting advertisements;and Our advertising systems require agreement to advertising policiesand guidance that prohibit adverts from displaying information thatviolates the law or causes certain harms. We check advertisers arecomplying with their obligations via our advertising review process.Our advertising systems use a mix of automation and humanreview to review adverts before they are published. We provideeasy mechanisms for users to hide and report advertisements thatviolate our policies or the law. We monitor ad rejection, reportingand enforcement data to monitor the effectiveness of ourapproach. We provide more information in Section 5 (see theAdvertising Systems sub-section). (e) our data related practices We have strong data principles, practices and privacy, safety andsecurity by design processes. We provide more information inSection 5 (see the Transparency sub-section) and Section 6 (seethe Platform Principles Framework and Privacy and Safety byDesign subsections. We have also analysed whether and how the risk of Adult Sexual Content is influenced by thefollowing general factors: Service Risk Factor How does it apply to Snapchat and this harm? Intentional manipulation, includinginauthentic use or inauthentic useor automated exploitation of theservice There are two key ways in which we consider our systems couldbe manipulated:(1) Users could seek to share novel illegal and violatingmaterial that is not detected by our automated systems.We are constantly working to adjust our systems andpolicies to address this. We provide more information onour approach in Section 5 (in particular the ContentModeration subsection) and Section 6 (Ongoing RiskDetection and Management).(2) Users could abuse our content moderation processes andreport non-violating content / accounts in bad faith. Wehave processes to combat misuse and more informationcan be found in Section 5 (Content Moderation andEnforcement subsections). Amplification and potentially rapidand wide dissemination of illegalcontent and of information that is Snapchat’s inscope services have a number of features and designconfigurations that act to limit the amplification and potentiallyrapid and wide dissemination of Adult Sexual Content, 1. Snap makes it difficult for unvetted content to reach a 107 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? Snapchatters can report Adult Sexual Content to us via in-appreporting options and anyone can submit a report through theSnapchat Support Site. Our in-app reporting tool allows users todirectly report the promotion, distribution or sharing of pornographiccontent as well as commercial activities that relate to pornography orsexual interactions (whether online or offline). We promptly enforce against accounts found to be sending AdultSexual Content: ● Snap removes such content from Snapchat. ● Snap promptly disables accounts that we determine arededicated to sharing such content, engage in multipleviolations involving Adult Sexual Content within a definedperiod, or engage in a serious violation involving Adult SexualContent. ● Where appropriate, for example when there is an imminentthreat to human life, safety or wellbeing, accounts engaging inviolation of these policies may be reported to lawenforcement. Moderation Adapting content moderationprocesses, including thespeed and quality ofprocessing notices related tospecific types of illegal contentand, where appropriate, theexpeditious removal of, or thedisabling of access to, thecontent notified, in particular inrespect of illegal hate speechor cyber violence, as well asadapting any relevantdecision-making processesand dedicated resources forcontent moderation. Yes, we have specific proactive and reactive moderation proceduresto prevent and remove Adult Sexual Content. As explained in the Content Moderation section in Section 5, Snap deploys a range ofautomated content moderation (which include abusive languagedetection, other keyword-based detection, andmachine-learning-based proactive detection models) to scan Storiesand Spotlight submissions. Text and symbol classifiers are trained onAdult Sexual Content signals. Algorithmic Systems Testing and adapting theiralgorithmic systems, includingtheir recommender systems. Unlike many of our peers, Snapchat does not offer an open news feedwhere unvetted publishers or individuals have an opportunity tobroadcast Adult Sexual Content, does not offer a broad ‘reshare’functionality that would encourage virality, and does not allowuser-generated content to be recommended to a wide audiencewithout going through further review. 110 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? Our algorithmic systems are not designed to recommend Adult SexualContent – i.e., there is no ‘Adult Sexual Content’ interest category. Inaddition, our platform has been designed to limit the prevalence ofsexually suggestive content. As explained in the Moderation Section of our Existing Mitigations inSection 5, on Spotlight and Discover, we take a proactive approach tomoderating any content that may violate our rules against AdultSexual Content prior to the content being recommended to a wideaudience. Advertising Systems Adapting their advertisingsystems and adoptingtargeted measures aimed atlimiting or adjusting thepresentation ofadvertisements in associationwith the service they provide. Other mitigations listed here also apply to our Advertising Systems. Ongoing Risk Detection andManagement Reinforcing the internalprocesses, resources, testing,documentation, or supervisionof any of their activities inparticular as regards detectionof systemic risk. For example we have specific prevalence testing and transparencyreporting which we use to help evaluate and manage Adult SexualContent. Trusted Flaggers Initiating or adjustingcooperation with trustedflaggers in accordance withArticle 22 and theimplementation of thedecisions of out-of-courtdispute settlement bodiespursuant to Article 21. We cooperate with trusted flaggers in relation to Non-ConsensualIntimate Image Abuse (NCII), notably Stop Fisha in France. Codes and Crisis Protocols Initiating or adjustingcooperation with otherproviders of online platforms We cooperate with other providers through various industry groups,including in particular the EU Internet Forum (EUIF) which hasexpanded its remit to also tackle the trafficking of human beings(which is often driven by sexual crimes or pornography). 111 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? or of online search enginesthrough the codes of conductand the crisis protocolsreferred to in Articles 45 and48 respectively. Transparency Taking awareness-raisingmeasures and adapting theironline interface in order togive recipients of the servicemore information. We provide guidance on harms and how to get help in our SafetyCenter. We make available robust reporting tools; and we provideguidance to parents on the web (see below). Protection of Minors Taking targeted measures toprotect the rights of the child,including age verification andparental control tools, toolsaimed at helping minors signalabuse or obtain support, asappropriate. Snap also takes steps to limit the prevalence of sexually suggestivecontent. For example, Spotlight has been designed not to distributesexually suggestive content to 13 - 17 Snapchat accounts and onlyrecommends sexually suggestive content to an 18+ Snapchat accountif that content has been created by a creator that the account hassubscribed to or favorites suggestive content. No viewer (who is over18 years old) who has opted in to seeing sexually suggestive contentis intended to see more than one sexually suggestive content videoout of seven in their Spotlight feed. If a user hides a video labeled assexually suggestive, we stop showing them that type of content. If auser hides a creator, we stop showing them that creator. Content Authenticity Ensuring that an item ofinformation, whether itconstitutes a generated ormanipulated image, audio orvideo that appreciablyresembles existing persons,objects, places or otherentities or events and falselyappears to a person to beauthentic or truthful isdistinguishable throughprominent markings whenpresented on their onlineinterfaces, and, in addition,providing an easy to usefunctionality which enables Snap has taken steps to mitigate the risk that (i) its generative AI toolsare used for creating illegal or otherwise violating content and (ii)illegal or otherwise violating content created using generative AI toolson any online platform are disseminated on Snapchat’s inscopeservices. 112 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? recipients of the service toindicate such information. Conclusion All forms of Adult Sexual Content now fall within our lowest relative likelihood category. We treatsexual crimes as a Level 2 overall risk prioritization given the risk of serious harm, and otherforms of Adult Sexual Content as Level 3 overall risk prioritization given the risk of significantharm. We have continued to dedicate substantial resources and taken significant steps tomitigate these risks, including further improvements to our proactive detection mechanisms. Thishas resulted in further substantial decreases in the prevalence rates for Adult Sexual Content,which demonstrates the effectiveness of our ongoing risk detection and management frameworkand procedures. We continue to work towards further reductions in the prevalence and enforcedcontent percentages for Adult Sexual Content. We continue to conclude that Snapchat’s in-scope services have reasonable, proportionateand effective mitigation measures for dissemination of Adult Sexual Content. As this remainsour highest prevalence violating category on Snapchat’s in-scope services, we will continue tocarefully monitor to achieve further falls in prevalence. 4.1.7 Dissemination of Content regarding Harassment and Bullying This Section 4.1.7 (Harassment and Bullying) considers the risk of harm arising from harassment,bullying and stalking (as described in the Harm Description below) on Snapchat’s in-scopeservices. Snap defines harassment as any unwanted behavior that could cause an ordinary person toexperience emotional distress, including bullying, verbal abuse, including certain threateningbehavior. The following behaviors are examples of harassment: ● Aggressive or profane name-calling. ● Shaming or embarrassing imagery directed at a person’s physical appearance,disabilities, or cognitive abilities. ● Using a new account to contact someone after previously being blocked by them. ● Attempts at intimidation. ● “Gossip girl” types of accounts whose primary purpose is to anonymously bully orshame individuals who are typically known to the account’s followers. 113 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ● When we consider Snapchat’s in-scope services specifically, i.e. the public parts of Snapchatwhich fall within the scope of the risk assessment obligations under Article 34, the likelihood ofthese public spaces being used for the dissemination of bullying \& harassment content is evenlower. As a result, in respect of Snapchat’s online platforms within the scope of our DSA risk assessmentonly, we consider Harassment and Bullying to now fall within our lowest likelihood category. Severity We are sensitive to the reality that Harassment and Bullying are serious issues that mayundermine mental health and, in the worst instances, contribute to self-harm and suicide. RecentEU studies reveal a troubling rise in online Harassment and Bullying, with young people, women,and minorities disproportionately affected. According to the European Union Agency forFundamental Rights (FRA), 14% of people in the EU have experienced cyber harassment orbullying in the past five years.71 71 European Union Agency for Fundamental Rights, Online Content Moderation: Current Challenges in Detecting HateSpeech, url, 2023. 115 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Moreover, and as highlighted in our prior reports,the UN Special Representative of theSecretary-General on Violence Against Children recognizes that cyberbullying can inflictsubstantial harm, on Teens in particular, by extending its impact through the ability of reaching abroad audience at any time. The UN considers that technology amplifies the severity ofharassment and bullying. Bullying, either on- or offline, is of major concern for children globallywith varying rates across different countries.72 Furthermore, the 2023-2024 Trends and UsageReport by CyberSafeKids reported that 21% of 12-14 year olds involved in their investigation hadbeen “bothered or upset by something seen or experienced online”. Of this group, 41% werebothered or upset by something seen or experienced on Snapchat.73 Where Harassment and Bullying involve both (1) harms that risk significant damage to the physicalor emotional well-being of Snapchatters, and (2) the imminent, credible risk of severe harm,including threats to human life, safety, and well-being, we treat this as a severe harm. In general,Snap qualifies Harassment and Bullying as ‘serious’ in terms of severity. DSA Risk Factors In accordance with Section 3 (Methodology), we have also taken into account, in particular,whether and how the following service risk factors referenced in Article 34(2) of the DSAinfluence the risk of this harm on Snapchat’s in-scope services. As set out below, while thefollowing risk factors could in principle influence this systemic risk, their overall impact is limitedgiven Snap’s existing mitigations, which are described later in this chapter and in Chapter 5. Service Risk Factor How does it apply to Snapchat and this harm? (a) the design ofrecommender systemsand any other relevantalgorithmic system; Where we algorithmically recommend content on our onlineplatforms, we take proactive measures to stop the dissemination ofcontent that includes Harassment and Bullying. Our algorithmicsystems do not knowingly recommend Harassment and Bullying –i.e., there is no “Harassment and Bullying” interest category.Harassing content violates our Community Guidelines, is removedfrom Snapchat, and is therefore not eligible for algorithmicrecommendation. Detailed information regarding the mitigationsrelating to our recommender systems can be found in Section 5(see the Algorithmic Systems sub-section). (b) content moderationsystems; We have specific moderation procedures to prevent and removeHarassment and Bullying content. We use a mix of automation(such as abusive language detection, image recognition models,and account history) and human review to enforce our guidelinesas explained in Section 5 of this Report (see the Moderationsub-section). Content on Snapchat can be reported in-app or on 73 CyberSafeKids, Trends and Usage Report Academic Year 2023-2024, p. 4 (URL). 72 UN Special Representative of the Secretary-General on Violence Against Children, ‘Bullying and Cyberbullying’, url. 116 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT our web site, and “harassment” is one of the reporting reasonsoffered. (c) the applicable terms andconditions andenforcement; Our terms prohibit harassment and bullying. This is explained tousers clearly in our Harassment and Bullying explainer withguidance on how we apply this policy. In Section 5 (see sub-sectionon Enforcement), we also explain the significant resources devotedto preventing the dissemination of content that includesHarassment and Bullying and how we strictly enforce our terms. (d) systems for selecting andpresentingadvertisements; and Other mitigations listed here also apply to our Advertising Systemsin relation to content regarding harassment and bullying. Weprovide more information in Section 5 (see the Advertising Systemssub-section). (e) our data related practices We have strong data principles, practices and privacy, safety andsecurity by design processes. We provide more information inSection 5 (see the Transparency sub-section) and Section 6 (seethe Platform Principles Framework and Privacy and Safety byDesign subsections). We have also analysed whether and how the risk of this harm is influenced by the followinggeneral factors: General Risk Factor How does it apply to Snapchat and this harm? 117 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Overall potential risk prioritization Our investigations have shown that Harassment and Bullying content falls within our lowestlikelihood category for Snapchat’s in-scope services. This is a change from our 2024 Reportwhen we assessed such content to fall within our medium likelihood category. However, as thiscontent remains one of our higher prevalence issues; there remains significant societal concern 118 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Mitigation Category Applies to this risk? Adapting the design, features or functioningof their services, including their onlineinterfaces. constituting Harassment and Bullying can be easilyreported. Terms and Enforcement Adapting their terms and conditions andtheir enforcement. Yes, our terms prohibit Harassment and Bullying. This isexplained to users clearly in our Harassment and Bullyingexplainer with guidance on how we apply this policy. Inour Enforcement section, we also explain the significantresources devoted to preventing the dissemination ofcontent that includes Harassment and Bullying and howwe strictly enforce our terms. Moderation Adapting content moderation processes,including the speed and quality ofprocessing notices related to specific typesof illegal content and, where appropriate,the expeditious removal of, or the disablingof access to, the content notified, inparticular in respect of illegal hate speechor cyber violence, as well as adapting anyrelevant decision-making processes anddedicated resources for contentmoderation. Yes, we have specific moderation procedures to preventand remove Harassment and Bullying content. We use amix of automation (such as abusive language detection,image recognition models, and account history) andhuman review to enforce our guidelines as explained inthe Content Moderation Section of this Report. Contenton Snapchat can be reported in-app or on our web site,and “harassment” is one of the reporting reasons offered. Algorithmic Systems Testing and adapting their algorithmicsystems, including their recommendersystems. Yes, where we algorithmically recommend content on ouronline platforms, we take proactive measures to stop thedissemination of content that includes Harassment andBullying. Our algorithmic systems do not knowinglyrecommend Harassment and Bullying – i.e., there is no“Harassment and Bullying” interest category. 120 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Mitigation Category Applies to this risk? Advertising Systems Adapting their advertising systems andadopting targeted measures aimed atlimiting or adjusting the presentation ofadvertisements in association with theservice they provide. Yes, other mitigations listed here also apply to ourAdvertising Systems. Ongoing Risk Detection and Management Reinforcing the internal processes,resources, testing, documentation, orsupervision of any of their activities inparticular as regards detection of systemicrisk. Yes, for example we have specific prevalence testing andmonitoring moderation and enforcement data which weuse to help detect and manage Harassment and Bullyingrisk. Our Safety Advisor Board also has severalanti-bullying experts which we call on for independentreview and expertise. Trusted Flaggers Initiating or adjusting cooperation withtrusted flaggers in accordance with Article22 and the implementation of the decisionsof out-of-court dispute settlement bodiespursuant to Article 21. Yes, we cooperate with many trusted flaggers in the EU.For example, Snap partners with the Bee Secure helplinein Luxembourg , with E-Enfance 3018 in France, and theDanish Centre for Digital Youth Care (CfDP). Codes and Crisis Protocols Initiating or adjusting cooperation with otherproviders of online platforms or of onlinesearch engines through the codes ofconduct and the crisis protocols referred toin Articles 45 and 48 respectively. Snap is a member of a number of EU trade associationsto contribute to the policy debate to support thedevelopment of a proportionate regulatory framework topromote online safety. Also, Snap has set up a number of crisis managementprotocols to help the organization swiftly tackleunexpected incidents and help minimize their impact onour service, users and operations. Transparency Taking awareness-raising measures andadapting their online interface in order togive recipients of the service moreinformation. Yes, we provide guidance on our terms, harms,moderation and enforcement practices, as well as how toget help in our Safety Center and via in-app resources(Here For You and Safety Snapshot). We have partneredwith local organisations, such as the Diana Award, toraise awareness of Harassment and Bullying. Protection of Minors Taking targeted measures to protect therights of the child, including age verificationand parental control tools, tools aimed athelping minors signal abuse or obtainsupport, as appropriate. Yes, we have protective measures to limit teen contactwith strangers; we offer Family Center; we make availablerobust reporting; and we provide guidance to parents andteens, including the safety measures and resourceshighlighted in the Transparency mitigation section above,such as the Harassment and Bullying explainers. 121 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Mitigation Category Applies to this risk? Our parents site provides additional guidance for parentsand caregivers on risks and support.74 Content Authenticity Ensuring that an item of information,whether it constitutes a generated ormanipulated image, audio or video thatappreciably resembles existing persons,objects, places or other entities or eventsand falsely appears to a person to beauthentic or truthful is distinguishablethrough prominent markings whenpresented on their online interfaces, and, inaddition, providing an easy to usefunctionality which enables recipients of theservice to indicate such information. General content authenticity measures taken in respectof Harassment and Bullying. Snap has taken steps tomitigate the risk that (i) its generative AI tools are used forcreating illegal or otherwise violating content and (ii)illegal or otherwise violating content created usinggenerative AI tools on any online platform aredisseminated on Snapchat’s inscope services. Thisincludes applying an AI sparkle icon in specific situations,such as our Bitmoji Backgrounds. We continue to assesswhether to include such an icon on a case-by-case basis,considering whether generated images are photorealistic. Conclusion Harassment and Bullying remains one of our higher prevalence issues. There also remainssignificant societal concern regarding the issue of Harassment and Bullying (although this oftenconcerns out of scope services such as private messaging). Given these factors and the severityof the harm that can result in some Harassment and Bullying cases (which we consider to beserious), we consider the dissemination of content on Snapchat’s in-scope services to have a Level 2 overall risk prioritisation level. Note: As with other harms, where there is an imminentrisk of severe harm from Harassment and Bullying, this category is treated as an overall Level 1potential risk. We have taken significant measures to prevent harassment and bullying, including clear guidanceon our rules and how we enforce them, easy to access reporting tools and rapid response timesto address violating content. Our investigations have shown the prevalence of Harassment andBullying on Snapchat’s in-scope services has continued to fall,While we see higher reports of Harassment and Bullyingrelating to out-of -scope services, such as private messaging, we have confirmed that relativelyfew enforcement cases relate to Snapchat’s in-scope services. As a result, we have moved therelative likelihood of Harassment and Bullying on Snapchat’s in-scope services from medium tolowest likelihood. 74 Snapchat Family Safety Hub, url. 122 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT As a result, we have concluded that Snapchat’s in-scope services have reasonable,proportionate and effective mitigation measures for dissemination of Harassment andBullying content. 4.1.8 Dissemination of content that glorifies Self-Harm, including Suicide This Section 4.1.8 (Self-Harm \& Suicide) considers the risk of harm arising from Self-Harm andSuicide content (as described in the Description below) on Snapchat’s in-scope services. Harm Description Self-harm and Suicide refers to content relating to suicide We provide a summary and explanation of ‘Self-Harm and Suicide’ in our explainer on Threats,Violence and Harm and our Transparency Report Glossary. Likelihood The risk of young people encountering content that promotes glorifies self-harm, including thepromotion of self-injury, suicide, eating disorders, body image dissatisfaction and distorted valuesand attitudes online and on social media in general has been identified in several studies. Forexample, a recent study by the European Parliament’s Culture and Education (CULT) Committeehighlighted the risk of young people encountering such material.75 Research published at thebeginning of the year by Reset (currently led by former Hillary Clinton advisor Ben Scott) indicatesthat some online platforms have a high prevalence of harmful content such as pro-restrictiveeating disorder and pro-suicide/self-harm material and a lack of appropriate mitigationmeasures.76 76 Reset research on risks to minors and DSA compliance, 16 Jan 2024, https://www.reset.tech/ 75 European Parliament, requested by the CULT Committee, ‘The influence of social media on the development ofchildren and young people’, url, 2023. 123 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT We have taken note of the Samaritans’ Report on experiences with self-harm on social media,which found that platforms such as Instagram and TikTok often recommend self‑harm content on“Explore” or “For You” around 83% of the time—without user intent.77 While Snapchat was notmentioned, we take these signals seriously. Furthermore, A Sky article cites a statement from theMolly Rose Foundation criticizing Snap for failing to identify remove sufficient content related tosuicide and self-harm. The foundation’s criticism is based on Snap’s Statements of Reasons sentto the Commission’s Transparency API, as well as Snap’s Transparency Report. It observed thatonly 2% of reported sSelf-Harm and Suicide content on Snapchat was taken down betweenJanuary and July of last year.78 We disagree with the foundation’s findings which are based on anassumption that Snapchat poses the same risk as other platforms and therefore should beexpected to have the same level of enforcement. It does not take into account the effectivenessof Snapchat’s design and mitigations in preventing the wide-spread dissemination of this suchviolating content on Snapchat’s in-scope services. Since our 2024 Report, our Transparency Report continues to show that “Self-Harm \& Suicide” isan issue that still leads to a moderate volume of content and account enforcements. In thesecond half of 2024, we received 307,660 reports related to Self-Harm and Suicide (up from188,124,785 reports in the second half of 2023), enforcing against approximately 32,841 pieces ofcontent and 13,885 accounts. However, as we noted in the 2024 Report, those figures relate toSnapchat in general. When we consider Snapchat’s in-scope services specifically, i.e. the publicparts of Snapchat which fall within the scope of the risk assessment obligations under Article 34,the likelihood of these public spaces being used for the dissemination of content that glorifiesSelf-Harm is very low. As in 2024, we rejected far fewer Snaps on Spotlight and Discover andtherefore we consider the moderate enforcement rates for Harassment and Bullying primarilyconcern services that are out of scope of this Report. Moreover, when content related to this specific harm was detected (whether proactively throughautomated tools or reactively following a user report), our Safety teams were generally able to actswiftly to verify and enforce violating content. According to our latest European UnionTransparency Report (covering the second half of 2024), the median turnaround time forenforcement action in response to proactive or reactive detections of this content was 17minutes. 78 News Sky, Snapchat ‘asleep at the wheel when it comes to suicide and self-harm content’ says childrens charity”, 13January 2025 URL. 77 Samaritans Report (2022) How social media users experience self-harm and suicide content 124 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT As a result, we consider the risk of dissemination of content glorifying Self-Harm and Suicide tofall within our lowest likelihood category for Snapchat’s in-scope services. Severity The extent of the harm risked by content glorifying self-harm is significant. In relation to contenton social media in general, historical reports have indicated a particular impact this content canhave on the mental health of Teens.79 While social media and other online services may not causeself-harm, there is a potential for content glorifying self-harm to potentially trigger an existingvulnerability, such as an eating disorder.80 We note also that in May 2023 the (US) SurgeonGeneral’s Advisory issued a warning regarding social media and youth mental health, in particularwith regards to exposure to hate-based content and suicide/self-harm-related material.81 As a result, we consider the severity of harm risked from Self-Harm and Suicide (including contentrelating to self-injury, suicide or eating disorders) to be “serious”, Where the dissemination ofcontent that indicates an imminent, credible risk of severe harm, including threats to human life,safety, and well-being, we consider the severity of harm risked to be severe (as explained in our severe harm explainer) In practice, we devote enforcement resources to preventing thedissemination of content that glorifies Self-Harm, including the promotion of self-injury, suicide oreating disorders. 81 https://www.hhs.gov/sites/default/files/sg-youth-mental-health-social-media-advisory.pdf 80 The New York Times, ‘Eating Disorders and Social Media Prove Difficult to Untangle’, url, October 2021. Note GroupChats are private messaging groups, and do not qualify as an online platform. 79 The Guardian, ‘Facebook aware of Instagram’s harmful effect on teenage girls, leak reveals’, url, 14 September 2021;E. Bozola e.a., ‘The Use of Social Media in Children and Adolescents: Scoping Review on the Potential Risks’, url, August 2022.; A.M. Memom e.a., ‘The role of online social networking on deliberate self-harm and suicidality inadolescents: A systematized review of literature’, url, October 2018. 125 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT DSA Risk Factors In accordance with Section 3 (Methodology), we have also taken into account, in particular,whether and how the following service risk factors referenced in Article 34(2) of the DSAinfluence the risk of this harm on Snapchat’s in-scope services. As set out below, while thefollowing risk factors could in principle influence this systemic risk, their overall impact is limitedgiven Snap’s existing mitigations, which are described later in this chapter and in Chapter 5. Service Risk Factor How does it apply to Snapchat and this harm? (a) the design ofrecommendersystems and anyother relevantalgorithmic system; On Snapchat’s services where we algorithmically recommend content, wetake proactive measures to stop the dissemination of content that glorifiesSelf-Harm and Suicide, including the promotion of self-injury, suicide oreating disorders. Self-Harm and Suicide content violates our CommunityGuideline, is removed from Snapchat, and is therefore not eligible foralgorithmic recommendation. Our algorithmic systems do not knowinglyrecommend content glorifying Self-Harm i.e. there is no ‘glorifying self-harm’interest category. Detailed information regarding the mitigations relating to our recommendersystems can be found in Section 5 (see the Algorithmic Systems sub-section) (b) content moderationsystems; We have specific proactive and reactive moderation procedures to preventand remove content that promotes Self-Harm and Suicide. We use a mix ofautomation (such as abusive language detection, image recognition models,and account history) and human review to enforce our guidelines. Wecontinue to make improvements to our proactive detection tools, includingwith respect to Self-Harm and Suicide content, to help ensure a low ornegligible level of Self-Harm and Suicide content on the surfaces onSnapchat that allow users to share Public Content. We also proactively scanLimited Broadcast Content in Friends Stories for certain severe harmsincluding Self-Harm content. Content on Snapchat can be reported in-app or on our web site, and“Self-Harm and Suicide” is one of the reporting reasons offered.Snapchatters can also report Self-Harm and Suicide content to us via in-appreporting options and anyone can submit a report through the SnapchatSupport Site. 126 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT We provide more information in Section 5 (see Content Moderationsub-section). (c) the applicable termsand conditions andenforcement; Snap’s Terms prohibit the dissemination of content that promotes Self-Harmand Suicide. We promptly enforce against accounts found to be sending prohibitedSelf-Harm and Suicide content and Snap removes such content for all users. (d) systems forselecting andpresentingadvertisements; and Our advertising systems require agreement to advertising policies andguidance that prohibit adverts from displaying information that violates thelaw or causes certain harms. We check advertisers are complying with theirobligations via our advertising review process. Other mitigations listed here apply to our Advertising Systems too. Weprovide more information in Section 5 (see the Advertising Systemssub-section). (e) our data relatedpractices We have strong data principles, practices and privacy, safety and security bydesign processes. We provide more information in Section 5 (see theTransparency sub-section) and Section 6 (see the Platform PrinciplesFramework and Privacy and Safety by Design subsections). We have also analysed whether and how the risk of this harm is influenced by the followinggeneral factors: Service Risk Factor How does it apply to Snapchat and this harmI? 127 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Intentional manipulation,including inauthentic useor inauthentic use orautomated exploitationof the service There are two key ways in which we consider our systems could bemanipulated:(1) Users could seek to share novel Self-Harm and Suicide material thatis not detected by our automated systems. We are constantlyworking to adjust our systems and policies to address this. Weprovide more information on our approach in Section 5 (in particularthe Content Moderation subsection) and Section 6 (Ongoing RiskDetection and Management).(2) Users could abuse our content moderation processes and reportnon-violating content / accounts in bad faith. We have processes tocombat misuse and more information can be found in Section 5(Content Moderation and Enforcement subsections). Amplification andpotentially rapid andwide dissemination ofillegal content and ofinformation that isincompatible with theirterms and conditions. Snapchat’s inscope services have a number of features and designconfigurations that act to limit the amplification and potentially rapid andwide dissemination of content glorifying Self-Harm and Suicide, in particular: 1. Snapchat is not an attractive platform for spreading contentglorifying Self-Harm and Suicide, in particular because it is difficult toreach a broad audience and content is deleted by default. Weprovide more information in Section 5 (see Snapchat Design /Function subsection) 2. Snap has implemented specific proactive and reactive moderationprocedures to prevent and remove such content. As explained in theContent Moderation Section, Snap deploys a range of automatedcontent moderation (which includes abusive language detection,other keyword-based detection, and machine-learning-basedproactive detection). We provide more information in Section 5 (seeContent Moderation) 3. Content recommended to users on Spotlight and Discover, our videosharing platforms, is moderated using a combination ofauto-moderation and human moderation, and is human moderatedbefore being widely distributed. Lens and Ads are subject to reviewprocesses before submission. We provide more information inSection 5 (see Content Moderation) Specific regional orlinguistic aspects,including when specificto a Member State. We recognise that our users may come from different Member States andcontent may be shared in different languages. To address this, ● Snapchat is provided in multiple EU languages and our Terms areavailable in all EU languages. We provide more information inSection 5 (see Terms). ● We deploy content moderation systems and moderators work acrossmultiple EU languages. We provide more information in Section 5(see Content Moderation). 128 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT specific mitigation in Section 5 of this Report which explains in more detail how each mitigationoperates to reduce the risk. MitigationCategory Applies to this risk? Snapchat Design and Function Adapting the design, features or functioningof their services, including their onlineinterfaces. Yes, several aspects of Snapchat’s design and functionreduce the risk of Self-Harm and Suicide activity: ● Unlike many of our peers, Snap does not offerthe option to live-stream or have an open newsfeed where unvetted publishers or individualshave an opportunity to broadcast prohibitedSelf-Harm and Suicide content nor doesSnapchat offer a ‘reshare’ functionality that wouldencourage virality. Snap also does not allowuser-generated content to be recommended fordistribution to a large audience without goingthrough human review. ● Private messaging services require mutualfriendship. Group chats are limited to a maximumof 201 users and are not publicly searchable. Terms and Enforcement Adapting their terms and conditions andtheir enforcement. Snap’s Terms prohibit the dissemination of content thatpromotes self-harm and suicide. This includes: Suicide (the act of intentionally causing one’s death); anddepictions of threats of suicide; Suicide attempts; Suicidalideation; Suicide encouragement/tips andPraising/glorifying self-harm. Glorifying suicide orself-harm is prohibited and includes: ● Content depicting self-harm or suicide postedfor shock value rather than expressing a cry forhelp. ● Content promoting suicidality or eating disordersby glamorizing, romanticizing, or normalizing theact. ● Encouraging, instructing, and/or asking users toharm themselves.We allow some discussion (such as news or public issuecommentary) of self-harm and suicide. We promptly enforce against accounts found to besending prohibited Self-Harm and Suicide content andSnap removes such content for all users. When we learnof content suggesting that there is an emergencysituation involving imminent danger of death or serious 130 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? bodily injury involving any person, we proactivelyescalate the report to law enforcement as appropriate.We have processes for referring such content to therelevant law enforcement authorities in the EU andgovernment agencies in the rest of the world. Moderation Adapting content moderation processes,including the speed and quality ofprocessing notices related to specific typesof illegal content and, where appropriate,the expeditious removal of, or the disablingof access to, the content notified, inparticular in respect of illegal hate speechor cyber violence, as well as adapting anyrelevant decision-making processes anddedicated resources for contentmoderation. Yes, we have specific proactive and reactive moderationprocedures to prevent and remove content that promotesself-harm. As described in the Content ModerationSection of this Report, we use a mix of automation (suchas abusive language detection, image recognitionmodels, and account history) and human review toenforce our guidelines. We continue to makeimprovements to our proactive detection tools, includingwith respect to Self-Harm and Suicide content, to helpensure a low or negligible level of Self-Harm and Suicidecontent on the surfaces on Snapchat that allow users toshare Public Content. We also proactively scan LimitedBroadcast Content in Friends Stories for certain severeharms including Self-Harm content. Content on Snapchat can be reported in-app or on ourweb site, and “Self-Harm and Suicide” is one of thereporting reasons offered. Snapchatters can also reportSelf-Harm content to us via in-app reporting options andanyone can submit a report through the SnapchatSupport Site. Snap cannot use proactive moderation procedures withrespect to Private Services due to our legal obligations.Chat / Group chat services are ephemeral by default.However, Snapchat does not use full end-to-endencryption and private messages will be retained andavailable to moderators for moderation if reported (and tolaw enforcement if requested/escalated). 131 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? Algorithmic Systems Testing and adapting their algorithmicsystems, including their recommendersystems. Yes, on Snapchat’s services where we algorithmicallyrecommend content, we take proactive measures to stopthe dissemination of content that glorifies self-harm,including the promotion of self-injury, suicide or eatingdisorders. Our algorithmic systems do not knowinglyrecommend content glorifying self-harm i.e. there is no‘glorifying self-harm’ interest category. We allow some discussion (such as news or public issuecommentary) of self-harm, suicide, or eating disorders,when the discussion is not glorifying such behavior. Evenso, to the extent we observe it, we mark this content as“sensitive” internally and adjust our algorithmic systemsso that content recommendations are not too dense withthis kind of content, as it may be troubling in excess. Advertising Systems Adapting their advertising systems andadopting targeted measures aimed atlimiting or adjusting the presentation ofadvertisements in association with theservice they provide. Yes, other mitigations listed here also apply to ourAdvertising Systems. Ongoing Risk Detection and Management Reinforcing the internal processes,resources, testing, documentation, orsupervision of any of their activities inparticular as regards detection of systemicrisk. Yes, for example we have specific prevalence testing andmonitoring moderation and enforcement data which weuse to help detect and manage Self-Harm and Suicide. Trusted Flaggers Initiating or adjusting cooperation withtrusted flaggers in accordance with Article22 and the implementation of the decisionsof out-of-court dispute settlement bodiespursuant to Article 21. We do not have specific Trusted Flaggers on Suicide andSelf-Harm but we do work with Trusted Flaggers on childsafety which may raise this. Codes and Crisis Protocols Initiating or adjusting cooperation with otherproviders of online platforms or of onlinesearch engines through the codes ofconduct and the crisis protocols referred toin Articles 45 and 48 respectively. Yes, we cooperate with other providers through variousindustry groups. For example, we are a member of Thrive\- an industry signal-sharing initiative focused on Suicideand Self-Harm content. 132 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? Transparency Taking awareness-raising measures andadapting their online interface in order togive recipients of the service moreinformation. Yes, we provide guidance on our terms, harms,moderation and enforcement practices, as well as how toreport and get help in our Safety Center. In Snapchat weprovide a number of tools to users. For example: ● If a user searches for certain Self-Harm andSuicide related terms we will surface our HereFor You tool and may be routed to suicidehelplines in their region. We work with third-partymental health groups to develop thesesupportive materials and resources. ● Snap includes help resources within rejectionreasons. For example, Snap has established aself-harm flow for Lenses, which includesescalation to the Trust \& Safety team, sendinghelp resources, and escalation to authorities.Lenses that are rejected, although few in number,include help resources within the rejectionreason. Protection of Minors Taking targeted measures to protect therights of the child, including age verificationand parental control tools, tools aimed athelping minors signal abuse or obtainsupport, as appropriate. Yes, we have protective measures to limit Teen contactwith strangers; we offer Family Center; we make availablerobust reporting; and we provide guidance to parents onthe web. Our parents site provides additional guidancefor parents and caregivers on risks and support.82 Content Authenticity Ensuring that an item of information,whether it constitutes a generated ormanipulated image, audio or video thatappreciably resembles existing persons,objects, places or other entities or eventsand falsely appears to a person to beauthentic or truthful is distinguishablethrough prominent markings whenpresented on their online interfaces, and, inaddition, providing an easy to usefunctionality which enables recipients of theservice to indicate such information. General content authenticity measures are taken. Snap hastaken steps to mitigate the risk that (i) its generative AItools are used for illegal or otherwise violating contentand (ii) illegal or otherwise violating content created usinggenerative AI tools on any online platform aredisseminated on Snapchat’s in-scope services. 82 Snapchat Family Safety Hub, url. 133 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Conclusion Content that glorifies self-harm is categorized within the Extremely Low likelihood category forSnapchat’s in-scope services. However, this content falls within our ‘serious harm’ categoryand asa result we have decided to categorize it as a Level 2 overall potential risk, even though our riskmatrix would suggest a lower category. We always treat content relating to suicide and othersituations involving imminent, credible risk of harm as a Level 1 overall potential risk. In response,we have significant dedicated mitigation measures, including clear prohibitions, guidance,proactive and reactive moderation, reporting tools, sensitive content recommendation limits andcooperation with trusted flaggers. Our prevalence rates for Self-Harm content on Snap’s in-scopeservices continue to decline and are at very low levels. This is further supported by low violativeview rates for Self-Harm content. As a result, we have concluded that Snapchat’s in-scope services have reasonable,proportionate and effective mitigation measures for dissemination of content glorifyingSelf-Harm (including the promotion of self-injury, suicide or eating disorders). Snap monitorsthis category to confirm whether further mitigating measures might be required. There is nochange in this conclusion since our 2024 Report. 4.1.9 Dissemination of content relating to violent or dangerous behavior This Section 4.1.9 (Violent or Dangerous Behaviours) considers the risk of harm arising fromviolent or dangerous behaviours (as described in the Harm Description below) on Snapchat’sin-scope services defined in Section 2 (Scope). We have assessed this risk in accordance with the Section 3 (Methodology) as follows. Harm Description This section addresses violence (including physical and psychological violence beyond thecategory of Harassment already referred to in this Section 4) and risky/dangerous behaviours \&activities. This includes: ● Violent, Threatening, or Abusive Behaviour: This includes any content that expresses anintent to inflict serious physical or emotional harm on an individual or group, or damage totheir property beyond the category of Harassment already referred to in this Section 4. ● Threats and Intimidation: Any form of explicit or implied threat—whether of violence,retaliation, or psychological harm. This includes content that attempts to coerce ormanipulate others through fear, blackmail, or control. ● Coercive and Controlling Behaviour: Content that reflects or promotes coercive tactics,including manipulation, isolation, surveillance, or restriction of a person’s freedom orautonomy. ● Vigilante Activity: This includes coordinated efforts to intimidate or take physical actionagainst individuals or communities outside proper legal process. 134 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ● Encouraging or Engaging in Dangerous Behaviour: Content that promotes or participatesin risky activities likely to be imitated, and that could result in serious harm. This includesreckless driving, unsafe challenges, or any behaviour that endangers personal or publicsafety. ● Glorification or Incitement of Harmful Behaviour: This includes content that glorifies orencourages violence or abuse, including towards people or animals. This includes Snapsdepicting gratuitous violence, graphic injury, animal cruelty, or other forms of distressingcontent. We provide a summary and explanation of ‘Violent or Dangerous Behaviours’ in our explainer of Threats, Violence \& Harm \& Harassment and Bullying (limited to verbal abuse and threats) andour Transparency Report Glossary. Likelihood Research has found that risky and criminal behavior is in danger of becoming normalized amonga generation of young people. The online environment, and the dissemination of contentencouraging or engaging in violent or dangerous behavior, is reported to play a significant role inthis trend.83 Algorithms and the interactions facilitated by online platforms in general have beenfound to have been used by radical groups to recruit vulnerable individuals to their cause. In2017, the UN Secretary-General addressed the problem of online violence in his report to the UNGeneral Assembly on ‘The Safety of Journalists and the Issue of Impunity’ (A 72/290).84 Thisappears to have resulted in the sharp growth of violent events and deteriorating onlinediscourse.85 For this Report, it is worth noting that in Q3 2023, our ongoing monitoring identified an uptick inthe prevalence of violating content views for the violent and disturbing category. In response, welaunched new proactive detection mechanisms to target violent and disturbing content.Immediately after launch, the team were able to enforce significantly more proactively detectedSnaps daily. Consequently, as of July 2024, we were pleased to report that prevalence for violentor disturbing content (as well as for Dangerous Activities) has seen a further substantial fal. Since our 2024 Report, ● We have seen further falls in the PVP levels for violent and disturbing content,This is a result of our specific efforts to reduce exposure to illegal andother violating content falling within our ‘Violent and disturbing content’ category. Our 85 Habib, e.a., ‘Making a Radical Misogynist: How online social engagement with the Manosphere influences traits ofradicalization’, February 2022, url. 84 UN General Assembly, The safety of journalists and the issue of impunity: Report of the Secretary-General,A/72/290, url. 83 The Guardian (D. Milmo), Risky online behaviour ‘almost normalised’ among young people, 5 Dec 2022, url. 135 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT As a resultwe continue to place the dissemination of content encouraging or engaging inViolent and Dangerous Behaviour within the lowest likelihood category relative to other risks onSnapchat’s in-scope services. We continue to note that all of the risks we track on Snapchat havea relatively low prevalence compared to the prevalence of these issues elsewhere online andoffline. Severity The extent to which a person’s access to violence content causes violent conduct and harm hasbeen the subject of debate for a long time. Researchers have linked certain types of internet useto increased aggressive behavior. For example, youths who perpetrated serious crimes weresignificantly more likely to have viewed violent online content.86 Snap considers that the spectrum of “encouraging or engaging in violent or dangerous behavior”can vary considerably and covers a broad range of content types: ● Content relating to imminent, credible threats such as school or other mass shooting andbombing threats, although this is mainly a US-related risk and less relevant for EU users.Snap considers credible imminent threats to human life to constitute a severe harm. ● Viral “challenges” may cause injury (for example, the “Milk Crate Challenge” of 2021).Since well before the existence of social media, some people have sought out videos ofother people getting hurt. This content ranges from horrifying shock content, to relativelytame comedic pratfalls and minor injuries. ● Local reports of teen users being blackmailed or extorted over Snapchat, which may spillover into real-world intimidation and violence.87 Snap considers that these issues can vary considerably in severity, from severe to significant andour teams are trained to distinguish between harmful and harmless content. Overall, Snapconsiders content encouraging or engaging in Violent and Dangerous Behaviour to fall within our significant harm category. DSA Risk Factors In accordance with Section 3 (Methodology), we have also taken into account, in particular,whether and how the following service risk factors referenced in Article 34(2) of the DSA 87 Dutch News, Dozens of teenagers blackmailed via Snapchat, police warn”, 20 January 2025, url. 86 M.L. Ybarra, M. Diener-West, D. Markow, Linkages between internet and other media violence with seriously violentbehavior by youth, Pediatrics, 2008/122, p. 929-937. 137 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT influence the risk of this harm on Snapchat’s in-scope services. As set out below, while thefollowing risk factors could in principle influence this systemic risk, their overall impact is limitedgiven Snap’s existing mitigations, which are described later in this chapter and in Chapter 5. Service Risk Factor How does it apply to Snapchat and this harm? (a) the design ofrecommender systemsand any other relevantalgorithmic system; Unlike many of our peers, Snapchat does not offer an open news feedwhere unvetted publishers or individuals have an opportunity tobroadcast violent or dangerous behaviours, does not offer a broad‘reshare’ functionality that would encourage virality, and does not allowuser-generated content to be recommended to a wide audiencewithout going through further review. Our algorithmic systems do not knowingly recommend violent ordangerous behaviours. Detailed information regarding the mitigationsrelating to our recommender systems can be found in Section 5 (seethe Algorithmic Systems sub-section). (b) content moderationsystems; We have specific proactive and reactive moderation procedures toprevent and remove content showing violent or dangerous behaviours. (c) the applicable terms andconditions andenforcement; Snap’s Terms and Community Guidelines expressly prohibit violent ordangerous behaviour and it is strictly enforced. Certain activities thatinvolve violent or dangerous behaviours, including sharing credible,imminent threats to human life, safety, or well-being, specific threats ofviolence or other serious criminal activities are a “severe harm” in ourCommunity Guidelines and we respond with swift and strictconsequences against violators as explained in our Severe Harmsexplainer. Snapchatters can also report violent or dangerous behaviours to us viain-app reporting options and anyone can submit a report through theSnapchat Support Site. We provide more information in Section 5 (see the Terms andEnforcement sub-sections). (d) systems for selecting andpresentingadvertisements; and Our advertising systems require agreement to advertising policies andguidance that prohibit adverts from displaying information that violatesthe law or causes certain harms. We check advertisers are complyingwith their obligations via our advertising review process. Other mitigations listed here apply to our Advertising Systems too. Weprovide more information in Section 5 (see the Advertising Systems 138 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT sub-section). (e) our data related practices We have strong data principles, practices and privacy, safety andsecurity by design processes. We provide more information in Section5 (see the Transparency sub-section) and Section 6 (see the PlatformPrinciples Framework and Privacy and Safety by Design subsections). We have also analysed whether and how the risk of Violent or Dangerous Behaviours isinfluenced by the following general factors: General Service Risk Factor How does it apply to Snapchat and this harm? Intentional manipulation, includinginauthentic use or inauthentic use orautomated exploitation of theservice There are two key ways in which we consider our systems couldbe manipulated:(1) Users could seek to share novel material relating toviolent or dangerous behavior that is not detected by ourautomated systems. We are constantly working to adjustour systems and policies to address this. We providemore information on our approach in Section 5 (inparticular the Content Moderation subsection) andSection 6 (Ongoing Risk Detection and Management).(2) Users could abuse our content moderation processesand report non-violating content / accounts in bad faith.We have processes to combat misuse and moreinformation can be found in Section 5 (ContentModeration and Enforcement sub-sections). Amplification and potentially rapidand wide dissemination of illegalcontent and of information that isincompatible with their terms andconditions. Snapchat’s inscope services have a number of features anddesign configurations that act to limit the amplification andpotentially rapid and wide dissemination of content glorifyingSelf-Harm, in particular: 1. Snapchat is not an attractive platform for spreadingcontent relating to violent or dangerous behavior, inparticular because it is difficult to reach a broad audienceand content is deleted by default. We provide moreinformation in Section 5 (see Snapchat Design / Functionsubsection) 2. Snap has implemented specific proactive and reactivemoderation procedures to prevent and remove suchcontent. As explained in the Content Moderation Section,Snap deploys a range of automated content moderation(which includes abusive language detection, otherkeyword-based detection, and machine-learning-basedproactive detection). We provide more information in 139 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Snap's Mitigations Snapchat enables photo and video sharing and other user interaction across Snapchat’s inscopeservices. While this functionality has many positive benefits for users, including in particularfacilitating engagement with friends and family, Snap recognises Snapchat’s functionality couldallow content relating to violent or dangerous behaviour to be disseminated. Snap has put inplace significant measures to substantially diminish the likelihood and impact of this content onSnapchat. In the table below we indicate the specific measures we have taken to mitigate this risk in respectof Snapchat’s in-scope services. These are organised into Snap’s risk assessment mitigationcategories. Note that the primary purpose of the below table is to indicate whether each specificmitigation category applies to this risk and the descriptions are illustrative rather than exhaustive.As many of our mitigations apply to all of the risks assessed in this Report, to reduce duplicationin this Report, each row in the tables provides a link in the left hand column to a full summary ofthe specific mitigation in Section 5 of this Report which explains in more detail how eachmitigation operates to reduce the risk. MitigationCategory Applies to this risk? Snapchat Design and Function Adapting the design, features orfunctioning of their services,including their online interfaces. Yes, several aspects of Snapchat’s design and function reducethe risk of Violent and Dangerous Behaviour being shared on theplatform: ● Snap makes it difficult for unvetted content to reach alarge audience on Snapchat, and Snap proactivelymoderates Snapchat’s in-scope services that provide anopportunity to reach a larger audience. As a result, weexperience very few instances of Violent and DangerousBehaviour on Snapchat. Terms and Enforcement Adapting their terms and conditionsand their enforcement. Yes, Snap’s Terms and Community Guidelines expressly prohibitViolent and Dangerous Behaviour and it is strictly enforced.Certain activities that involve Violent and Dangerous Behaviour,including sharing credible, imminent threats to human life, safety,or well-being, specific threats of violence or other serious criminalactivities are a “severe harm” in our Community Guidelines andwe respond with swift and strict consequences against violatorsas explained in our Severe Harms explainer.Snapchatters can also report Violent and Dangerous Behaviourto us via in-app reporting options and anyone can submit a reportthrough the Snapchat Support Site. Our in-app reporting toolallows users to directly report threats, violence or dangerousbehaviours.We promptly enforce against accounts found to be sharing this 141 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? content: ● Snap removes such content for all users. ● Accounts we discover engaging in prohibited activitieswill also be promptly disabled. ● Where appropriate, accounts engaging in violation ofthese policies are reported to law enforcement asappropriate. Moderation Adapting content moderationprocesses, including the speed andquality of processing notices relatedto specific types of illegal contentand, where appropriate, theexpeditious removal of, or thedisabling of access to, the contentnotified, in particular in respect ofillegal hate speech or cyberviolence, as well as adapting anyrelevant decision-making processesand dedicated resources forcontent moderation. Yes, we have specific proactive and reactive moderationprocedures to prevent and remove content showing Violent and Dangerous Behaviour. As explained in the Content Moderation section in Section 5 of this Report, Snap deploys a range ofautomated content moderation (which include abusive languagedetection, other keyword-based detection, andmachine-learning-based proactive detection models) to scanStories and Spotlight submissions. Image classifiers are trainedon violent behaviour signals. Algorithmic Systems Testing and adapting theiralgorithmic systems, including theirrecommender systems. Unlike many of our peers, Snapchat does not offer an open newsfeed where unvetted publishers or individuals have anopportunity to broadcast Violent and Dangerous Behaviour, doesnot offer a broad ‘reshare’ functionality that would encouragevirality, and does not allow user-generated content to berecommended to a wide audience without going through furtherreview. 142 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? As explained in the Content Moderation Section of our ExistingMitigations in Section 5, on Spotlight and Discover, we take aproactive approach to moderating any content that may violatethese rules prior to the content being recommended to a wideaudience. Advertising Systems Adapting their advertising systemsand adopting targeted measuresaimed at limiting or adjusting thepresentation of advertisements inassociation with the service theyprovide. Yes, other mitigations listed here also apply to our AdvertisingSystems. Ongoing Risk Detection andManagement Reinforcing the internal processes,resources, testing, documentation,or supervision of any of theiractivities in particular as regardsdetection of systemic risk. Yes, for example we have specific prevalence testing andtransparency reporting which we use to help detect and manageViolent and Dangerous Behaviour. Trusted Flaggers Initiating or adjusting cooperationwith trusted flaggers in accordancewith Article 22 and theimplementation of the decisions ofout-of-court dispute settlementbodies pursuant to Article 21. We do not have a specific trusted flagger on Violent andDangerous Behaviour in general but we do engage with severaltrusted flaggers on specific behaviors. For example, for certainthreats, abusive and coercive behaviours we cooperate withRefuge. Codes and Crisis Protocols Initiating or adjusting cooperationwith other providers of onlineplatforms or of online searchengines through the codes of We are not working with other providers on Violent andDangerous Behaviour specifically. However, Snap is a member ofa number of EU trade associations to contribute to the policydebate to support the development of a proportionate regulatoryframework to promote online safety. 143 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? conduct and the crisis protocolsreferred to in Articles 45 and 48respectively. Also, Snap has set up a number of crisis management protocolsto help the organization swiftly tackle unexpected incidents andhelp minimize their impact on our service, users and operations. Transparency Taking awareness-raising measuresand adapting their online interfacein order to give recipients of theservice more information. Yes, we provide guidance on harms and how to get help in our Safety Center. We make available robust reporting tools; and weprovide guidance to parents on the web (see below). Protection of Minors Taking targeted measures to protectthe rights of the child, including ageverification and parental controltools, tools aimed at helping minorssignal abuse or obtain support, asappropriate. Yes, we have protective measures to limit Teen contact withstrangers; we offer Family Center, reporting, and guidance. Ournew parents site provides additional guidance for parents andcaregivers on risks and support.88 In addition, In particular, we would note that sensitive contentdistribution is limited on both Spotlight and Discover: ● In Spotlight, we limit the distribution of sensitive contentbased on the following rules: ○ We do not recommend sensitive content to usersunder 18 by default. ○ We do not recommend sensitive content to newusers (i.e. users with less than 200 views in thepast 28 days). ○ For all other users, by default, we ensure theinitial video watched in a session is not sensitiveand after that we ensure that sensitive content isonly shown sparingly (i.e. 1 in 7 videos). ● In Discover, as in Spotlight, we limit the display ofsensitive content for all users. We also do not showsensitive content to users under 18 by default and thedisplay of sensitive content can be disabled entirely inthe Family Center. Content Authenticity Ensuring that an item of information,whether it constitutes a generatedor manipulated image, audio orvideo that appreciably resemblesexisting persons, objects, places orother entities or events and falsely Yes, Snap has taken steps to mitigate the risk that (i) itsgenerative AI tools are used for creating illegal or otherwiseviolating content and (ii) illegal or otherwise violating contentcreated using generative AI tools on any online platform aredisseminated on Snapchat’s inscope services. 88 https://parents.snapchat.com. 144 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? appears to a person to be authenticor truthful is distinguishable throughprominent markings whenpresented on their online interfaces,and, in addition, providing an easyto use functionality which enablesrecipients of the service to indicatesuch information. Conclusion Dissemination of content encouraging or engaging in Violent and Dangerous Behaviour onSnapchat’s in-scope services is one of our lowest likelihood category risks. We recognize that thepotential harm arising from such content can be significant and we have therefore tracked thisrisk with an overall Level 3 potential risk rating. We devote significant resources to enforcingagainst truly harmful or shocking content encouraging or engaging in Violent and DangerousBehaviour as summarized above. Our prevalence testing shows the prevalence of this type ofcontent to be failing on Snapchat’s in-scope services. As a result, we have concluded that Snapchat’s in-scope services have reasonable,proportionate and effective mitigation measures for dissemination of content encouraging orengaging in Violent and Dangerous Behaviour. Snap monitors this category to confirmwhether further mitigating measures might be required. There is no change in this conclusionsince our 2024 Report. 4.1.10 Dissemination of Harmful False Information This Section 4.1.10 (False Information) considers the risk of harm arising from the dissemination ofharmful false content (as described in the Harm Description below) on Snapchat’s in-scopeservices. Harm Description Snap describes False Information as content that is false or misleading and causes harm or ismalicious. Harmful False Information may be observed in content denying tragic events (e.g.Holocaust denial), promoting unsubstantiated medical claims, impersonating others in harmfulways, misleading users about democratic processes (e.g. election times or procedures), ormisrepresenting public interest issues. 145 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ● We provide a summary and explanation of this harm as part of our explainer on Harmful False orDeceptive Practices and our Transparency Report Glossary. Likelihood Our external research shows that “Fake news,” (online) “disinformation” and “deep fakes” havegained a lot of attention in the media and academic and political debate over the last years.89 Misinformation can include publishing false news articles to win elections and the impersonationof a celebrity in order to promote products or services, promote propaganda, or simply forattention. It may be a malicious effort to harass someone. It may be an attempt to extort someoneinto paying to regain access to an account or online identity. Such information could conceivablybe present in videos published on Spotlight and For You, promoted in Stories on Public Profiles,in places and Snaps featured on Snap Map and in Lenses published via Lens Studio. Harmfulfalse advertising might include ads for content that mimics the appearance or function ofSnapchat features or formats or political advertising with false statements and slogans regardingimportant societal issues. In practice, the dissemination of harmful misinformation is still not common on Snapchat. Asexplained in our Transparency Reports, False information continues to account for only 0.1% ofthe total of all content enforced on Snapchat. This figure remained steady throughout 2024. Wetrack Impersonation separately, and it similarly accounts for a very low percentage of ourenforcement actions (0.1% in the second half of 2024)) Lenses with this type of information arerarely submitted. In our 2024 Report we observed that our Prevalence Testing showed a very low prevalence of‘Harmful False Information’ (0.0001% PVP) in July 2024 which remains the same by April 2025.Moreover, when content related to this specific Harm was detected (whether proactively throughautomated tools or reactively following a user report) our Safety teams acted swiftly. According toour latest European Union Transparency Report (covering the second half of 2024), the median 89 T. McGonagle, ‘“Fake news”: False fears or real concerns?’, 35 Netherlands Quarterly of Human Rights (No. 4,December 2017), p. 203-209. Katie Pentney, ‘Tinker, Tailor, Twitter, Lie: Government Disinformation and Freedom ofExpression in a Post-Truth Era’ (2022) 22 Human Rights Law Review, 1-29; Paulo Cavaliere, ‘The Truth in Fake News:How Disinformation Laws Are Reframing the Concepts of Truth and Accuracy on Digital Platforms’, EuropeanConvention on Human Rights Law Review, (2022) 3(4), 481-523. 146 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT turnaround time for enforcement action in response to proactive or reactive detections of thiscontent was 2 minutes. As a result, we continue to place dissemination of harmful misinformation into our lowestlikelihood category relative to other risks.90 Severity False information does not present an imminent threat to human life. However, Snap recognisesthere is a risk that malicious false information could be harmful. This includes: ● Disinformation: content that is deliberately false and designed to cause harm; ● Misinformation: content that is false or misleading in ways that can cause harm, sharedwithout knowledge that the information is false and harmful; and ● Mal-information: genuine information that is shared with an intent to cause harm The common denominator of these categories of false information content is that their falsenature can be difficult to identify, because content can be manipulated, disguised as credibleinformation or even allowed under free speech protection. Because of the diverse forms thatfalse information can take, it is more reasonable to classify Harmful False Information as "general"harm. It can be observed that in recent years more and more political initiatives are emerging tocombat Harmful False Information, demonstrating the need to combat the spread of this type ofcontent.91 To this end, the EU has launched a (Strengthened) Code of Practice on 91 European Commission, ‘Tackling online disinformation’, overview of initiatives (url). 90 This classification is also supported by the fact that Snapchat was not included in the report issued by the EuropeanCommission: European Commission, Directorate-General for Communications Networks, Content and Technology, Digital Services Act – Application of the risk management framework to Russian disinformation campaigns,Publications Office of the European Union, 2023 (url). 147 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Disinformation,92 several reputable international institutions have recognized the need forintermediaries to take action to restrict third party content in their Joint Declaration on “FakeNews”, Disinformation and Propaganda.93 As a result, we continue to classify “Harmful False Information” in general as having a risk of significant harm relative to other risks. DSA Risk Factors In accordance with Section 3 (Methodology), we have also taken into account, in particular,whether and how the following service risk factors referenced in Article 34(2) of the DSAinfluence the risk of this harm on Snapchat’s in-scope services. As set out below, while thefollowing risk factors could in principle influence this systemic risk, their overall impact is limitedgiven Snap’s existing mitigations, which are described later in this chapter and in Chapter 5. Service Risk Factor How does it apply to Snapchat and this harm? (a) the design of recommendersystems and any otherrelevant algorithmic system; Our recommender system presents political content only fromtrusted, verified creators and partners. Our algorithmic systemsdo not knowingly recommend content encouraging or engagingin misinformation i.e. there is no ‘misinformation’ interestcategory. We take steps to prevent content with misleading orsensationalist headlines. Detailed information regarding themitigations relating to our recommender systems can be found inSection 5 (see the Algorithmic Systems sub-section). (b) content moderationsystems; We use specific proactive and reactive moderation procedures toprevent and remove misinformation. In particular, Discoverfeatures content only from approved media publishers andsignificant content creators. Our entertainment platform foruser-generated content, Spotlight, is proactively and a priorimoderated before content can reach a wide audience. Weprovide more information in Section 5 (see Content Moderationsub-section) (c) the applicable terms andconditions andenforcement; Our terms prohibit misinformation. We have a specific HarmfulFalse or Deceptive Information explainer which explains ourapproach to enforcement. We provide more information inSection 5 (see the Terms and Enforcement sub-sections). 93 Declaration by the United Nations Special Rapporteur on Freedom of Opinion and Expression, the Organization forSecurity and Co-operation in Europe Representative on Freedom of the Media, the Organization of American States(OAS) Special Rapporteur on Freedom of Expression and the African Commission on Human and Peoples’ RightsSpecial Rapporteur on Freedom of Expression and Access to Information, March 2017 (url). 92 European Commission, ‘2022 Strengthened Code of Practice on Disinformation’, June 2022 (url). 148 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT (d) systems for selecting andpresenting advertisements;and Ads are reviewed for false, misleading and misinformation as partof Snap’s Advertising Policies. Any reviewed ad that has false,misleading or misinformation will be rejected. Our moderationteam also reviews reported ads, so if an ad were to be approvedfor misinformation and is reported, our team will take anotherlook. Every political, health or sensitive issue ad is reviewed byhumans on the ad review team. We reject ads that containunsubstantiated or false claims. All political ads are logged in ourpolitical ads library. We provide more information in Section 5(see the Advertising Systems sub-section). (e) our data related practices We have strong data principles, practices and privacy, safety andsecurity by design processes. We provide more information inSection 5 (see the Transparency sub-section) and Section 6 (seethe Platform Principles Framework and Privacy and Safety byDesign subsections). We have also analysed whether and how the risk of this harm is influenced by the followinggeneral factors: General Service Risk Factor How does it apply to Snapchat and this harm? Intentional manipulation, includinginauthentic use or inauthentic use orautomated exploitation of theservice There are two key ways in which we consider our systems couldbe manipulated:(1) Users could seek to share novel illegal and violatingmaterial that is not detected by our automated systems.We are constantly working to adjust our systems andpolicies to address this. We provide more information onour approach in Section 5 (in particular the ContentModeration subsection) and Section 6 (Ongoing RiskDetection and Management).(2) Users could abuse our content moderation processesand report non-violating content / accounts in bad faith.We have processes to combat misuse and moreinformation can be found in Section 5 (ContentModeration and Enforcement subsections). Amplification and potentially rapidand wide dissemination of illegalcontent and of information that isincompatible with their terms andconditions. Snapchat’s in-scope services have a number of features anddesign configurations that act to limit the amplification andpotentially rapid and wide dissemination of Harmful FalseInformation: (1) Snapchat is not an attractive platform for spreadingHarmful False Information, in particular because it is 149 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Mitigation Category Applies to this risk? Algorithmic Systems Testing and adapting their algorithmic systems,including their recommender systems. Yes, our algorithmic systems do not knowinglyrecommend content encouraging or engaging inmisinformation i.e. there is no ‘misinformation’interest category. We take steps to prevent contentwith misleading or sensationalist headlines. Advertising Systems Adapting their advertising systems and adoptingtargeted measures aimed at limiting or adjustingthe presentation of advertisements in associationwith the service they provide. Yes, other mitigations listed here also apply to ourAdvertising Systems. Every political, health orsensitive issue ad is reviewed by humans on thead review team. We reject ads that containunsubstantiated or false claims. All political ads arelogged in our political ads library. Ongoing Risk Detection and Management Reinforcing the internal processes, resources,testing, documentation, or supervision of any oftheir activities in particular as regards detection ofsystemic risk. Yes, for example we have specific prevalencetesting and monitoring moderation andenforcement data which we use to help detect andmanage harmful false misinformation. Trusted Flaggers Initiating or adjusting cooperation with trustedflaggers in accordance with Article 22 and theimplementation of the decisions of out-of-courtdispute settlement bodies pursuant to Article 21. Yes, we cooperate with trusted flaggers, ourtrusted flaggers may also report misinformation,but this rarely happens because of the limitedamount of misinformation on the platform. Codes and Crisis Protocols Initiating or adjusting cooperation with otherproviders of online platforms or of online searchengines through the codes of conduct and thecrisis protocols referred to in Articles 45 and 48respectively. Snap has not yet signed up to be a member of theEU disinformation code. We have limited exposureto the risk and use our limited resources to focuson other codes relating to risks more relevant toSnapchat’s in-scope services. However, Snapworks closely with French regulator Arcom, whichmonitors industry action against misinformation.We have also worked closely with the Commissionand other stakeholders during the recent EUelections. Transparency Taking awareness-raising measures and adaptingtheir online interface in order to give recipients ofthe service more information. Yes, we provide guidance on our terms, harms,moderation and enforcement practices (seecorresponding annexes, as well as how to and howto get help in our Safety Center. This includes aspecific Harmful False or Deceptive Information explainer. 152 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Mitigation Category Applies to this risk? Protection of Minors Taking targeted measures to protect the rights ofthe child, including age verification and parentalcontrol tools, tools aimed at helping minors signalabuse or obtain support, as appropriate. Yes, we have protective measures to limit Teencontact with strangers; we offer Family Center; wemake available robust reporting; and we provideguidance to parents on the web. Our parents siteprovides additional guidance for parents andcarers on risks and support.94 Content Authenticity Ensuring that an item of information, whether itconstitutes a generated or manipulated image,audio or video that appreciably resembles existingpersons, objects, places or other entities or eventsand falsely appears to a person to be authentic ortruthful is distinguishable through prominentmarkings when presented on their onlineinterfaces, and, in addition, providing an easy touse functionality which enables recipients of theservice to indicate such information. We recognise the risk that generative AI could beused to generate harmful false misinformation,including deep fakes. Snap has taken steps tomitigate the risk that (i) its generative AI tools areused for creating illegal or otherwise violatingcontent; and (ii) illegal or otherwise violatingcontent created using generative AI tools on anyonline platform are disseminated on Snapchat’sinscope services. Conclusion We recognise a risk of significant harm that could arise from Harmful False Information. Inpractice, Snapchat’s in-scope services have very little exposure to Harmful False Information. It isone of our lowest likelihood categories of risks. As a result we track this risk as an overallsignificant potential risk. Snapchat has significant measures in place to prevent harmfulmisinformation, in particular the design and function of Snapchat’s in-scope services which limitsthe spread of content, limits the places where user generated can reach a broader audience andtargets proactive moderation at those areas to prevent harmful misinformation from becomingviral. We have a rapid response time when Harmful False Information does slip through. As a result, we have concluded that Snapchat’s in-scope services have reasonable,proportionate and effective mitigation measures for dissemination of Harmful FalseInformation. There is no change in this conclusion from our 2024 Report. 4.1.11 Dissemination of Fraud and Spam This Section 4.1.11 (Fraud and Spam) considers the risk of harm arising from Fraud and Spam (asdescribed in the Harm Description below) on Snapchat’s in-scope services defined in Section 2 (Scope). 94 https://parents.snapchat.com. 153 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT We have assessed this risk in accordance with the Section 3 (Methodology) as follows. Harm Description Snap describes Fraud and Spam as content from users, media partners and advertisers that fallswithin one of the following two categories: ● We provide a summary and explanation of ‘Fraud and Spam’ in our explainer of Harmful, False orDeceptive Practices and our Transparency Report Glossary. Likelihood We have considered the likelihood of this harm in line with Section 3 (Methodology) andobserved the following for this 2025 Report: 154 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ● Fraud and Spam are forms of cybercrime, which is a growing problem in the EuropeanUnion.95 Online fraud takes many forms and Europol has stated that “the growinge-commerce industry will result in a parallel growth of card—not-present fraud, especiallyas industry measures at preventing card-present fraud become more effective.”96 TheEuropean Securities and Markets Authority (ESMA) has also invited Snap and other onlineplatforms, through a 2025 letter, to consider the measures identified by InternationalOrganization of Securities Commissions (IOSCO), which highlighted the global concernregarding online harm linked to financial misconduct97. ● In addition, evidence98 submitted to a UK Home Affairs Committee inquiry99 into fraud byAlison Thewliss MP (SNP, Glasgow Central) quoted figures from TSB on the prevalence offraud on different platforms. She stated that 70% of the frauds that TSB was picking upwere being perpetrated on Meta —24% on Facebook and 46% on Instagram— 4% onSnapchat and 23% across other platforms. This is further evidence that indicates thatFraud has low prevalence on Snapchat in general. ● Snap has also been closely monitoring emerging trends identified at the UK level, with thepotential for these to spread across the EU. A recent research report by the Alan TuringInstitute (31 March 2025)100 highlights that AI-enabled crime is on the rise. While still at anearly stage, there is growing evidence of a significant acceleration in such activities,particularly in areas including financial crime, child sexual abuse material, phishing, andromance scams. With respect to Snapchat specifically, this report refers to intervieweeconcerns about the dissemination of material on private messaging services likeSnapchat. While we take these concerns very seriously, private messaging services onSnapchat are out of scope of this Report. ● With regards to Fraud and Spam in the content present on Snapchat’s in-scope services: ○ ○ Our latest European Union Transparency Report shows that “Fraud and Spam”reports continue to lead to a moderate volume of content and accountenforcements on our content online platforms, such as Spotlight and Discover. 100 AI and Serious Crime Online, March 2025, https://cetas.turing.ac.uk/publications/ai-and-serious-online-crime 99 UK House of Commons Home Affairs Committee, Committee Press Release. 98 UK House of Commons Home Affairs Committee, Home Affairs Committee. Oral evidence: Fraud, HC 125,Wednesday 22 November 2023, url. 97 https://www.esma.europa.eu/sites/default/files/2025-05/ESMA35-1872330276-2397_-_ESMA_Letter_to_Snap.pdf 96 Europol, ‘Payment fraud’, url. 95 Europol, Cybercrime, ‘EU Policy Cycle – EMPACT’, January 2022, url. 155 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ○ In the EU, data in our Transparency Report shows that, in the second half of 2024,only 18,527 accounts were locked and 41,731 content being enforced with amedian turnaround time of 2 minutes to enforce such content. This data issignificantly lower than figures recorded in the second half of 2023 when 140,388content and 106,057 accounts were enforced. ○ ● 156 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ○ Overall, given the further reductions in prevalence of Fraud and Spam content on Spotlight andDiscover and new evidence regarding the prevalence of Fraud and Spam in advertisingpost-publication, we consider the dissemination of Fraud and Spam in terms of relative likelihoodacross all of Snapchat’s in-scope services to fall within the lowest likelihood category. This is a 157 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? Terms and Enforcement Adapting their terms and conditions and theirenforcement. Snap’s Terms and Community Guidelines expresslyprohibit Fraud and Spam and it is strictly enforced. Snapchatters can report Fraud and Spam to us viain-app reporting options and anyone can submit areport through the Snapchat Support Site. We promptly enforce against accounts found to besharing this content: ● Snap removes such content from Snapchat. ● Snap promptly disables accounts that wedetermine are dedicated to sharing suchcontent, engage in multiple violationsinvolving Fraud and Spam within a definedperiod, or engage in a serious violationinvolving Fraud and Spam Moderation Adapting content moderation processes,including the speed and quality of processingnotices related to specific types of illegalcontent and, where appropriate, the expeditiousremoval of, or the disabling of access to, thecontent notified, in particular in respect of illegalhate speech or cyber violence, as well asadapting any relevant decision-makingprocesses and dedicated resources for contentmoderation. We have specific proactive and reactive moderationprocedures to prevent and remove content involving Fraud and Spam. As explained in the ContentModeration section in Section 5 of this Report, Snapdeploys a range of automated content moderationfeatures (which include abusive language detection,other keyword-based detection, andmachine-learning-based proactive detection models)to scan Public Stories and Spotlight submissions.Text and symbol classifiers are trained on Fraud andSpam signals. 160 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? Algorithmic Systems Testing and adapting their algorithmic systems,including their recommender systems. Unlike many of our peers, Snapchat does not offeran open news feed where unvetted publishers orindividuals have an opportunity to broadcast contentincluding Fraud and Spam, does not offer a broad‘reshare’ functionality that would encourage virality,and does not allow user-generated content to berecommended to a wide audience without goingthrough further review. Our algorithmic systems are designed not torecommend content including Fraud and Spam. As explained in the Content Moderation section inSection 5 of this Report, on Spotlight and Discover,we take a proactive approach to moderating anycontent that may violate our rules against Fraud andSpam prior to the content being recommended to awide audience. In addition, when we consider whether to allowcontent for algorithmic recommendations, we applyadditional rules. Content is “Not Eligible forRecommendation” when it contains engagementbait. This means content where the intent is not toentertain or inform the viewer, but to manipulatethem to boost the Snap’s views or interactions.Engagement bait often sets up an expectation thatnever pays off. Some examples: ● A “wait for it” caption, but “it” neverhappens. ● Challenges based on nonexistent Snapchatfeatures, such as, “Snapchat won’t let youlike this 10 times”. ● Attempts to leverage likes or shares, suchas, “If this gets 20,000 likes, I’ll shave myhead”. ● Attempt to trick people into re-watching orpausing a Snap via long blocks of text, briefglimpses of something, or “spot thedifference” games. ● Misleading or sensationalized headlines. Advertising Systems Yes, other mitigations listed here also apply to our 161 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? Adapting their advertising systems and adoptingtargeted measures aimed at limiting or adjustingthe presentation of advertisements inassociation with the service they provide. Advertising Systems. Snap’s Advertising Policies detail the criteria that ourautomation and human review teams apply whileconsidering whether to allow or reject an ad on ourplatform. Our advertising policies prohibit DeceptiveContent, including: ● Ads that are false or misleading, includingdeceptive claims, offers, functionality, orbusiness practices. ● Unauthorized or undisclosed sponsoredcontent. ● Promotion of fraudulent goods or services,including counterfeit documents orcertificates, or counterfeit products. ● Creating or sharing content that mimics theappearance or function of Snapchat featuresor formats. ● Ads that contain deceiving calls to action, orlead to landing pages unrelated to the brandor content being advertised. ● Cloaking, otherwise restricting landing pageaccess, or modifications to URL contentfollowing submission in an attempt tocircumvent review. ● Ads that encourage dishonest behavior.(e.g., ads for fake IDs, plagiarism, essaywriting services). ● Non-delivery of goods, or misrepresentedshipping delays or inventory constraints. The advertising policies for financial products andservices add further detail about the kind ofdeceptive content that is prohibited. ● Ads for financial products and services mustclearly and prominently disclose allapplicable material terms and conditions toconsumers prior to the submission of anapplication. ● Ads for loans must disclose, among otherthings, APR, repayment period, fees andcosts, penalties, and the contact informationof the lending institution. 162 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? ● Ads for products intended for a limitedaudience should only be targeted to thataudience. For example, if a credit card offeris limited to individuals over the age of 18,the offer’s ad campaign must be agetargeted to 18+. ● Ads for certain complex financial products,which may include cryptocurrency walletsand trading platforms, require prior approvalfrom Snap. ● We prohibit: ○ Get-rich-quick offers, pyramidschemes, or other deceptive ortoo-good-to-be true financial offers(see General Requirements: Fraudfor more details). ○ Promising guaranteed financialreturns on speculative investments. ○ Ads that promote particularsecurities or that provide or allegeto provide insider tips. ○ Payday loans or predatory lending. For commercial promotion within content from mediapartners or users, we apply our Commercial ContentPolicy. The Commercial Content Policy outlines rulesto protect Snapchatters from potentially misleadingReferences to Snap. Commercial content must notsuggest an affiliation with or endorsement by Snapor its products. This means that commercial contentmust not use any Snap-owned trademark, Bitmojiartwork or representations of the Snapchat userinterface, except as permitted in the Snapchat BrandGuidelines or the Bitmoji Bitmoji Brand Guidelines.Commercial content must also not contain altered orconfusingly similar variations of any Snap-ownedtrademark. The Commercial Content Policy also prohibitsDeceptive Content, which includes: ● False or misleading content, includingdeceptive claims, offers, functionality, orbusiness practices. 163 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? ● Promotion of fraudulent goods or services,including counterfeit documents orcertificates, or counterfeit products. ● Creating or sharing content that mimics theappearance or function of Snapchat featuresor formats. ● Deceiving calls to action, or bait-and-switchlinks to landing pages unrelated to the brandor content being promoted. ● Cloaking, otherwise restricting landing pageaccess, or modifications to URL contentfollowing submission in an attempt tocircumvent review. ● Encouraging dishonest behavior. (e.g.,commercial content related to fake IDs,plagiarism, essay writing services). ● Non-delivery of goods, or misrepresentedshipping delays or inventory constraints. ● Products or services principally dedicated toselling counterfeit products, such asimitations of designer or officially-licensedproducts. ● Products or services with false celebritytestimonials or usage. ● Deceptive financial products such as,payday loans, predatory lending, insider tipsrelating to financial products or services,get-rich-quick offers, pyramid schemes orother deceptive or too-good-to-be truefinancial offers. Ongoing Risk Detection and Management Reinforcing the internal processes, resources,testing, documentation, or supervision of any oftheir activities in particular as regards detectionof systemic risk. For example, we have specific prevalence testingand transparency reporting which we use to helpevaluate and manage Fraud and Spam. Prevalencetesting is generally not used for ads since they areprescreened and there is a higher bar for bad actorsfor ads since it requires payment configurations. Trusted Flaggers Initiating or adjusting cooperation with trustedflaggers in accordance with Article 22 and the We cooperate with trusted flaggers, our trustedflaggers may also report fraud spam, but this is notgenerally the focus of their efforts. 164 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? implementation of the decisions of out-of-courtdispute settlement bodies pursuant to Article 21. Codes and Crisis Protocols Initiating or adjusting cooperation with otherproviders of online platforms or of online searchengines through the codes of conduct and thecrisis protocols referred to in Articles 45 and 48respectively. we are members of severalorganizations and trade associations that tackleonline issues facing the industry. Transparency Taking awareness-raising measures andadapting their online interface in order to giverecipients of the service more information. We provide guidance on harms and how to get helpin our Safety Center. We make available robustreporting tools; and we provide guidance to parentson the web (see below). We have also supported theStopThinkFraud campaign on Snapchat. Protection of Minors Taking targeted measures to protect the rightsof the child, including age verification andparental control tools, tools aimed at helpingminors signal abuse or obtain support, asappropriate. We have protective measures to limit Teen contactwith strangers; we offer Family Center, reporting, andguidance. Our new parents site provides additionalguidance for parents and caregivers on risks andsupport.105 Content Authenticity Ensuring that an item of information, whether itconstitutes a generated or manipulated image,audio or video that appreciably resemblesexisting persons, objects, places or otherentities or events and falsely appears to aperson to be authentic or truthful isdistinguishable through prominent markingswhen presented on their online interfaces, and,in addition, providing an easy to usefunctionality which enables recipients of theservice to indicate such information. Snap has taken steps to mitigate the risk that (i) itsgenerative AI tools are used for creating illegal orotherwise violating content and (ii) illegal orotherwise violating content created using generativeAI tools on any online platform are disseminated onSnapchat’s inscope services. DSA Risk Factors In accordance with Section 3 (Methodology), we have also taken into account, in particular,whether and how the following service risk factors referenced in Article 34(2) of the DSAinfluence the risk of this harm on Snapchat’s in-scope services. As set out below, while the 105 https://parents.snapchat.com. 165 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT following risk factors could in principle influence this systemic risk, their overall impact is limitedgiven Snap’s existing mitigations, which are described later in this chapter and in Chapter 5. Service Risk Factor How does it apply to Snapchat and this harm? (a) the design of recommendersystems and any otherrelevant algorithmicsystem; Our recommender systems make it difficult for unvetted content,including Fraud and Spam, to reach a broad audience withoutmoderation. Our algorithmic systems are designed not to recommendcontent including Fraud and Spam. Detailed information relating to ourrecommender systems can be found in section 5 (see the AlgorithmicSystems sub-section). (b) content moderationsystems; Snap has implemented specific proactive and reactive contentmoderation procedures to prevent and remove Fraud and Spam. Asexplained in Section 5 (see Moderation), Snap for example deploys arange of automated content moderation features (that include text andsymbol classifiers that are trained on spam and fraud signals, as wellas labels, filters and back end rules). (c) the applicable terms andconditions andenforcement; Our Community Guidelines (which form part of our service) prohibitFraud and Spam and are strictly enforced. We provide moreinformation in section 5 (see the Terms and Enforcementsub-sections). (d) systems for selecting andpresenting advertisements;and Our advertising systems require agreement to advertising policies andguidance that prohibit adverts from displaying information thatviolates the law or causes certain harms. We check advertisers arecomplying with their obligations via our advertising review process.Our advertising systems use a mix of automation and human review toreview adverts before they are published. We provide easymechanisms for users to hide and report advertisements that violateour policies or the law. We monitor ad rejection, reporting andenforcement data to monitor the effectiveness of our approach. Weprovide more information in Section 5 (see the Advertising Systemssub-section). (e) our data related practices We have strong data principles, practices and privacy, safety andsecurity by design processes. We provide more information in Section5 (see the Transparency sub-section) and Section 6 (see the PlatformPrinciples Framework and Privacy and Safety by Design subsections). We have also analysed whether and how the risk of Fraud and Spam is influenced by thefollowing general factors: 166 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Service Risk Factor How does it apply to Snapchat and this harm? Intentional manipulation,including inauthentic use orinauthentic use or automatedexploitation of the service There are two key ways in which we consider our systems could bemanipulated: ● Users could seek to share novel illegal and violating materialthat is not detected by our automated systems. We areconstantly working to adjust our systems and policies toaddress this. We provide more information on our approach inSection 5 (in particular the Content Moderation subsection)and Section 6 (Ongoing Risk Detection and Management). ● Users could abuse our content moderation processes andreport non-violating content / accounts in bad faith. We haveprocesses to combat misuse and more information can befound in Section 5 (Content Moderation and Enforcementsubsections). Amplification and potentiallyrapid and wide dissemination ofillegal content and ofinformation that is incompatiblewith their terms and conditions. Snapchat’s inscope services have a number of features and designconfigurations that act to limit the amplification and potentially rapidand wide dissemination of Fraud and Spam, 1. Snapchat is not an attractive platform for spreading Fraud andSpam, in particular because it is difficult to reach a broadaudience and content is deleted by default. We provide moreinformation in Section 5 (see Snapchat Design / Functionsubsection) 2. Snap has implemented specific proactive and reactivemoderation procedures to prevent and remove Fraud andSpam. We provide more information in Section 5 (see ContentModeration). 3. Content recommended to users on Spotlight and Discover,our video sharing platforms, is moderated using acombination of auto-moderation and human moderation, andis human moderated before being widely distributed. Lensand Ads are subject to review processes before submission.We provide more information in Section 5 (see ContentModeration). Specific regional or linguisticaspects, including whenspecific to a Member State. We recognise that our users may come from different Member Statesand content may be shared in different languages. To address this, ● Snapchat is provided in multiple EU languages and our Termsare available in all EU languages. We provide moreinformation in Section 5 (see Terms). ● We deploy content moderation systems and moderators workacross multiple EU languages. We provide more informationin Section 5 (see Content Moderation). 167 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Conclusion We have assessed Fraud and Spam across both content and advertising to fall within our lowestlikelihood category. Given the risk of significant harm arising from Fraud and Spam, we categorizethis issue as a Level 3 overall risk prioritization. We handle significant volumes of enforcementand rejections every month. Our prevalent testing shows this is working, with significant furtherreductions in the prevalence of Fraud and Spam on public content surfaces of Snapchat. Adrejection rates have remained consistent with the overall increase in ads reviewed. However, wesee very low reports of violating ads, post-publication, including with respect to Fraud and Spam. As a result, we have concluded that Snapchat’s in-scope services have reasonable,proportionate and effective mitigation measures for Fraud and Spam. We are pleased with thefurther reductions in the prevalence of Fraud and Spam on Snapchat’s public content surfacesand the new evidence we have gathered which demonstrate that our ad review and rejectionprocesses are reasonable, proportionate and effective. 4.1.12 Dissemination of information related to Other Illegal Activities This Section 4.1.12 (Other Illegal Activities) considers the risk of harm arising from other illegalcontent and activity (as described in the Harm Description below), beyond the illegal harmcategories already referred to in this Section 4, on Snapchat’s in-scope services defined in Section 2 (Scope). We have assessed this risk in accordance with the Section 3 (Methodology) as follows. Harm Description As we allow users to publish content, we recognise that it is possible that information related toOther Illegal Activities not already captured by our other Snap Harm Categories above may bedisseminated on Snapchat. While laws and regulations differ in jurisdictions throughout the world – and Snapchat is a globalcommunity – our policies generally prohibit any activity that undermines public safety or violateshuman rights, the laws of the United States or the laws of the country in which the user is located.In all cases, prohibited illegal activities will include promotion of criminal activity (includingfacilitation or participation in cybercrime). Likelihood Our prevalence measurement and transparency reporting continue to track the prevalence ofknown significant issues that could potentially impact online platforms, including Snapchat, asinformed by our work with Trusted Flaggers, industry groups and our safety advisory board andinternal cross functional working groups. These categories are already addressed above, as inour 2024 Report, and we are not currently aware of other significant issues. 168 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT With the introduction of the Digital Services Act, we introduced a new reporting option to report‘illegal content’ in general. We have seen very few reports being made through this reportingoption and, when it is used, the quality of the reports are very low (for example, missing keyinformation to be able to identify the content in question and/or the illegal nature of the activity orthe report concerned harmless activity) and are usually not actionable. With regards to the verysmall number of reports that were actionable, almost all of these related to our existing illegal andother violating content categories referred to above. We have not observed any significant newillegal activity categories. As a result we still believe the dissemination of information related to Other Illegal Activities to fallwithin the lowest likelihood category relative to other risks identified by Snap. Snap has assessed the possibility of illegal content and activities occurring on Snapchat that isnot already covered by the Snap Harm Categories: ● We did not identify any external evidence that suggested there was a significant newcategory of illegal content or activity occurring on Snapchat. This includes consultationwith our Safety Advisory Board as referred to in Section 6 (Ongoing Risk Detection andMitigation). ● With regards to Internal Evidence: ○ With the introduction of the DSA, we introduced a new reporting option to report‘illegal content’ in general. It is worth noting that we have seen relatively fewreports being made through the existing DSA reporting option and we have notobserved any significant new activity that is not covered by our existing SnapHarm Categories / Community Guidelines categories. ○ We have assessed our community support requests and we have not observedany significant new activity that is not covered by our existing Snap HarmCategories / Community Guidelines categories. ○ As Section 5.10 shows, we do not engage trusted flaggers for illegal content ingeneral. We receive low volumes of reports relating to illegal activity from ourtrusted flaggers. Severity The extent of harm that might be risked by information relating to Other Illegal Activities woulddepend on the issue. Snap has specific categories for risks concerning the dissemination ofinformation which are most relevant to online platforms. As a result, we categorize the risk ofharm in general from information relating to Other Illegal Activities as significant. Snap wouldconsider the issue of illegal activity to be severe where the content includes a credible threat tohuman life, safety, or well-being. 169 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT DSA Risk Factors In accordance with Section 3 (Methodology), we have also taken into account, in particular,whether and how the following service risk factors referenced in Article 34(2) of the DSAinfluence the risk of this harm on Snapchat’s in-scope services. As set out below, while thefollowing risk factors could in principle influence this systemic risk, their overall impact is limitedgiven Snap’s existing mitigations, which are described later in this chapter and in Chapter 5. Service Risk Factor How does it apply to Snapchat and this harm? (a) the design of recommendersystems and any otherrelevant algorithmic system; Our recommender systems are designed not to knowinglyrecommend any illegal or harmful content or activities. Detailedinformation regarding the mitigations relating to ourrecommender systems can be found in Section 5 (see theAlgorithmic Systems sub-section) (b) content moderation systems; Snap has implemented specific proactive and reactivemoderation procedures to prevent and remove illegal andharmful content. Detailed information regarding Snap’s contentmoderation practices can be found in Section 5 (see ContentModeration sub-section). (c) the applicable terms andconditions and enforcement; Snap’s Community Guidelines (which form part of our terms ofservice) cover a wide range of topics, including illegal orregulated activities in general. Our terms are strictly enforced.Our policies generally prohibit any activity that underminespublic safety or violates human rights, the laws of the UnitedStates or the laws of the country in which the user is located. Inall cases, prohibited illegal activities will include promotion ofcriminal activity (including facilitation or participation incybercrime). With the introduction of the DSA, we introduced anew reporting option to report ‘illegal content’ in general. Weprovide more information in Section 5 (see the Terms andEnforcement sub-sections). (d) systems for selecting andpresenting advertisements;and Our advertising systems require agreement to advertisingpolicies and guidance that prohibit adverts from displayinginformation that violates the law or causes certain harms. Wecheck advertisers are complying with their obligations via ouradvertising review process. Our advertising systems use a mixof automation and human review to review adverts before theyare published. We provide easy mechanisms for users to hideand report advertisements that violate our policies or the law.We monitor ad rejection, reporting and enforcement data tomonitor the effectiveness of our approach. We provide moreinformation in Section 5 (see the Advertising Systems 170 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT sub-section) (e) our data related practices We have strong data principles, practices and privacy, safetyand security by design processes. We provide more informationin Section 5 (see the Transparency sub-section) and Section 6(see the Platform Principles Framework and Privacy and Safetyby Design subsections). We have also analysed whether and how the risk of Other Illegal Activities is influenced by thefollowing general factors: 171 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Snap's Mitigations In the table below we indicate the specific measures we have taken to mitigate this risk in respectof Snapchat’s in-scope services, using the defined list of mitigations set out in Article 35 of theDSA. The primary purpose of the below table is to indicate whether each specific mitigationcategory applies to this risk and the descriptions are illustrative rather than exhaustive. As manyof our mitigations apply to all of the risks assessed in this Report, to reduce duplication in thisReport, each row in the tables provides a link in the left hand column to a full summary of thespecific mitigation in Section 5 of this Report which explains in more detail how each mitigationoperates to reduce the risk. Mitigation Category Applies to this risk? Snapchat Design and Function Adapting the design, features orfunctioning of their services, includingtheir online interfaces. Yes, Snapchat’s in-scope services have been adapted toinclude proactive moderation for some Other Illegal Activities. Terms and Enforcement Adapting their terms and conditionsand their enforcement. Yes, our terms prohibit Other Illegal Activities and they arestrictly enforced. Our legal team, supported by externalcounsel as needed, reviews reports of new issues to confirmillegality and appropriate enforcement action. Moderation Adapting content moderationprocesses, including the speed andquality of processing notices related tospecific types of illegal content and,where appropriate, the expeditiousremoval of, or the disabling of accessto, the content notified, in particular inrespect of illegal hate speech or cyberviolence, as well as adapting anyrelevant decision-making processesand dedicated resources for contentmoderation. Yes, general proactive and reactive moderation procedures toprevent and remove Other Illegal Activities. Algorithmic Systems Testing and adapting their algorithmicsystems, including their recommendersystems. Yes, our algorithmic systems do not knowingly recommendinformation relating to illegal activity i.e. there is no ‘illegalactivity’ interest category. Advertising Systems Adapting their advertising systems andadopting targeted measures aimed at Yes, other mitigations listed here also apply to our AdvertisingSystems. 173 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT limiting or adjusting the presentationof advertisements in association withthe service they provide. Ongoing Risk Detection andManagement Reinforcing the internal processes,resources, testing, documentation, orsupervision of any of their activities inparticular as regards detection ofsystemic risk. We rely on our Trusted Flaggers, industry groups and our safety advisory board and internal cross functional workinggroups to ensure we are prioritizing the right issues. With theintroduction of the Digital Services Act, we have introduced anew reporting option to report ‘illegal content’ in general, andwe expect to use data gathered from this option to provide uswith greater visibility on the prevalence of information relatingto other illegal activity on Snapchat. Trusted Flaggers Initiating or adjusting cooperation withtrusted flaggers in accordance withArticle 22 and the implementation ofthe decisions of out-of-court disputesettlement bodies pursuant to Article21. Yes, we cooperate with trusted flaggers who are able to flagOther Illegal Activities. Codes and Crisis Protocols Initiating or adjusting cooperation withother providers of online platforms orof online search engines through thecodes of conduct and the crisisprotocols referred to in Articles 45 and48 respectively. Yes, we cooperate with other providers through variousindustry groups on prominent issues facing online platforms. Transparency Taking awareness-raising measuresand adapting their online interface inorder to give recipients of the servicemore information. Yes, we provide guidance on our terms, harms, moderationand enforcement practices (see the Annex), as well as how toand how to get help in our Safety Center. Protection of Minors Taking targeted measures to protectthe rights of the child, including ageverification and parental control tools,tools aimed at helping minors signalabuse or obtain support, asappropriate. Yes, we have protective measures to limit Teen contact withstrangers; we offer Family Center; we make available robustreporting; and we provide guidance to parents on the web. Ourparents site provides additional guidance for parents andcarers on risks and support.106 Content Authenticity No specific content authenticity measures taken in respect of 106 https://parents.snapchat.com. 174 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Ensuring that an item of information,whether it constitutes a generated ormanipulated image, audio or videothat appreciably resembles existingpersons, objects, places or otherentities or events and falsely appearsto a person to be authentic or truthfulis distinguishable through prominentmarkings when presented on theironline interfaces, and, in addition,providing an easy to use functionalitywhich enables recipients of the serviceto indicate such information. information relating to illegal activities. Snap has taken steps tomitigate the risk that (i) its generative AI tools are used forcreating illegal or otherwise violating content and (ii) illegal orotherwise violating content created using generative AI toolson any online platform are disseminated on Snapchat’sinscope services. Conclusion We prohibit the dissemination of information relating to illegal activities and criminal activity in our Terms. We specifically track the issues relating to the dissemination of information which weconsider to have the most relevance to online platforms, such as Snapchat. We treat otherdissemination issues as a Level 3 overall potential risk compared to other harms. We regularlyreview our risk categories using our Risk Detection and Management processes. We have seenfew reports using our new option to report ‘other illegal activity’ and have seen any newcategories emerge as the vast majority are either not actionable or relate to one of our existingcategories. As a result, we have concluded that Snapchat’s in-scope services have reasonable,proportionate and effective mitigation measures for information relating to Other IllegalActivities. Since our 2024 Report, we have monitored DSA enquiries, including to our newreporting option, but have so far not identified any new trends or the need to establish newillegal or harmful content categories. 4.2 Category 2: Negative Effects on Fundamental EU Rights (Article 34.1.b / DSA Recital 81) In this part of the Report, we explain the results of our assessment on actual or foreseeablenegative effects of Snapchat’s in-scope services on our Fundamental EU Rights as required byArticle 34.1.b and Recital 81 of the Digital Services Act. Those Fundamental EU Rights are set outin the Charter of Fundamental Rights of the European Union (the “Charter”)107. We have assessedin particular the rights to human dignity, freedom of expression and of information, includingmedia freedom and pluralism, private life, data protection, non-discrimination and consumerprotection. We also consider the rights of the child, including how easy it is for Teens to 107 Charter of Fundamental Rights of the European Union (url). 175 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT understand the design and functioning of the service, as well as how Teens can be exposedthrough their service to content that may impair Teens’ health, physical, mental and moraldevelopment. Such risks may arise, for example, in relation to the design of online interfaceswhich intentionally or unintentionally exploit the weaknesses and inexperience of Teens or whichmay cause addictive behavior. Note that for all harms, where there is (1) a risk of significant damage to the physical or emotionalwell-being of Snapchatters, and (2) imminent, credible risk of severe harm, including threats tohuman life, safety, and well-being, we treat this as a severe harm and an Level 1 overall riskprioritization. Category 2 - Negative effects on Fundamental EU Rights Category Relative likelihoodof risk occurringon Snapchat Harmclassificationindustry wide Risk Prioritization Conclusion 4.2.1 Right toHuman Dignity Extremely LowLikelihood Severe harmindustry wide Level 1 Low Risk /Reasonable,proportionate andeffective 4.2.2 Right toFreedom ofExpression Extremely LowLikelihood Significant harmindustry wide Level 3 Low Risk /Reasonable,proportionate andeffective 4.2.3 Right toPrivate Life Extremely LowLikelihood Serious harmindustry wide Level 2 Low Risk /Reasonable,proportionate andeffective 4.2.4 Right to DataProtection Low Likelihood Severe harmindustry wide Level 1 Low Risk /Reasonable,proportionate andeffective 4.2.5 Right toNon-Discrimination and Freedom ofReligion Extremely LowLikelihood Serious harmindustry wide Level 3 Low Risk /Reasonable,proportionate andeffective 4.2.6 Children’sRights Extremely LowLikelihood Severe harmindustry wide Level 1 Low Risk /Reasonable,proportionate andeffective and weare activelyparticipating inefforts to develop 176 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT an EU wideguidance toassess if furtherindustry measuresare needed. 4.2.7 Right toConsumerProtection Extremely LowLikelihood Significant harmindustry wide Level 3 Low Risk /Reasonable,proportionate andeffective 4.2.8 Right toProperty N/A. Already covered under Category 1: Dissemination of content that infringes onintellectual property rights 4.2.1 Right to Human Dignity All public spaces displaying user generated content have the potential for the dissemination ofcontent that may undermine Human Dignity. We recognise that without mitigation such contentcould conceivably appear in any of Snapchat’s in-scope services displaying user generatedcontent, from videos featured on Spotlight / Discover, to Place Stories on Snap Map. Advertisingcould, for example, include Hate Speech or discriminatory elements. Snapchat, as with otherplatforms that host user generated content, may be used to spread content that underminesrespect for Human Dignity. All of the risks we track on Snapchat have a low prevalence comparedto the prevalence of these issues elsewhere online and offline. To aid our prioritization, ourmethodology seeks to assess the relative likelihood between the risks we track (even though allare low in absolute terms). Without mitigations, this could include content that promotes: ● Human trafficking and/or the sale of coerced sex; ● Child sexual abuse material; ● Terrorism; ● Self-harm, including the promotion of self-injury, suicide or eating disorders; ● Incitement to violence or hatred directed against a group of persons or a member of agroup based on any of the grounds referred to in Article 21 of the Charter. As Snap takes these issues very seriously and has implemented several levers to prevent thiscontent from being distributed on the platform Likelihood We have assessed the relative likelihood of Snapchat’s inscope services disseminating contentthat may undermine Human Dignity, based on Policy Violating Prevalence (PVP) via randomsampling and our transparency report data in Section 4.1 of this Report, as follows: 177 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Category Relative likelihood of riskoccurring on Snapchat 4.1.1 Dissemination of Child Sexual Abuse Material Extremely Low 4.1.2 Dissemination of Illegal Hate Speech Extremely Low 4.1.4 Dissemination of Terrorist Content Extremely Low 4.1.6 Dissemination of Adult Sexual Content Extremely Low 4.1.8 Dissemination of content that glorifies Self-Harm, including the Promotionof Self-Injury, Suicide or Eating Disorders Extremely Low We therefore continue to assess that the relative likelihood that the in-scope services ofSnapchat would have an actual or foreseeable negative effects of the Right to Human Dignityfalls within our Extremely low likelihood category. Severity The Council of Europe recognises that the misuse of social media can trigger numerous harmfulconsequences, including the risk threatening human dignity, and flagged examples such as HateSpeech, incitement to violence and discrimination, etc.108 We have assessed the severity of harmcaused by each of these categories of content that significantly undermines the Right to HumanDignity in Section 4.1 of this Report, as follows: Category Relative likelihood of riskoccurring on Snapchat 4.1.1 Dissemination of Child Sexual Abuse Material Severe harm industry wide 4.1.2 Dissemination of Illegal Hate Speech Significant harm industrywide 4.1.4 Dissemination of Terrorist Content Serious harm industry wide 4.1.6 Dissemination of Adult Sexual Content Serious harm industry wide 4.1.8 Dissemination of content that glorifies Self-Harm, including the promotionof Self-Injury, Suicide or Eating Disorders Serious harm industry wide Our assessment shows a variety of harm ranging from significant to the most severe. We continueto choose to assess the category of actual or foreseeable negative effects of the Right to HumanDignity using the highest severity rating of the categories we have assessed. Several of them,including CSEAI and human trafficking, have been identified as ‘Severe Harms’ in our Community 108 Council of Europe, ‘Social media: social threads or threats to human rights’ January 2017, url. 178 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Snap's Mitigations In the table below we indicate the specific measures we have taken to mitigate this risk in respectof Snapchat’s in-scope services, using the defined list of mitigations set out in Article 35 of theDSA. The primary purpose of the below table is to indicate whether each specific mitigationcategory applies to this risk and the descriptions are illustrative rather than exhaustive. As many of our mitigations apply to all of the risks assessed in this Report, to reduce duplicationin this Report, each row in the tables provides a link in the left hand column to a full summary ofthe specific mitigation in Section 5 of this Report which explains in more detail how eachmitigation operates to reduce the risk. Mitigation Category Applies to this risk? Snapchat Design and Function Adapting the design, features or functioning oftheir services, including their online interfaces. Yes, Snapchat’s in-scope services have beenadapted to include proactive moderation for CSEAIand other illegal content that undermines HumanDignity. We also have tools within the app whereindividuals can report this type of activity to ourTrust and Safety team. When our Trust and Safety team recognizes aSnapchatter in distress, they can forward self-harmprevention and support resources, and notifyemergency personnel when appropriate. Forexample, if a user searches for suicide relatedterms we will surface our Here For You tool. Terms and Enforcement Adapting their terms and conditions and theirenforcement. Yes, our Terms prohibit CSEAI and other illegalcontent that undermines Human Dignity and theyare strictly enforced. Moderation Adapting content moderation processes, includingthe speed and quality of processing notices relatedto specific types of illegal content and, whereappropriate, the expeditious removal of, or thedisabling of access to, the content notified, inparticular in respect of illegal hate speech or cyberviolence, as well as adapting any relevantdecision-making processes and dedicatedresources for content moderation. Yes, specific proactive and reactive moderationprocedures to prevent CSEAI and other illegalcontent that undermines Human Dignity. We have terms in place to prevent Media Partnersfrom publishing illegal or harmful content onDiscover. All Media Partners are vetted prior tobeing permitted to distribute their content broadlyon Snapchat by a team of editors. Media Partnersgo through an editorial review of their content, areputational search (to evaluate if a Media Partner 180 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT has a history damaging press, legal actions, etc.),and compliance review before they’re able todistribute content. Media partners are proactivelymoderated, and the content of their shows/editionsare reactively moderated. Senior partner managerswill relay feedback to Media Partners to remove orchange content. If a partner refuses, we could justremove it ourselves, but partners typically comply. Algorithmic Systems Testing and adapting their algorithmic systems,including their recommender systems. Yes, our algorithmic systems do not knowinglyrecommend content that would negatively affectthe Right to Human Dignity i.e. there are nointerest categories that we consider to negativelyaffect Human Dignity. Advertising Systems Adapting their advertising systems and adoptingtargeted measures aimed at limiting or adjustingthe presentation of advertisements in associationwith the service they provide. Yes, other mitigations listed here also apply to ourAdvertising Systems. Ongoing Risk Detection and Management Reinforcing the internal processes, resources,testing, documentation, or supervision of any oftheir activities in particular as regards detection ofsystemic risk. Yes, we have specific prevalence testing andtransparency reports for CSEAI, Terrorist Content,and other illegal content that undermines HumanDignity. Trusted Flaggers Initiating or adjusting cooperation with trustedflaggers in accordance with Article 22 and theimplementation of the decisions of out-of-courtdispute settlement bodies pursuant to Article 21. Yes, we cooperate with trusted flaggers in relationto CSEAI and other illegal content that underminesHuman Dignity. Codes and Crisis Protocols Initiating or adjusting cooperation with otherproviders of online platforms or of online searchengines through the codes of conduct and thecrisis protocols referred to in Articles 45 and 48respectively. Yes, we cooperate with other providers throughvarious industry groups Transparency Taking awareness-raising measures and adaptingtheir online interface in order to give recipients ofthe service more information. Yes, we provide guidance on our terms, harms,moderation and enforcement practices (see the Annex), as well as how to get help in our SafetyCenter. For example, if a user searches for suiciderelated terms we will surface our Here For You tool. 181 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Protection of Minors Taking targeted measures to protect the rights ofthe child, including age verification and parentalcontrol tools, tools aimed at helping minors signalabuse or obtain support, as appropriate. Yes, we have protective measures to limit Teencontact with strangers; we offer Family Center; wemake available robust reporting; and we provideguidance to parents on the web. Our parents siteprovides additional guidance for parents andcarers on risks and support.109 Content Authenticity Ensuring that an item of information, whether itconstitutes a generated or manipulated image,audio or video that appreciably resembles existingpersons, objects, places or other entities or eventsand falsely appears to a person to be authentic ortruthful is distinguishable through prominentmarkings when presented on their onlineinterfaces, and, in addition, providing an easy touse functionality which enables recipients of theservice to indicate such information. Some content authenticity measures have beentaken in respect of content that underminesHuman Dignity. Snap has taken steps to mitigatethe risk that (i) its generative AI tools are used forcreating illegal or otherwise violating content and(ii) illegal or otherwise violating content createdusing generative AI tools on any online platformare disseminated on Snapchat’s inscope services. Conclusion Snap considers risks to Human Dignity to have a Level 1 overall potential risk. In response it hasput in place a range of mitigation measures. This includes in particular our proactive content Moderation which is designed to detect and prevent CSEAI from appearing on each ofSnapchat’s in-scope services. For example, our automated and human review on Spotlight. Ourprevalence testing has allowed us to improve this proactive content moderation. As a result,we’ve reduced the prevalence of CSEAI and other content that may undermine human dignity onSnapchat’s in-scope services to the lowest likelihood level. See Section 4.1.1 (dissemination ofchild sex abuse material). Similarly, dissemination of Terrorist Content is not prevalent on Snap. 4.2.2 Right to Freedom of Expression and Assembly Snapchat is a platform whose mission is to empower people to express themselves, live in themoment, learn about the world, and have fun together. By design, the platform itself presents anopportunity to enhance the freedom of expression, information and assembly of Snapchatters. 109 https://parents.snapchat.com. 182 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT However, Snap, alongside other digital platforms hosting user-generated content, presents somerisk to these rights and freedoms. Likelihood All of the risks we track on Snapchat have a low prevalence compared to the prevalence of theseissues elsewhere online and offline. To aid our prioritization, our methodology seeks to assessthe relative likelihood between the risks we track (even though all are low in absolute terms). It is difficult to quantify the likely risk of negative impact on Freedom of Expression and Assembly.Algorithmic biases and self-censorship are difficult to detect. We rely on user feedback andtesting to flag significant incidents. At present, we are not aware of any significant bias ofself-censorship issues in the algorithms used by Snapchat’s in-scope services. We continue tomonitor the number and nature of the general community support requests we receive and thisdata does not identify any trend that suggests Snapchat may be negatively impacting Freedom ofExpression and Assembly. Our Transparency Reports continue to show that we receive lowincidents of illegal content reports from recipients of Snapchat or authorities that we chose not totake action Based on the 183 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT lack of reporting Snap has received and the overall design of Snapchat (which does not generallyprovide a platform for political public content in general), we deem this the extremely lowlikelihood category in terms of likelihood. Severity Snap has assessed information published by governments and other third party sources andconsiders that if content that may undermine human dignity were to materialise on an onlineplatform it would fall within our significant harm category. However, Snapchat generally is not aplatform for political or activist content and so the impact on freedom of expression and assemblyis unlikely to be severe on Snapchat compared with other spaces on the internet dedicated tosuch content. DSA Risk Factors In accordance with Section 3 (Methodology), we have also taken into account, in particular,whether and how the following service risk factors referenced in Article 34(2) of the DSAinfluence the risk of this harm on Snapchat’s in-scope services. As set out below, while thefollowing risk factors could in principle influence this systemic risk, their overall impact is limitedgiven Snap’s existing mitigations, which are described later in this chapter and in Chapter 5. Service Risk Factor How does it apply to Snapchat and this harm? 111 184 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT (a) the design of recommendersystems and any otherrelevant algorithmic system; Our recommender systems are designed not to knowinglyrecommend content that impedes the right to Freedom ofExpression and Assembly. Detailed information regarding themitigations relating to our recommender systems can be foundin Section 5 (see the Algorithmic Systems sub-section). (b) content moderation systems; Snap has implemented specific proactive and reactivemoderation procedures to make it difficult for unvetted contentto reach a large audience on Snapchat, and Snap proactivelymoderates Snapchat’s in-scope services that provide anopportunity to reach a larger audience. We provide moreinformation in Section 5 (see Content Moderation sub-section). (c) the applicable terms andconditions and enforcement; Our Community Guidelines (which form part of our terms ofservice)clearly define certain topics which we prohibit,including false information that threatens Public Health (e.g.COVID-19 vaccinations), civic processes, or that denies tragicevents (like the Holocaust). These terms are strictly enforcedgiven the risk of severe harm. We provide more information inSection 5 (see the Terms and Enforcement sub-sections). (d) systems for selecting andpresenting advertisements;and Our advertising systems require agreement to advertisingpolicies and guidance that prohibit adverts from displayinginformation that violates the law or causes certain harms. Wecheck advertisers are complying with their obligations via ouradvertising review process. Our advertising systems use a mixof automation and human review to review adverts before theyare published. We provide easy mechanisms for users to hideand report advertisements that violate our policies or the law.We monitor ad rejection, reporting and enforcement data tomonitor the effectiveness of our approach. We provide moreinformation in Section 5 (see the Advertising Systemssub-section). (e) our data related practices We have strong data principles, practices and privacy, safetyand security by design processes. We provide moreinformation in Section 5 (see the Transparency sub-section)and Section 6 (see the Platform Principles Framework andPrivacy and Safety by Design subsections). We have also analysed whether and how the risk of serious Negative Effects on the Right toFreedom of Expression and Assembly is influenced by the following general factors: General Risk Factor How does it apply to Snapchat and this harm? 185 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Intentional manipulation, includinginauthentic use or inauthentic use orautomated exploitation of the service There are two key ways in which we consider our systemscould be manipulated:(1) Users could seek to share novel illegal and violatingmaterial that is not detected by our automatedsystems. We are constantly working to adjust oursystems and policies to address this. We provide moreinformation on our approach in Section 5 (in particularthe Content Moderation subsection) and Section 6(Ongoing Risk Detection and Management).(2) Users could abuse our content moderation processesand report non-violating content / accounts in badfaith. We have processes to combat misuse and moreinformation can be found in Section 5 (ContentModeration and Enforcement subsections). Amplification and potentially rapid andwide dissemination of illegal contentand of information that is incompatiblewith their terms and conditions. Snapchat’s inscope services have a number of features anddesign configurations that act to limit the harms to theexercise of the Right toFreedom of Expression and Assembly,in particular: 1. Snapchat is generally not a place for political oractivist public content. Such content is not eligible forpromotion on Spotlight and user content on Discoveris only from a small number of popular, entertainingcommunity creators and their content is moderated byhumans against our Content Guidelines. 2. Snap makes it difficult for unvetted content to reach alarge audience on Snapchat, and Snap proactivelymoderates Snapchat’s in-scope services that providean opportunity to reach a larger audience. We providemore information in Section 5 (see Snapchat Design /Function subsection). 3. Content recommended to users on Spotlight andDiscover, our video sharing platforms, is moderatedusing a combination of auto-moderation and humanmoderation, and is human moderated before beingwidely distributed. Lens and Ads are subject to reviewprocesses before submission. We provide moreinformation in Section 5 (see Content Moderation) Specific regional or linguistic aspects,including when specific to a MemberState. We recognise that our users may come from different MemberStates and content may be shared in different languages. Toaddress this, ● Snapchat is provided in multiple EU languages andour Terms are available in all EU languages. Weprovide more information in Section 5 (see Terms). 186 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? Snapchat Design and Function Adapting the design, features orfunctioning of their services, including theironline interfaces. Yes, several aspects of Snapchat’s design and functionreduce the risk for the Freedom of Expression andAssembly: ● Snap makes it difficult for unvetted content toreach a large audience on Snapchat, and Snapproactively moderates Snapchat’s in-scopeservices that provide an opportunity to reach alarger audience. ● Our platform is generally not a place for politicalor activist public content. Such content is noteligible for promotion on Spotlight and usercontent on Discover is only from a small numberof popular, entertaining community creators andtheir content is moderated by humans against ourContent Guidelines. ● All Media Partners are vetted prior to beingpermitted to distribute their content broadly onSnapchat by a team of editors. These Partnersinclude news organizations, which are subject totheir own professional rules. Media Partners gothrough an editorial review of their content, areputational search (to evaluate if a publisher hasa history damaging press, legal actions, etc.), andcompliance review before they’re able todistribute content. As a result, we provide abalanced approach to political and activist publiccontent on Snapchat that is designed to limit thesources of such information to professional mediapartners. ● As explained when discussing the disseminationof content that infringes on intellectual propertyrights, Snap respects the doctrine of “fair use,”i.e., that there are certain circumstances (such asnews reporting, social commentary on issues ofpublic interest, criticism, parody, or education)where excerpts of copyrighted material could bedistributed without permission from or payment tothe copyright holder. This helps reinforce therights of Freedom of Expression and the Freedomof Assembly. Terms and Enforcement Snap’s Terms and Community Guidelines clearly define 188 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? Adapting their terms and conditions andtheir enforcement. certain topics which we prohibit, including falseinformation that threatens Public Health (e.g. COVID-19vaccinations), civic processes, or that denies tragic events(like the Holocaust). We expressly prohibit harmful false ordeceptive information and they are strictly enforced. Werespond with swift and strict consequences againstviolators as explained in our explainer. We promptly enforce against accounts found to besending terrorism content: ● Snap removes such content for all users. ● Accounts we discover engaging in prohibitedterrorist activity will also be promptly disabled. ● Where appropriate, accounts engaging inviolation of these policies may be reported to lawenforcement. Moderation Adapting content moderation processes,including the speed and quality ofprocessing notices related to specific typesof illegal content and, where appropriate,the expeditious removal of, or the disablingof access to, the content notified, inparticular in respect of illegal hate speechor cyber violence, as well as adapting anyrelevant decision-making processes anddedicated resources for contentmoderation. Yes, we have specific proactive and reactive moderationprocedures to prevent and remove violative content. As explained in the Content Moderation section in Section5 of this Report, Snap deploys a range of automatedcontent moderation (which include abusive languagedetection, other keyword-based detection, andmachine-learning-based proactive detection models) toscan Stories and Spotlight submissions. Snapchatters canreport violative content to us via in-app reporting optionsand anyone can submit a report through the SnapchatSupport Site. Our in-app reporting tool also allows usersto directly report violative content. Algorithmic Systems Testing and adapting their algorithmicsystems, including their recommendersystems. Yes, unlike many of our peers, Snapchat does not offer anopen news feed where unvetted publishers or individualshave an opportunity to broadcast violative content, doesnot offer a broad ‘reshare’ functionality that wouldencourage virality, and does not allow user-generatedcontent to be recommended to a wide audience withoutgoing through review. Our algorithmic systems do not knowingly recommendviolative content. As explained in the Content Moderation section in Section 5 of this Report, on our high-reach 189 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? surfaces, like Spotlight and Discover, we take a proactiveapproach to moderating any content that may violatethese rules prior to the content being recommended to awide audience. The pool of content recommended by our algorithmicsystems does not generally include political or otherimportant societal matters regardless of where they fall onthe political spectrum. Advertising Systems Adapting their advertising systems andadopting targeted measures aimed atlimiting or adjusting the presentation ofadvertisements in association with theservice they provide. Yes, other mitigations listed here also apply to ourAdvertising Systems. Ongoing Risk Detection and Management Reinforcing the internal processes,resources, testing, documentation, orsupervision of any of their activities inparticular as regards detection of systemicrisk. Yes, for example we monitor data to help detect andmanage content that may present a risk for the Right toFreedom of Expression, including data from our specificprevalence testing and enforcements (which aresummarised in our Transparency Reports). Trusted Flaggers Initiating or adjusting cooperation withtrusted flaggers in accordance with Article22 and the implementation of the decisionsof out-of-court dispute settlement bodiespursuant to Article 21. No, we do not work with trusted flaggers for users’ rightsto Freedom of Expression and access to accurateinformation. Codes and Crisis Protocols Initiating or adjusting cooperation withother providers of online platforms or ofonline search engines through the codesof conduct and the crisis protocols referredto in Articles 45 and 48 respectively. Yes, our Crisis Protocols handle issues related to users’rights to Freedom of Expression and access to accurateinformation.Note, we will continue to reassess and explore theopportunity to join the EU disinformation code. Transparency Taking awareness-raising measures andadapting their online interface in order togive recipients of the service moreinformation. Yes, we provide guidance on harms and how to get helpin our Safety Center. We make available robust reportingtools; and we provide guidance to parents on the web(see below). 190 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? Protection of Minors Taking targeted measures to protect therights of the child, including age verificationand parental control tools, tools aimed athelping minors signal abuse or obtainsupport, as appropriate. Yes, we have protective measures to limit Teen contactwith strangers; we offer Family Center, reporting, andguidance. Our new parents site provides additionalguidance for parents and caregivers on risks andsupport.112 Content Authenticity Ensuring that an item of information,whether it constitutes a generated ormanipulated image, audio or video thatappreciably resembles existing persons,objects, places or other entities or eventsand falsely appears to a person to beauthentic or truthful is distinguishablethrough prominent markings whenpresented on their online interfaces, and,in addition, providing an easy to usefunctionality which enables recipients ofthe service to indicate such information. Yes, Snap has taken steps to mitigate the risk that (i) itsgenerative AI tools are used for creating illegal orotherwise violating content and (ii) illegal or otherwiseviolating content created using generative AI tools on anyonline platform are disseminated on Snapchat’s inscopeservices. Conclusion Snap continues to consider the overall risk to be within the level 3 risk prioritization categorygiven the stakes and the severity of threats to Freedom of Expression, despite low prevalenceand robust protections in place. Snap’s mission is to be an expressive platform where users canbe their authentic self, and we view our obligation to facilitate Freedom of Expression asfoundational. While harms to Freedom of Expression are hard to detect, and we are not aware ofany significant bias of self-censorship issues in the algorithms used by Snapchat’s in-scopeservices, we provide avenues for our users to report these issues to us, and we value andrespect user feedback. We continually evaluate and evolve our algorithms, including to reduceperceived biases, and monitor for and respond to events that could impact Freedom ofExpression. We couple this with enforcement of our Terms and our robust Moderation practicesto provide a platform where users feel free to express themselves in the world. We have concluded therefore that Snapchat’s in-scope services have reasonable,proportionate and effective mitigation measures to address risks relating to Freedom ofExpression. Snap monitors its impact on this fundamental right category to confirmprevalence continues to decline, or whether further mitigating measures might be required.There is no change in this conclusion from our 2024 Report. 112 https://parents.snapchat.com. 191 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 4.2.3 Right to Private Life We understand well that online platforms can be used to spread content that undermines respectfor private and family life (Right to Private Life), and that such content can have traumaticconsequences if not properly mitigated. On Snapchat, without mitigations, content thatundermines private and family life and personal data privacy could conceivably appear in any ofSnapchat’s in-scope services displaying user generated content, including information in videosfeatured on Spotlight / Discover and Snap Map. Snapchat’s platform architecture, combined withits commitment to responsible policy enforcement across our content surfaces, establishessafeguards against negative impacts to the private life of users. Likelihood In our 2024 Report, we explained that: ● Our prevalence testing as at 30 July 2024 showed that “invasion of privacy” had seen afurther, substantial fall It is now at a very low level. ● Overall we have seen aslight increase in line with expectations and we continue to receive low numbers ofprivacy-related queries.113 In our 2025 Report, we observed the following: ● As of 30 April 2025, our prevalence testing indicated a slight increase in reports of“invasion of privacy,” though the overall level remains very low at 0.0109%. ● We therefore continue to assess that the relative likelihood that the in-scope services ofSnapchat would have an actual or foreseeable Negative Effects on the Right to Private Life fallswithin our Extremely low likelihood category. 113 Note that these numbers exclude requests we receive from automated services for data requests, and generalsupport tickets. 192 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Severity Snap takes risks to privacy very seriously. Online platforms can be used to spread content thatundermines respect for private and family life, home and communications, and personal dataincluding by distributing surreptitious or non-consensual imagery of intimate activities, privatemovements, or identifying information; distributing deceptive content that involves theimpersonation of friends, celebrities, public figures for harmful, non-satirical purposes; or contentdepicting Teens without parental consent. Without mitigations, content that undermines the Rightto Private Life could find reach, particularly if it is of a nature of high public interest (such ascelebrity voyeurism or doxxing) or if it appeals to the prurient interests of some people (e.g.,certain non-consensual intimate imagery), which is why Snap enforces against this contentrobustly. The severity of this risk lies not only in the immediacy of harm but in its potential to causeenduring psychological, reputational, and social damage. Victims may suffer from anxiety, fear,social isolation, or ongoing harassment - especially when content is widely circulated orpermanently archived online. In the case of minors, the impact can be particularly profound,potentially affecting their development, education, and digital confidence. The nature of suchviolations, especially when tied to sensitive or identity-compromising content, underscores theneed for swift enforcement and proactive prevention. Snap recognizes this and treats violationsof privacy-related rights as a serious threat to user safety on the platform and consequentlyconsider it to fall within our serious harm category. DSA Risk Factors In accordance with Section 3 (Methodology), we have also taken into account, in particular,whether and how the following service risk factors referenced in Article 34(2) of the DSAinfluence the risk of this harm on Snapchat’s in-scope services. As set out below, while thefollowing risk factors could in principle influence this systemic risk, their overall impact is limitedgiven Snap’s existing mitigations, which are described later in this chapter and in Chapter 5. Service Risk Factor How does it apply to Snapchat and this harm? (a) the design of recommendersystems and any otherrelevant algorithmic system; Our recommender systems are designed not to knowinglyrecommend harmful content which impedes the exercise of theRight to Private Life. Detailed information regarding themitigations relating to our recommender systems can be foundin Section 5 (see the Algorithmic Systems sub-section). (b) content moderation systems; Snap has implemented specific proactive and reactivemoderation procedures to prevent and remove harmfulcontent which could impede the exercise of the Right toPrivate Life. As explained in the Content Moderation Section,Snap deploys a range of specific proactive and reactive 193 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT moderation procedures to protect the privacy interests of ourcommunity. We provide more information in Section 5 (seeContent Moderation sub-section). (c) the applicable terms andconditions and enforcement; Our Community Guidelines (which form part of our terms ofservice) prohibit impersonation, our Commercial Content Policy prohibits non-consensual sexual material and our SpotlightTerms require “you must have any necessary third-party rightsincluding, without limitation, music copyrights and rights ofpublicity, for all content in your Snaps”. (d) systems for selecting andpresenting advertisements;and Our advertising systems require agreement to advertisingpolicies and guidance that prohibit adverts from displayinginformation that violates the law or causes certain harms. Wecheck advertisers are complying with their obligations via ouradvertising review process. Our advertising systems use a mixof automation and human review to review adverts before theyare published. We provide easy mechanisms for users to hideand report advertisements that violate our policies or the law.We monitor ad rejection, reporting and enforcement data tomonitor the effectiveness of our approach. We provide moreinformation in Section 5 (see the Advertising Systemssub-section) (e) our data related practices We have strong data principles, practices and privacy, safetyand security by design processes. Indeed, Privacy by Design isSnap’s approach to building products that consider userprivacy from inception. Each product is subject to a PASSReview (Privacy Assessment System) to ensure that ourproducts do not misuse user-data. We provide moreinformation in Section 5 (see the Transparency sub-section)and Section 6 (see the Platform Principles Framework andPrivacy and Safety by Design subsections). We have also analysed whether and how the risk of Negative Effects on the Right to Private Lifeis influenced by the following general factors: 194 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 195 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Adapting their terms and conditions andtheir enforcement. non-consensual sexual material and our Spotlight Terms require “you must have any necessary third-party rightsincluding, without limitation, music copyrights and rights ofpublicity, for all content in your Snaps”. Moderation Adapting content moderation processes,including the speed and quality ofprocessing notices related to specifictypes of illegal content and, whereappropriate, the expeditious removal of,or the disabling of access to, the contentnotified, in particular in respect of illegalhate speech or cyber violence, as well asadapting any relevant decision-makingprocesses and dedicated resources forcontent moderation. Yes, specific proactive and reactive moderation proceduresto protect the privacy interests of our community. Users have the ability to report Snaps and the reportingmenu includes options such as “They leaked / arethreatening to leak my nudes”, , “It involves a child” Algorithmic Systems Testing and adapting their algorithmicsystems, including their recommendersystems. Yes, our algorithmic systems do not categorize orrecommend content that violates users’ Right to Private Life. For example, we have terms, moderation and enforcementto prevent distribution of illegal / violating content. We alsodo not process sensitive category information. Advertising Systems Adapting their advertising systems andadopting targeted measures aimed atlimiting or adjusting the presentation ofadvertisements in association with theservice they provide. Yes, other mitigations listed here also apply to ourAdvertising Systems. For example, Snap ensures that adsshown are in line with its Snap Advertising Policies whichstates that advertisements do not collect sensitiveinformation or special category of data. We also ensureadvertisers are not targeting specific individuals on ourplatform and that users do not feel like their privacy is beingcompromised by our advertising. Ongoing Risk Detection andManagement Reinforcing the internal processes,resources, testing, documentation, orsupervision of any of their activities inparticular as regards detection ofsystemic risk. Yes, we have specific prevalence testing and TransparencyReports for sexual content and intrusion of privacy. We also monitor privacy-related inquiries as detailed above. Trusted Flaggers Initiating or adjusting cooperation withtrusted flaggers in accordance with Yes, we cooperate with trusted flaggers in relation to sexualcontent and Teen safety which may impact users’ Right toPrivate Life. 197 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Article 22 and the implementation of thedecisions of out-of-court disputesettlement bodies pursuant to Article 21. Codes and Crisis Protocols Initiating or adjusting cooperation withother providers of online platforms or ofonline search engines through the codesof conduct and the crisis protocolsreferred to in Articles 45 and 48respectively. Yes, we cooperate with other providers through variousindustry groups e.g. CIPL, FPF. Our content moderation policies provide de facto contentmoderation crisis protocol. Transparency Taking awareness-raising measures andadapting their online interface in order togive recipients of the service moreinformation. Yes, we provide guidance on our terms, harms, moderationand enforcement practices (see the Annex), as well as howto and how to get help in our Safety Center. Our Privacy Center offers a suite of information on ourproducts, users’ choices to safeguard their privacy and howto contact us. Protection of Minors Taking targeted measures to protect therights of the child, including ageverification and parental control tools,tools aimed at helping minors signalabuse or obtain support, as appropriate. Yes, we have protective measures in place for Teens. Ourreporting menu also includes the option to report “Itinvolves a child”. Our Family Center includes resources and guidance forTeens and their parents or trusted adults. Our parents siteprovides additional guidance for parents and carers on risksand support.114 Content Authenticity Ensuring that an item of information,whether it constitutes a generated ormanipulated image, audio or video thatappreciably resembles existing persons,objects, places or other entities or eventsand falsely appears to a person to beauthentic or truthful is distinguishablethrough prominent markings whenpresented on their online interfaces, and,in addition, providing an easy to usefunctionality which enables recipients ofthe service to indicate such information. Yes, Snap has taken steps to mitigate the risk that (i) itsgenerative AI tools are used for creating illegal or otherwiseviolating content and (ii) illegal or otherwise violatingcontent created using generative AI tools on any onlineplatform are disseminated on Snapchat’s inscope services. 114 https://parents.snapchat.com. 198 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Conclusion Snap continues to consider the overall risk prioritization to be within the Level 2 category giventhe stakes and the severity of threats to privacy life, despite low prevalence. However,privacy is the first of Snap’s four core platform governance values. We have robust protections inplace, including clear terms and moderation. Snap enforces against these content violationsrobustly. We also mitigate risks throughintentional product design choices and collaborate with experts, think tanks and researchers onhuman rights, privacy and online safety to inform our approach. We have concluded therefore that Snapchat’s in-scope services have reasonable,proportionate and effective mitigation measures to address risks relating to the Right toPrivate Life. There is no change in this conclusion from our 2024 Report. 4.2.4 Right to Data Protection We understand well the importance of ensuring that personal data is collected, processed orsecured appropriately. Depending on how and the extent to which Snapchatters use ourplatforms, significant volumes of the content published on Snapchat’s in-scope services, includingon Spotlight / Discover and Snap Map, is user generated images and videos. Snapchat recognises that rights of personal data may be infringed by excessive use of datashared with Snapchat for personalized advertising. Additionally, this right may be impacted bydisseminating microtargeted ads, or ads that attempt to incite users, or by collection of sensitiveinformation by advertisers. In its research on online advertising, the OECD identifies misleading advertising online as aparticular concern, and flags that consumers may not be able to identify some forms of onlineadvertising and that this is a significant issue as misleading online advertising could reduceconsumer sentiment and trust online.115 The research also raises concern that online advertisingmay prey on consumer biases and vulnerabilities to sell and in extreme cases can threatenindividuals through malicious advertising. It also raises concern that individuals may suffer harmfrom increased data collection associated with the most aggressive forms of online advertising. 115 OECD, ‘Online advertising - Trends, benefits and risks for consumers’, January 2019, url. 199 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT These issues are echoed in research by the EP in which privacy risks are found to arise fromexcessive behavioral targeting.116 The research considered that obfuscation and location basedtargeting of advertisements reduce consumer choice. Excessive behavioral targeting techniquesincluding exploiting consumers behavior biases via the use of dark patterns. The research raisedthe concern for discrimination and harmful targeting of vulnerable consumers through Real-TimeBidding (RTB). It considered that data-driven ad distribution through RTB processes had thepotential for structural discrimination or harmful targeting of vulnerable consumers. For example,if past browsing behavior relating to sensitive matters were used to target advertising e.g. badeating habits or a potential addiction to drinking or gambling, this could increase exposure ofvulnerable persons to advertisement in these fields. This could pose a serious risk to consumers’wellbeing. The research also highlighted the increasing prevalence of malvertising andspearphishing which threatens cybersecurity. An article117 published by the International Association of Privacy Professionals indicates thatconsumers are increasingly protective of their personal data. As revealed by the IAPP Privacy andConsumer Trust Report 2023, 68% of consumers globally are either somewhat or very concernedabout their privacy online. The recent popularization of generative AI tools was highlighted asone of the newest factors to drive these concerns, with 57% of consumers globally agreeing thatAI poses a significant threat to their privacy. Additionally, this right might be impacted by the dissemination of harmful ads, for example adsthat use Hate Speech or contain discriminatory elements, or targets a specific audience based ondiscriminatory parameters. Also, the design of the algorithmic systems used for advertising couldharm human dignity by inadvertently targeting specific groups by basing targeting decisions onbiased data. Without mitigations, these ads and related systems could severely impact humandignity. Likelihood All of the risks we track on Snapchat have a low prevalence compared to the prevalence of theseissues elsewhere online and offline. To aid our prioritization, our methodology seeks to assessthe relative likelihood between the risks we track (even though all are low in absolute terms). Snapchat handles a significant volume of personal data relating to individuals in the EuropeanUnion. Depending on how and the extent to which Snapchatters use Snapchat, this could belimited to basic account information or it could extend, for example, to published images andvideos and metadata about the Snapchatter’s interaction with such content. Significant volumesof the content published on Snapchat’s in-scope services is user generated images and videoswhich might be related to individual Snapchatter creators and/or others. It is therefore more likely 117 Consumer Perspectives of Privacy and Artificial Intelligence, February 2024, url. 116 N. Fourberg e.a., on ‘Online advertising: the impact of targeted advertising on advertisers, market access andconsumer choice’, 2021, url. 200 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT than not that Snapchat’s in-scope services could cause an impact on an individual’s dataprotection rights if such personal data is not collected, processed or secured appropriately. In practice however, we continue to observe a low volume of data protection issues on Snapchat: ● Our prevalence testing showed that the Policy Violating Prevalence of “invasion of privacy” content (as per Section 6.4 on Prevalence Testing chapter) has been maintainedat an extremely low level through 2024 and the first quarter of 2025: ○ ● Snap also receives consistently low numbers of privacy-related queries from users andthe broader community: ○ However, despite low prevalence of privacy issues and low numbers of privacy related queriesfrom our users, a significant volume of personal data is being processed by Snap in relation tothe in-scope services on Snapchat. As a result, we continue to assess this risk falls within our LowLikelihood category. Severity The impact on an individual’s data protection rights caused by a data security breach or otherincident involving inappropriate processing of personal data would depend on the nature of theinformation involved. In respect of a security breach, the European Data Protection Board in itsGuidelines 01/2021 on Examples regarding Personal Data Breach (14 December 2021)118 providesa range of examples relevant to Snapchat such as: (1) on one hand, a Ransomware attack withproper backup and without exfiltration giving rise to only minor consequences and no significanteffect on data subjects; and (2) on the other hand, highly confidential personal data sent bymistake giving rise to high risk to data subjects. 118 European Data Protection Board, ‘Guidelines 01/2021 on Examples regarding Personal Data Breach’, 14 December2021, url. 201 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Snap's Mitigations In the table below we indicate the specific measures we have taken to mitigate this risk in respectof Snapchat’s in-scope services, using the defined list of mitigations set out in Article 35 of theDSA. The primary purpose of the below table is to indicate whether each specific mitigationcategory applies to this risk and the descriptions are illustrative rather than exhaustive. As many of our mitigations apply to all of the risks assessed in this Report, to reduce duplicationin this Report, each row in the tables provides a link in the left hand column to a full summary ofthe specific mitigation in Section 5 of this Report which explains in more detail how eachmitigation operates to reduce the risk. Mitigation Category Applies to this risk? Snapchat Design and Function Adapting the design, features orfunctioning of their services, includingtheir online interfaces. Yes, Snapchat is a platform with strong privacy principles.These principles are reflected into the architecture of ourplatform. Product changes are subject to privacy by design reviewsand we maintain data protection impact assessments. For example, our Lenses only require object detection ratherthan facial identification. Lenses can tell what is or isn’t aface, they do not identify specific faces, limiting dataprocessing for the use of Lenses. Snap does not use anydata collected by Lenses to customize the content that theuser sees in Spotlight or Discover, nor is any data collectedfor advertising purposes. Besides, voice data collection ofSnapchatters in the EU is off by default; it is only used toprovide the service. Terms and Enforcement Adapting their terms and conditions andtheir enforcement. Yes, our Privacy Center provides a suite of policies, includingour Privacy Policy and they are enforced.In our Content Guidelines for Recommendation Eligibility weinform creators “We inform these standards with proactivemoderation using technology and human review” and “youmust have any necessary third-party rights including, withoutlimitation, music copyrights and rights of publicity, for allcontent in your Snaps” This prevents any risk that users maynot be aware that their content submitted to Spotlight issubject to automated and human review, and prohibitscreators from depicting individuals in content withoutnecessary rights. 203 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT In our Snap Spotlight Submission and Revenue Terms westate “You understand that Snaps you submit to Spotlight arePublic Content and may be visible to all Snapchat users, aswell as non-Snapchat users on other services and websites”.This prevents the risk of creators being unaware that theirStories submitted to Spotlight become public and informsusers that their content may be saved off Snapchat. Moderation Adapting content moderationprocesses, including the speed andquality of processing notices related tospecific types of illegal content and,where appropriate, the expeditiousremoval of, or the disabling of access to,the content notified, in particular inrespect of illegal hate speech or cyberviolence, as well as adapting anyrelevant decision-making processes anddedicated resources for contentmoderation. Yes, specific proactive and reactive moderation proceduresto prevent and remove content that violates users’ Right toData Protection. For example, on Discover, Media Partners are proactivelymoderated and only a small pool of Snapchatters are shownin Discover (“Snap Stars” or “Popular Users”. Algorithmic Systems Testing and adapting their algorithmicsystems, including their recommendersystems. Yes, our algorithmic systems do not categorize orrecommend content that violates users’ Right to DataProtection. For example, users can opt out from personalizedrecommendations based on inferred interest and we do notprocess sensitive category information. Advertising Systems Adapting their advertising systems andadopting targeted measures aimed atlimiting or adjusting the presentation ofadvertisements in association with theservice they provide. Yes, our Advertising Systems has a suite of protectionsincluding: ● No microtargeting ● We offer controls to turn off most personalized ads.Users can learn more about their choices here Howto Adjust My Advertising \& Interest Preferences onSnapchat. ● We ensure that sensitive data is not being used forad targeting ● We continue to trial evolving privacy enhancingtechnologies, such as third party data clean rooms,to provide advertisers with options to furtherminimize the privacy impact of Snap ad services. Ongoing Risk Detection andManagement Yes, we consult with experts and our community, and we alsomonitor and respond to privacy-related inquiries. 204 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Reinforcing the internal processes,resources, testing, documentation, orsupervision of any of their activities inparticular as regards detection ofsystemic risk. Trusted Flaggers Initiating or adjusting cooperation withtrusted flaggers in accordance withArticle 22 and the implementation of thedecisions of out-of-court disputesettlement bodies pursuant to Article 21. No, we don’t cooperate with trusted flaggers in relation todata protection violations. Codes and Crisis Protocols Initiating or adjusting cooperation withother providers of online platforms or ofonline search engines through thecodes of conduct and the crisisprotocols referred to in Articles 45 and48 respectively. Yes, we cooperate with other providers through variousindustry groups e.g. CIPL, FPF. We also have a well-established protocol to deal with privacyincidents, as well as a Security Incident Response Policy. Transparency Taking awareness-raising measures andadapting their online interface in orderto give recipients of the service moreinformation. Yes, we provide guidance on privacy protection in our PrivacyCenter. For example, we explain to users How We RankContent in Discover, How We Rank Content on Spotlight –Snapchat Support and Snapchat Ads Privacy \& Transparency. Protection of Minors Taking targeted measures to protect therights of the child, including ageverification and parental control tools,tools aimed at helping minors signalabuse or obtain support, as appropriate. Yes, we have protective measures to limit disclosure ofTeens’ data and we avoid nudge techniques to encourageTeens to change their privacy settings and select lessprivacy-enhancing choices. We offer Family Center; we make available robust reporting;and we provide guidance to parents on the web. Our parents site provides additional guidance for parents andcarers on risks and support.120 Content Authenticity Ensuring that an item of information,whether it constitutes a generated ormanipulated image, audio or video thatappreciably resembles existing persons,objects, places or other entities or No specific content authenticity measures taken in respect ofusers’ Right to Data Protection. 120 https://parents.snapchat.com. 205 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT events and falsely appears to a personto be authentic or truthful isdistinguishable through prominentmarkings when presented on theironline interfaces, and, in addition,providing an easy to use functionalitywhich enables recipients of the serviceto indicate such information. Conclusion Snap considers the likelihood and the serious nature of the impacts on the Right to DataProtection within the European Union to fall within our Level 3 overall potential risk of Snapchat’sin-scope services, despite robust protections in place. Depending on how and the extent towhich Snapchatters use these platforms, significant volumes of the content published onSnapchat’s in-scope services is user generated images and videos. It is therefore more likely thannot that Snapchat’s in-scope services could negatively affect an individual’s data protection rightsif such personal data is not collected, processed or secured appropriately, which is why Snapenforces its privacy principles robustly. Privacy is central to Snapchat’s values. We put significantthought and consideration into our privacy principles and those principles are reflected into thearchitecture of our platform. We have a cross-functional group responsible for compliance withour privacy and safety by design principles, we review product changes for impact to dataprotection rights and we maintain Data Protection Impact Assessments of our processing ofpersonal data where appropriate to ensure we are confident this will not result in a high risk tothe rights and freedoms of individuals. We receive a low level of data protection queries as aresult of the robust protections in place. We have concluded therefore that Snapchat’s in-scope services have reasonable,proportionate and effective mitigation measures against the risk of Negative Effects on theRight to Data Protection. There is no change in this conclusion from our 2024 Report. 4.2.5 Right to Non-Discrimination and Freedom of Religion We understand well that online platforms can be used to spread content that contains orpromotes discrimination for example by using discriminatory characteristics for targeting ads,biased algorithms used for recommender systems and content moderation, the spread ofdiscriminatory content, facilitating online harassment, disproportionately reporting accounts ofindividuals from marginalized (religious) communities based on user reports, etc. This risk poses aserious threat to the rights of EU citizens who are already vulnerable to abuse and haveencountered discrimination and marginalization historically. Without mitigations, content thatundermines the Right to Non-Discrimination and Freedom of Religion could conceivably appear 206 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT in any of Snapchat’s in-scope services displaying user generated content, including information invideos featured on Spotlight / Discover and Snap Map. Likelihood All of the risks we track on Snapchat have a low prevalence compared to the prevalence of theseissues elsewhere online and offline. To aid our prioritization, our methodology seeks to assessthe relative likelihood between the risks we track (even though all are low in absolute terms). Wehave assessed the relative likelihood of Snapchat’s inscope services disseminating contentrelating to matters that may undermine the Right to Non-Discrimination and Freedom of Religion,based on Policy Violating Prevalence (PVP) via random sampling and our Transparency Reportdata in Section 4.1 of this Report, as follows: Category Relative likelihood of riskoccurring on Snapchat 4.1.2 Dissemination of Illegal Hate Speech Lowest Relative Likelihood 4.1.4 Dissemination of Terrorist Content Lowest Relative Likelihood In addition, although we placed the risks to the Right to Data Protection in the highest relativelikelihood category in Section 4.2.4, we have noted that the overall number of privacy and dataprotection related queries we received is very low. When focused on algorithmic bias specifically,we have not received any material volume of queries, which is not surprising as we noted inSection 4.2.2 (Right to Freedom of Expression and information) that Snap’s inscope services donot generally provide a platform for political public content. We therefore continue to assess that the relative likelihood that the in-scope services ofSnapchat would have an actual or foreseeable Negative Effects of the Right to Human Dignityfalls within Extremely Low Likelihood category. Severity This risk poses a serious threat to the rights of EU citizens, many of whom have historically faceddiscrimination and marginalization. Recent examples underscore how algorithmic systems canperpetuate bias even today. For instance, the Netherlands Institute for Human Rights found thatthe Breeze dating app's matching algorithm discriminated against non‑white users, resulting in a 207 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT formal order to address the bias.121 In the regulatory sphere, the European Commission hasdemanded that X (formerly Twitter) provide internal documentation on how its recommendationsystems may be amplifying far‑right content—underscoring concerns about algorithmicmoderation potentially skewing democratic discourse.122 These examples further reflect thescrutiny that algorithmic bias has attracted, within both legal frameworks and regulatory action,particularly under the evolving mandates of the EU’s AI Act and GDPR. As in prior reports, we have assessed the severity of harm caused by categories of content thatmay undermines the Right to Non-Discrimination and Freedom of Religion in Section 4.1 of thisReport, as follows: Category Relative likelihood of riskoccurring on Snapchat 4.1.2 Dissemination of Illegal Hate Speech Significant harm industrywide 4.1.4 Dissemination of Terrorist Content Serious harm industry wide Given these circumstances, Snap qualifies this risk of harm relating to negative impacts on theRight to Non-Discrimination and Freedom of Religion to be ‘serious’. DSA Risk Factors In accordance with Article 34.2, our risk assessment also addresses our recommender systems,content moderation systems, applicable terms and conditions, systems for the selection andpresenting of advertisements and any of our data-related practices. These factors have beenlisted and explained in Section 3 on the Risk Assessment Methodology and applied throughoutSection 4. We also considered the risk factors in the context of the Right to Non-Discriminationand Freedom of Religion. As many of these factors pose similar risks, and are mitigated in ahorizontal manner (i.e. by measures that cut across all systemic risks), we did not include them inthis section again but refer to our explanation in Sections 4.1.2 on Hate Speech and Section 4.1.4on Terrorist Content. Overall potential risk prioritization Snap would consider this risk to the right to non-discrimination and freedom of religion tofall be within the Level 3 category overall. Although we consider the risk to fall within our seriousharm category, there is arelatively low prevalence of Hate Speech, terrorism and bias concernson the platform. There is no change in this assessment from our 2024 Report. 122 Financial Times, ‘Brussels orders X to hand over documents on algorithm’,url, (2025) 121 Tim de Jonge, Frederik Zuiderveen Borgesius, ‘Mitigating Digital Discrimination in Dating Apps -- The Dutch Breezecase’, url, (2024) 208 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ● We add diversity to every viewer’s feed in terms of the account they see, and thecategories of content we surface to them. This prevents users from entering an echochamber or filter bubble of seeing the same content repeatedly. We use machine learningto understand content categories and diversify it. Modifying facial features or overlaying cultural elements in Snapchat's Lenses may reinforcediscriminatory ideas based on appearance or ethnicity and promote harmful imagery. Also,Lenses incorporating cultural symbols or references might lack proper context and sensitivity.The Lens Studio Submission Guidelines, reiterated our Community Guidelines and spelled outthat the following categories of Lenses are prohibited: ● Content that demeans, defames, or promotes discrimination or violence on the basis ofany of the identities listed in our Community Guidelines ● Examples: slurs, stereotypes, hate symbols, the promotion of hateful conspiracy theories,the glorification of atrocities or historical hatemongers Snap designs every Lens with race, gender, ethnicity and cultural norms in mind. Snap leveragesits ever-growing diverse training datasets, as well as feedback from community members. If aLens does not resonate with our community, as expressed through a high ratio of user reports,we take that feedback into consideration and will re-review the Lens with a goal to leave as-is,modify, or remove. If a Lens is appropriate, but could theoretically be misused by someone, that alone is notsufficient to reject a Lens. Snap considers current and historical global events when releasing aLens, and delays or denies amplification to Lenses that may be deemed insensitive due tobroader social occurrences throughout the world. We aim for our Lenses to celebrate individualityand diversity without altering a user’s skin tone or features to mimic another ethnicity or race. Weare committed to improving our technology to uphold these values. . Snap presents religious andcultural iconography in a respectful manner, with feedback solicited from internal and externalsubject matter experts. This means Snap is especially thoughtful around holiday or event-basedcontent, including the geography in which a Lens will launch. Also, Snap ensures that a Lens isnot deceptive. Snap uses signifiers and watermarks where there may be questions of creativeauthenticity. Snap tests Lenses on photos/videos of and in real life settings with diverse groups ofpeople to accurately enforce our policies. As reported in our 2024 Diversity Annual Report, we know DEI is critical for long-term growth -whether it’s Snapchatters demanding products to meet their diverse needs, or the desire to reachnew and different markets. It also highlights in particular two new initiatives since our 2023Report that showcase examples of how empathy can inspire new perspectives and tangiblebusiness impact. 210 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ● Snap Out Loud \- Snapchat is a platform that celebrates authenticity. That’s why our teamcreated an AR experience to spotlight the different communities who share the LGBTQIAumbrella. Led by SnapPride, this Snap Show educates Snapchatters about the meaning ofLGBTQIA, and celebrates the people who make up the community. Snapchatters werewelcomed into seven separate spaces, denoted by the letters of the acronym, to exploreeach world. 25 million unique users were reached across 11 countries and the lens wasshared one million times. ● 8 Mars 8 femmes \- In France, only 10% of statues in public spaces honor female figures.SnapWomen partnered with the Sales and AR Studio team in Paris to launch an ARactivation on International Women’s Day 2023 across 8 major cities. Called 8 Mars 8femmes, or 8th of March, 8 women, the activation featured female AR statues next tomale ones to celebrate great women in history who were never given appropriate creditfor their impact. These AR statues are permanently activated, and honor Josephine Baker,Olympe de Gouges, Manon Tardon, Hubertine Auclert, Simone Veil, Françoise deGraffigny, Élisabeth Vigée Le Brun, and Simone de Beauvoir. The initiative receivedwidespread media coverage in France. Snap’s AR Studio team was honored to win theglobal Drum Award for Marketing for their outstanding creativity. 211 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Specific Mitigations. In the table below we indicate the specific measures we have taken to mitigate this risk in respectof Snapchat’s in-scope services, using the defined list of mitigations set out in Article 35 of theDSA. The primary purpose of the below table is to indicate whether each specific mitigationcategory applies to this risk and the descriptions are illustrative rather than exhaustive. As manyof our mitigations apply to all of the risks assessed in this Report, to reduce duplication in thisReport, each row in the tables provides a link in the left hand column to a full summary of thespecific mitigation in Section 5 of this Report which explains in more detail how each mitigationoperates to reduce the risk. Mitigation Category Applies to this risk? Snapchat Design and Function Adapting the design, features orfunctioning of their services, includingtheir online interfaces. Yes, Snapchat’s in-scope services have been adapted toinclude proactive moderation for hateful content or activitiessupporting terrorism or violent extremism.We also work with civil society organizations to ensure ourpolicies are enforced responsibly. Product Inclusion helps us create equitable experiences byintentionally involving and considering marginalized groups 212 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT at critical moments throughout the product developmentprocess. Terms and Enforcement Adapting their terms and conditions andtheir enforcement. Yes, Snap’s Terms and Community Guidelines prohibit HateSpeech or content that demeans, defames, or promotesdiscrimination or violence on the basis of race, color, caste,ethnicity, national origin, religion, sexual orientation, genderidentity, disability, or veteran status, immigration status,socio-economic status, age, weight, or pregnancy status. Westrictly enforce these rules. Moderation Adapting content moderation processes,including the speed and quality ofprocessing notices related to specifictypes of illegal content and, whereappropriate, the expeditious removal of,or the disabling of access to, the contentnotified, in particular in respect of illegalhate speech or cyber violence, as well asadapting any relevant decision-makingprocesses and dedicated resources forcontent moderation. Yes, specific proactive and reactive moderation proceduresto prevent and remove hateful content or activitiessupporting terrorism or violent extremism. We provide in-app reporting for hateful content or activitiessupporting terrorism or violent extremism. Algorithmic Systems Testing and adapting their algorithmicsystems, including their recommendersystems. Yes, our algorithmic systems do not categorize orrecommend hateful content or activities supporting terrorismor violent extremism. Advertising Systems Adapting their advertising systems andadopting targeted measures aimed atlimiting or adjusting the presentation ofadvertisements in association with theservice they provide. Yes, other mitigations listed here also apply to ourAdvertising Systems. In order to ensure we are not using discriminatory targetingmodels particularly when there is significant legal impact tothe consumers, we offer special targeting models that do notinclude gender or age, which we require for advertisers whoare advertising in the housing, credit or employment (HCE)spaces, so that discriminatory factors will not go into whosees these ads. We do not allow advertisers to buildaudiences for their ads based on their own data about ourteenage users regardless of those user’s own ad settings(i.e. activity data from the advertisers own online propertiesand the advertiser’s own customer lists). Ongoing Risk Detection andManagement Yes, we have specific prevalence testing and transparencyreporting for Hate Speech, terrorist and violent extremist 213 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Reinforcing the internal processes,resources, testing, documentation, orsupervision of any of their activities inparticular as regards detection ofsystemic risk. content. Trusted Flaggers Initiating or adjusting cooperation withtrusted flaggers in accordance withArticle 22 and the implementation of thedecisions of out-of-court disputesettlement bodies pursuant to Article 21. Yes, we cooperate with trusted flaggers in relation to illegalhate speech, terrorist and violent extremist content. Codes and Crisis Protocols Initiating or adjusting cooperation withother providers of online platforms or ofonline search engines through the codesof conduct and the crisis protocolsreferred to in Articles 45 and 48respectively. Yes, we cooperate with other providers through variousindustry groups e.g. EU Internet Forum. We have signed onto the EU Hate Speech Code. Transparency Taking awareness-raising measures andadapting their online interface in order togive recipients of the service moreinformation. Yes, we provide guidance on our terms, harms, moderationand enforcement practices (see the Annex), as well as howto and how to get help in our Safety Center. We provide in-app reporting for hateful content or activitiessupporting terrorism or violent extremism. Protection of Minors Taking targeted measures to protect therights of the child, including ageverification and parental control tools,tools aimed at helping minors signalabuse or obtain support, as appropriate. Yes, we have protective measures in place for Teens. Forexample, Teens cannot create public profiles and if they postto Spotlight or Snap Maps their profile details areanonymized as an extra precaution. Our reporting menu alsoincludes the option to report “It involves a child”. We hopeprotections like these help protect Teens from hatefulcontent. Our Family Center includes resources and guidance forTeens and their parents or trusted adults. Our parents site provides additional guidance for parentsand carers on risks and support.123 Content Authenticity No specific content authenticity measures taken in respectof Hate Speech, terrorist and violent extremist content. 123 https://parents.snapchat.com. 214 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Ensuring that an item of information,whether it constitutes a generated ormanipulated image, audio or video thatappreciably resembles existing persons,objects, places or other entities or eventsand falsely appears to a person to beauthentic or truthful is distinguishablethrough prominent markings whenpresented on their online interfaces, and,in addition, providing an easy to usefunctionality which enables recipients ofthe service to indicate such information. However, Snap has taken steps to mitigate the risk that (i) itsgenerative AI tools are used for creating illegal or otherwiseviolating content and (ii) illegal or otherwise violating contentcreated using generative AI tools on any online platform aredisseminated on Snapchat’s in-scope services. Conclusion Snap considers the overall risk to be within the Level 3 category taking account of the harm thatrisks to the Right to Non-Discrimination and Freedom of Religion may cause and the lowprevalence for Hate Speech on the platform. In practice Snap has substantial protectivemeasures in place. Snap works with civil society organizations, like Access Now, human rightsexperts, law enforcement agencies, NGOs, and safety advocates to make sure we are calibratingwherever necessary to ensure that our products and policies function to keep Snapchatters safe.Our in-app reporting tool allows users to directly report hateful content or activities that supportterrorism or violent extremism. On our high-reach surfaces, like Spotlight and Discover, we take aproactive approach to moderating any content that may violate these rules. Further, our diversityand inclusion efforts continue to help us create equitable experiences and build inclusiveproducts. We have concluded therefore that Snapchat’s in-scope services have reasonable,proportionate and effective mitigation measures to protect users’ Right to Non-Discriminationand Freedom of Religion. There is no change in this conclusion from our 2024 Report. 4.2.6 Children’s Rights We understand that online platforms can impact Children’s Rights. This is a risk we take seriouslyas Snap’s priority is protecting the safety and wellbeing of our users whilst ensuring they have apositive experience online. Privacy, safety and security are key values of the company and at thecore of our value proposition to our users. The ‘rights of the child’ under the Charter124 comprises two elements that are relevant toSnapchat’s in-scope services:1. Children have the right to such protection and care as is necessary for their well-being;and 124 Art 24, Charter of Fundamental Rights of the European Union (CFREU), url. 215 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 2. Children have the right to express their views freely and have those views taken intoconsideration on matters which concern them in accordance with their age and maturity. In respect of element 1, we address the well-being of children when considering Category 4 ofthe DSA risks in particular parts of the Negative Effects on Minors and physical and mentalwellbeing elsewhere in this Section 4. This section therefore focuses on element 2 i.e. risks tochildren’s rights of expression. Likelihood As explained in Snapchat Community as part of our Introduction to this Report, Snapchat is usedby a wide demographic, with 18-24 year olds still making up the highest percentage of users ofSnapchat. Nevertheless, there is still a percentage of our users who are Teens (13-17). Thereforewe still consider that Teens using Snapchat are just as likely to be exposed to freedom ofexpression issues identified in this Report as other members of the Snapchat Community asfollows: Risk Category Relative likelihood of riskoccurring on Snapchat Relative likelihood of NegativeEffect on children Right to Freedom of Expression Extremely Low Likelihood Extremely Low Likelihood As a result, we continue to conclude that the relative likelihood of a risk of Negative Effects onchildren and Teens falls within the Lowest Relative Likelihood category. Severity We assessed the risk of harm from the Right to Freedom of Expression to fall within oursignificant harm classification. However, we take the safety and wellbeing of the youngestmembers of our community very seriously and recognise that this group is particularly vulnerableand if a particular risk materializes, there is an increased risk that the severity of the harm theysuffer is higher. For Freedom of Expression, we consider this as follows: Risk Category Harm classificationindustry wide Is the industry wide severity riskhigher for children and Teens? Right to Freedom of Expression Significant harm industrywide Yes, Snap considers that it is vitalthat children and Teens are ableto access online platforms andparticipate in lawful onlinedebate and dialogue to learn,have their views heard anddevelop their own values andidentities, regardless of their 216 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT DSA. The primary purpose of the below table is to indicate whether each specific mitigationcategory applies to this risk and the descriptions are illustrative rather than exhaustive. As many of our mitigations apply to all of the risks assessed in this Report, to reduce duplicationin this Report, each row in the tables provides a link in the left hand column to a full summary ofthe specific mitigation in Section 5 of this Report which explains in more detail how eachmitigation operates to reduce the risk. MitigationCategory Applies to this risk? Snapchat Design and Function Adapting the design, features orfunctioning of their services, includingtheir online interfaces. Yes, several aspects of Snapchat’s design and function reducethe risk for the Freedom of Expression and Assembly: ● Snap makes it difficult for unvetted content to reach alarge audience on Snapchat, and Snap proactivelymoderates Snapchat’s in-scope services that providean opportunity to reach a larger audience. ● Our platform is generally not a place for political oractivist public content. Such content is not eligible forpromotion on Spotlight and user content on Discover isonly from a small number of popular, entertainingcommunity creators and their content is moderated byhumans against our Content Guidelines. ● All Media Partners are vetted prior to being permittedto distribute their content broadly on Snapchat by ateam of editors. These Partners include newsorganizations, which are subject to their ownprofessional rules. Media Partners go through aneditorial review of their content, a reputational search(to evaluate if a publisher has a history damagingpress, legal actions, etc.), and compliance reviewbefore they’re able to distribute content. As a result,we provide a balanced approach to political andactivist public content on Snapchat that is designed tolimit the sources of such information to professionalmedia partners. ● As explained when discussing the dissemination ofcontent that infringes on intellectual property rights,Snap respects the doctrine of “fair use,” i.e., that thereare certain circumstances (such as news reporting,social commentary on issues of public interest,criticism, parody, or education) where excerpts ofcopyrighted material could be distributed withoutpermission from or payment to the copyright holder. 218 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? This helps reinforce the rights of Freedom ofExpression and the Freedom of Assembly. Terms and Enforcement Adapting their terms and conditionsand their enforcement. Our Terms clearly define certain topics which we prohibit,including false information that threatens Public Health (e.g.COVID-19 vaccinations), civic processes, or that denies tragicevents (like the Holocaust).Yes, Snap’s Terms and Community Guidelines expresslyprohibit harmful false or deceptive information and they arestrictly enforced. We respond with swift and strictconsequences against violators as explained in our Explainer. We promptly enforce against accounts found to be sendingTerrorist Content: ● Snap removes such content for all users. ● Accounts we discover engaging in prohibited terroristactivity will also be promptly disabled. ● Where appropriate, accounts engaging in violation ofthese policies may be reported to law enforcement. Moderation Adapting content moderationprocesses, including the speed andquality of processing notices relatedto specific types of illegal content and,where appropriate, the expeditiousremoval of, or the disabling of accessto, the content notified, in particular inrespect of illegal hate speech or cyberviolence, as well as adapting anyrelevant decision-making processesand dedicated resources for contentmoderation. Yes, we have specific proactive and reactive moderationprocedures to prevent and remove violative content. As explained in the Moderation section in Section 5, Snapdeploys a range of automated content moderation (whichinclude abusive language detection, other keyword-baseddetection, and machine-learning-based proactive detectionmodels) to scan Stories and Spotlight submissions.Snapchatters can report violative content to us via in-appreporting options and anyone can submit a report through theSnapchat Support Site. Our in-app reporting tool also allowsusers to directly report violative content. Algorithmic Systems Testing and adapting their algorithmicsystems, including their recommendersystems. Yes, unlike many of our peers, Snapchat does not offer an opennews feed where unvetted publishers or individuals have anopportunity to broadcast violative content, does not offer abroad ‘reshare’ functionality that would encourage virality, anddoes not allow user-generated content to be recommended toa wide audience without going through review. Our algorithmic systems do not knowingly recommend violativecontent. As explained in the Moderation section of our Existing 219 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? Mitigations in Section 5, on our high-reach surfaces, likeSpotlight and Discover, we take a proactive approach tomoderating any content that may violate these rules prior to thecontent being recommended to a wide audience. The pool of content recommended by our algorithmic systemsdoes not generally include political or other important societalmatters regardless of where they fall on the political spectrum. Advertising Systems Adapting their advertising systemsand adopting targeted measuresaimed at limiting or adjusting thepresentation of advertisements inassociation with the service theyprovide. Yes, other mitigations listed here also apply to our AdvertisingSystems. Ongoing Risk Detection andManagement Reinforcing the internal processes,resources, testing, documentation, orsupervision of any of their activities inparticular as regards detection ofsystemic risk. Yes, for example we monitor data to help detect and managecontent that may present a risk for the Right to Freedom ofExpression, including data from our specific prevalence testingand enforcements (which are summarised in our TransparencyReports). Trusted Flaggers Initiating or adjusting cooperation withtrusted flaggers in accordance withArticle 22 and the implementation ofthe decisions of out-of-court disputesettlement bodies pursuant to Article21. No, we do not work with trusted flaggers for users’ rights toFreedom of Expression and access to accurate information.However we are working with trusted flaggers on children’ssafety in general. Codes and Crisis Protocols Initiating or adjusting cooperation withother providers of online platforms orof online search engines through thecodes of conduct and the crisisprotocols referred to in Articles 45 and48 respectively. Yes, our Crisis Protocols balance Teen’s rights to Freedom ofExpression with access to accurate information. We haverecently exercised these protocols successfully during theFrench riots in June 2023. Note, we are actively working to support efforts to agree an EUAge appropriate design code to protect Children’s Rights. Transparency Yes, we provide guidance on harms and how to get help in our 220 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? Taking awareness-raising measuresand adapting their online interface inorder to give recipients of the servicemore information. Safety Center. We make available robust reporting tools andwe provide guidance to parents on the web (see below). Protection of Minors Taking targeted measures to protectthe rights of the child, including ageverification and parental control tools,tools aimed at helping minors signalabuse or obtain support, asappropriate. We have protective measures to allow Teens to expressthemself without the pressures of friends lists, comments andlikes. We have community, ad and content guidelines that arespecific to Teens. Snap also adopted protective measures to limit Teen contact with strangers; we offer Family Center,reporting, and guidance. Our new parents site providesadditional guidance for parents and caregivers on risks andsupport.125 Content Authenticity Ensuring that an item of information,whether it constitutes a generated ormanipulated image, audio or videothat appreciably resembles existingpersons, objects, places or otherentities or events and falsely appearsto a person to be authentic or truthfulis distinguishable through prominentmarkings when presented on theironline interfaces, and, in addition,providing an easy to use functionalitywhich enables recipients of theservice to indicate such information. Yes, Snap has taken steps to mitigate the risk that (i) itsgenerative AI tools are used for creating illegal or otherwiseviolating content and (ii) illegal or otherwise violating contentcreated using generative AI tools on any online platform aredisseminated on Snapchat’s inscope services. Conclusion Snap considers Negative Effects on Children’s Rights to be a lower likelihood risk but one thathas a risk for severe harm industry wide, without appropriate mitigations. As a result we treat thisas one of our highest priority risks, with a Level 1 Risk Prioritization. Snap is designed to fairlyapply rules on content publication and provide an appropriate environment for Teens to exerciseexpression and assembly on Snapchat’s in-scope services (and Snapchat as a whole). Asexplained in the Freedom of Expression and Protection of Minors section of the Report, thisincludes adapting our systems to limit the access of Teen accounts to higher risk features andcontent, like public profiles and sexually suggestive content, as well providing Teens and Familieswith accessible guidance and tools for the use of Snapchat and ensuring our Terms, Moderation and Enforcement also operate fairly. 125 https://parents.snapchat.com. 221 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT We have concluded therefore that Snapchat’s in-scope services have reasonable,proportionate and effective mitigation measures to protect against Negative Effects onChildren’s Rights. In addition, we continue to assess Snapchat against the Commission’s newArticle 28 Guidelines on ensuring a high level of privacy, safety and security for minors. 4.2.7 Right to Consumer Protection We understand that without mitigations online platforms can be used to spread content thatcontains false or misleading information that can harm consumers. This risk to the Right toConsumer Protection poses a serious threat to the rights of EU citizens who may be vulnerable todeception or invasion of privacy. Likelihood Snap has implemented safeguards, both through product design and policy enforcement, toeffectively diminish the likelihood that the Right to Consumer Protection is violated on theplatform. We monitor the number and nature of Privacy and Data Protection requests we receive. In our 2024 Report, we explained that: ● Our prevalence testing as at 30 July 2024 showed that “invasion of privacy” had seen afurther, substantial fall It is now at an Extremely Low PVP level. ● In July 2023-June 2024, Overall we haveseen a slight increase in line with expectations and we continue to receive low numbersof privacy-related queries. In this reporting period, we observed the following: ● As of 30 April 2025, our prevalence testing indicated a slight increase in reports of“invasion of privacy,” though the overall level remains low at 222 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ■ Given these safeguards we have in place, and the low, decreasing level of consumer queries andconsistent levels of ad rejections for our main fraud category, Snap considers that the risk to theright of consumer protection falls within the Extremely Low Likelihood level. Severity As described above, Snap recognises that the processing and sharing of extensive user data canlead to disproportionate personalized ad targeting.126 Additionally, misleading or falseadvertisements can harm consumers, which harm is recognized generally by the EuropeanUnion, for example within its Audiovisual Media Services Directive which also covers adtransparency, and in relation to political ads.127 National legislators have also recognized the needfor transparency, see for example the Dutch ACM’s recent guidelines for promoting a transparentand fair online platform economy for businesses.128 An example of a fraudulent ad that would be rejected by Snap is shown below. The advert itselfuses a low quality top Snap with too good to be true prices ($6.90 for Polo brand shirts). Theadvert links to a URL is suspicious, and ultimately redirects to a website with what appears to bea fake Ralph Lauren landing page.129 Products listed on this page are again below $10. It isunlikely any customer placing orders will receive any goods, if any goods are shipped it isextremely unlikely they will be authentic. It is also very likely any credit card used on this pagewould be stolen and would result in a chargeback. 129 https://mart.hdebrnz.shop/ralphlauren which redirects to https://www.ddssoodc.shop/. 128 Authority for Consumers \& Markets, ‘ACM Guidelines for Promoting a transparent and fair online platform economyfor businesses’, April 2023, url. See also: ACM, AFM, AP, CvdM, ‘Basic principles for effective online transparency’ July2023, url. 127 See for example Regulation (EU) 2024/900 of the European Parliament and of the Council of 13 March 2024 on thetransparency and targeting of political advertising, url. 126 A.M. Correa, ‘Regulating targeted advertising: Addressing discrimination with transparency, fairness, and auditingtests remedies’, 2022, 46 Computer Law \& Security Review, url. 224 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT information that causes harm or is malicious, impersonation,i.e., attempting to deceive people about who you are, anddisallow spam and other deceptive practices. Our CommercialContent Policy also disallows false or misleading content,including deceptive claims, offers, functionality, or businesspractices, promotion of fraudulent goods or services, productsor services with false celebrity testimonials or usage, deceptivefinancial products, and other similar content. Moderation Adapting content moderationprocesses, including the speed andquality of processing notices related tospecific types of illegal content and,where appropriate, the expeditiousremoval of, or the disabling of accessto, the content notified, in particular inrespect of illegal hate speech or cyberviolence, as well as adapting anyrelevant decision-making processesand dedicated resources for contentmoderation. Yes, we use a combination of automated and human review toprevent and remove ads that violate our policies or the lawfrom appearing on Snapchat. This also includes ensuringinappropriate ads are not targeted at Teens. Additionally, allads can be flagged by Snapchatters in the app as beinginappropriate along with the reason for the violation. We also don’t allow user-generated political content from beingpromoted on Spotlight. We take these measures in order tocircumvent the spread of harmful and false content. Algorithmic Systems Testing and adapting their algorithmicsystems, including their recommendersystems. See Advertising Systems below. Advertising Systems Adapting their advertising systems andadopting targeted measures aimed atlimiting or adjusting the presentation ofadvertisements in association with theservice they provide. To address potential risks with targeted advertisements, and toensure advertisers are not manipulating small audiences withmicro-targeted campaigns, most of the ads on Snapchat,including all political ads, require a specific minimum ofSnapchatters to be targeted. We also offer specialtargeting models that do not include gender or age foradvertisers who are advertising in the housing, credit oremployment (HCE) spaces so that discriminatory factors will notgo into who sees these ads. Lastly, to ensure that users havechoice about use of their personal data for targeting ads, weallow users to control the data that’s used to determine the adsthey see. In the EU, we offer controls to turn off mostpersonalized ads and for other regions users can restrict ouruse of third party data and being included in advertisersupplied audience matches for ads targeting. Ongoing Risk Detection andManagement Yes, we have specific prevalence testing and TransparencyReport false information, impersonation, spam and other 227 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Reinforcing the internal processes,resources, testing, documentation, orsupervision of any of their activities inparticular as regards detection ofsystemic risk. regulated goods. Trusted Flaggers Initiating or adjusting cooperation withtrusted flaggers in accordance withArticle 22 and the implementation ofthe decisions of out-of-court disputesettlement bodies pursuant to Article21. Yes, we cooperate with trusted flaggers in relation to regulatedgoods. Codes and Crisis Protocols Initiating or adjusting cooperation withother providers of online platforms orof online search engines through thecodes of conduct and the crisisprotocols referred to in Articles 45 and48 respectively. Yes, we cooperate with other providers through variousindustry groups e.g. CIPL, FPF. Transparency Taking awareness-raising measuresand adapting their online interface inorder to give recipients of the servicemore information. Yes, to ensure users know when content is commercial innature, we automatically place an “Ad” marker on all paid adsthat run on Snapchat. Our Commercial Content Policy requiresall organic content posted by influencers to be markedappropriately and we now offer a “Paid Partnership” tag toolthat influencers and users may use when they post commercialcontent to help them comply with this policy and their legalobligations. We also provide transparency on our privacy practicesincluding ads on our Privacy Center and provide an ads libraryin line with DSA requirements. Protection of Minors Taking targeted measures to protectthe rights of the child, including ageverification and parental control tools,tools aimed at helping minors signalabuse or obtain support, asappropriate. Yes, for example we prevent inappropriate ads for Teens andadvertising based on profiling. We make available robust reporting; and we offer Family Center and provide guidance toparents on the web. Our parents site provides additional guidance for parents andcarers on risks and support.130 Content Authenticity Yes, Snap has taken steps to mitigate the risk that (i) its 130 https://parents.snapchat.com. 228 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Ensuring that an item of information,whether it constitutes a generated ormanipulated image, audio or video thatappreciably resembles existingpersons, objects, places or otherentities or events and falsely appearsto a person to be authentic or truthfulis distinguishable through prominentmarkings when presented on theironline interfaces, and, in addition,providing an easy to use functionalitywhich enables recipients of the serviceto indicate such information. generative AI tools are used for creating illegal or otherwiseviolating content and (ii) illegal or otherwise violating contentcreated using generative AI tools on any online platform aredisseminated on Snapchat’s inscope services. Conclusion Snap considers Right to Consumer Protection risks to fall within our Level 3 risk prioritization.Although there is a risk of significant harm arising from content and activity negatively impactingthe Right to Consumer Protection, our evidence indicates a relatively low likelihood on Snapchat.In response, Snap takes a multipronged approach and has put in place a range of mitigationmeasures. These include, for example, developing and enforcing advertising policies thatsafeguard the Right to Consumer Protection. Our ad policies aim to prevent inappropriate andillegal advertising and our review processes were designed to enforce these policies. Throughthese terms and other mitigations, such as safeguards in the product design and policyenforcement, Snap has been able to effectively uphold users’ consumer protection rights. We have concluded therefore that Snapchat’s in-scope services have reasonable,proportionate, and effective mitigation measures for the risk of Negative Effects on the Rightto Consumer Protection. There is no change in this conclusion from our 2024 Report. 4.2.8 Right to Property The property right that has a significant risk of being impacted by Snapchat’s in-scope services isthe right to intellectual property. This risk stems from the disclosure of such property contrary tothe intellectual property rights of a natural or legal person. This is discussed above under Section4.1.5 (IP Infringement). In addition, we continue to consider there is a potential risk that individuals may harm someoneelse’s property while under pressure to create content that others find entertaining or humorouson Snapchat. 229 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT This risk is discussed above under Section 4.1.9 (Dissemination of contentencouraging or engaging in violent or dangerous behavior). 4.3 Category 3: Negative effects on Public Security (Article 34.1.c / DSA Recital 82) In this part of the Report, we explain the results of our assessment on actual or foreseeablenegative effects of Snapchat’s in-scope services on Democratic and Electoral Processes, CivicDiscourse and Public Security as required by Article 34.1.c and Recital 82 of the Digital ServicesAct. We have assessed in particular Negative Effects on Democratic and Electoral Processes,Civic Discourse, as well as Public Security. Note that for all harms, where there is (1) a risk of significant damage to the physical or emotionalwell-being of Snapchatters, and (2) imminent, credible risk of severe harm, including threats tohuman life, safety, and well-being, we treat this as a severe harm and an Level 1 overall riskprioritization. Category 3 - Negative effect on Public Security Category Relative likelihood ofrisk occurring onSnapchat Harm classificationindustry wide Risk Prioritization Conclusion 4.3.1 NegativeEffects onDemocratic andElectoral Processes Extremely LowLikelihood Severe harmindustry wide Level 3 Low Risk /Reasonable,proportionate andeffective mitigations 4.3.2 NegativeEffects on CivicDiscourse Extremely LowLikelihood Severe harmindustry wide Level 3 Low Risk /Reasonable,proportionate andeffective mitigations 4.3.3 NegativeEffects on PublicSecurity Extremely LowLikelihood Serious harmindustry wide Level 3 Low Risk /Reasonable,proportionate andeffective mitigations 4.3.1 Negative Effects on Democratic and Electoral Processes The role of digital platforms in helping to shape information environments establishes asignificant nexus with Democratic and Electoral Processes. As digital technologies such as Snapenable expression and access to information, the impact of these platforms on the free and fair 230 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT exercise of political rights warrants careful attention, presenting risks to which Snap has longbeen vigilant. Likelihood As outlined in Section 1, a significant proportion of EU citizens use Snapchat. As at 1 January2025, we have 93.7 million average monthly active recipients of Snapchat in the EU, andsignificant recipient numbers in individual Member States. There is the potential for publiccontent on Snapchat to reach a sizable audience within the European Union (particularly withinthe 18-24 age bracket which accounts for the biggest share of our registered accounts). However, Snapchat’s platform architecture, combined with its commitment to responsible policyenforcement across our content surfaces, establishes unique safeguards against risks todemocracy. The steps Snap has taken to mitigate threats to democracy mean that likelihood issubstantially diminished. Independent reports of electoral interference on Snapchat are vanishingly rare. In connectionwith a major, high-profile election in 2022, we onboarded Snap to the Election IntegrityPartnership (EIP),135 a partnership among leading research centers and civil society organizationswho monitor online harms to democratic processes; as participants in the EIP threat escalationprogram, our teams received only one single incident report from the researchers monitoringrisks on Snapchat. We participated in the Commission’s stress test and multi-stakeholderroundtable dialogues ahead of the European Parliament elections in 2024 and were able tosuccessfully navigate the test exercises. As we reported in our election blog post on 24 June2024, Snap saw a small uptick in reported activity, but did not receive or observe any materialincidents or threats. Our moderation and reporting tools worked well, and none of the reportedpieces of content were verified as misinformation on Snapchat. 135 Election Integrity Partnership (2020), url. 1 231 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT As highlighted in Section 4.1.10 (Harmful False Information), Snap’s own reporting metrics confirmthe limited occurrence of content harmful to democracy: ● Our Prevalence Testing has consistently found extremely low levels of Harmful FalseInformation. Testing conducted since July 2024 shows a further significant decline, ● Our most relevant transparency reporting category on this topic is “Harmful FalseInformation,” which our policies define as including content that “undermines the integrityof civic processes.” In the second half of 2024, false information continues to account foronly 0.013% of the total of all content enforced in the EU on Snapchat, showing adecrease from 0.015% registered in the first half of the same year and even a furtherdecrease from 0.020% in the second half of 2023. Snap’s product design and policy practices continue to substantially reduce the likelihood ofnegative impacts on democracy. Our ongoing quantitative and qualitative analysis shows that therisk of potential negative impact on Democratic and Electoral Processes on Snapchat falls intoour Extremely Low likelihood category. Severity Snap takes risks to democracy very seriously. Although the recent European Parliament electionsunfolded overall in a positive online environment with no major threats136, other real-worldexamples – like Cambridge Analytica,137 the Brazilian elections,138 and the US Presidentialelections139 – illustrate the devastating negative impact that social media and content platformcan have on Democratic and Electoral Processes. Quite often misinformation is designed toundermine trust in the electoral process and dissuade specific groups of people from exercisingtheir right to vote.140 Accounting for the real-world examples illustrating the potential disruptive effects that digitalplatforms can have on Democratic and Electoral Processes, we understand that Negative Effectson Democratic and Electoral Processes have a risk of severe harm if not properly mitigated. DSA Risk Factors In accordance with Section 3 (Methodology), we have also taken into account, in particular,whether and how the following service risk factors referenced in Article 34(2) of the DSAinfluence the risk of this harm on Snapchat’s in-scope services. As set out below, while the 140 See for example: https://edmo.eu/publications/final-report-results-and-outcomes-of-a-community-wide-effort/ and https://www.brennancenter.org/election-misinformation. 139 https://www.hrw.org/news/2024/08/15/disinformation-about-us-elections-targets-communities-color. 138 Misinforeview, ‘Explaining beliefs in electoral misinformation in the 2022 Brazilian election: The role of ideology,political trust, social media, and messaging apps’, May 2023, url. 137 The New York Times, ‘Cambridge Analytica and Facebook: The Scandal and the Fallout So Far’, April 2018, url. 136 European Commission and independent observers confirmed that they did not observe major online threats inrecent multi-stakeholder dialogues relating to the European elections, url 232 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT following risk factors could in principle influence this systemic risk, their overall impact is limitedgiven Snap’s existing mitigations, which are described later in this chapter and in Chapter 5. Service Risk Factor How does it apply to Snapchat and this harm? (a) the design of recommendersystems and any otherrelevant algorithmic system; Our recommender systems are designed not to knowinglyrecommend political content. Political content is not eligible forpromotion in Spotlight and all Spotlight and non-professionalDiscover content must pass both automated and humanreview before wider recommendation. Detailed informationregarding the mitigations relating to our recommender systemscan be found in Section 5 (see the Algorithmic Systemssub-section). (b) content moderation systems; Snap has implemented specific proactive and reactivemoderation procedures to prevent and remove electoralmisinformation. Moderators are given specific escalationguidance during elections. We provide more information inSection 5 (see Content Moderation sub-section) (c) the applicable terms andconditions and enforcement; Our Community Guidelines (which form part of our terms ofservice) prohibit content that undermines the integrity ofelections and civic processes. Enforcement covers all contentformats, including AI-generated media. We provide moreinformation in Section 5 (see the Terms and Enforcementsub-sections). (d) systems for selecting andpresenting advertisements;and Our advertising systems require agreement to advertisingpolicies and guidance that prohibit adverts from displayinginformation that violates the law or causes certain harms.Specifically, our political ad policies require that any politicaladvertisements are subject to review and fact-checking beforethey are eligible for placement on Snapchat. We checkadvertisers are complying with their obligations via ouradvertising review process. Our advertising systems use a mixof automation and human review to review adverts before theyare published. We provide easy mechanisms for users to hideand report advertisements that violate our policies or the law.We monitor ad rejection, reporting and enforcement data tomonitor the effectiveness of our approach. We provide moreinformation in Section 5 (see the Advertising Systemssub-section) (e) our data related practices We have strong data principles, practices and privacy, safety 233 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT and security by design processes. We provide moreinformation in Section 5 (see the Transparency sub-section)and Section 6 (see the Platform Principles Framework andPrivacy and Safety by Design subsections). We have also analysed whether and how the risk of Negative Effects to Democratic and ElectoralProcesses is influenced by the following general factors: General Risk Factor How does it apply to Snapchat and this harm? Intentional manipulation, includinginauthentic use or inauthentic use orautomated exploitation of the service There are two key ways in which we consider our systemscould be manipulated:(1) Users could seek to share novel illegal and violatingmaterial that is not detected by our automatedsystems. We are constantly working to adjust oursystems and policies to address this. We provide moreinformation on our approach in Section 5 (in particularthe Content Moderation subsection) and Section 6(Ongoing Risk Detection and Management).(2) Users could abuse our content moderation processesand report non-violating content / accounts in badfaith. We have processes to combat misuse and moreinformation can be found in Section 5 (ContentModeration and Enforcement subsections). Amplification and potentially rapid andwide dissemination of illegal contentand of information that is incompatiblewith their terms and conditions. Snapchat’s inscope services have a number of features anddesign configurations that act to limit the amplification andpotentially rapid and wide dissemination of content that isharmful to Democratic and Electoral Processes, in particular: 1. Snapchat is not an attractive platform for spreadingpolitical misinformation, in particular because it isdifficult to reach a broad audience and content isdeleted by default. We provide more information inSection 5 (see Snapchat Design / Functionsubsection) 2. Snap has implemented specific proactive and reactivemoderation procedures to prevent and removecontent that is harmful to electoral processes. Weprovide more information in Section 5 (see ContentModeration). 3. Content recommended to users on Spotlight andDiscover, our video sharing platforms, is moderatedusing a combination of auto-moderation and humanmoderation, and is human moderated before being 234 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT political rights by amplifying digital disinformation or deceptive content relating to politicalmatters or processes. However, the steps Snap has taken to mitigate threats to democracy meanthat likelihood is substantially diminished. As we highlighted in our previous Reports, Snap has for some time taken a multifacetedapproach to mitigating negative impacts to democracy, including policy enforcement, productdesign, and expert engagement. This approach aligns with Guideline for providers of VLOPs andVLOSEs on the mitigation of systemic risks for electoral processes,141 as follows: Internal Processes As we have explained in this Report, and highlighted above, our assessment of risk prioritizationwith regards to Negative Effects on Democratic and Electoral Processes and Snap’s measures tomitigate the risk, are guided by information on elements such as the presence and activity ofpolitical actors on the service and the number of Snapchatters in the EU and evidence regardingthe use of tactics, techniques and procedures for information manipulation. We also engage with experts in the information integrity and democracy and human rightscommunity to inform our approach. This includes collaborations and engagement with individualexperts (for example, former US Ambassador to the UN Human Rights Council Eileen Donahoe, inaddition to several others), as well as think tanks (such as the Atlantic Council’s Digital ForensicsResearch Lab) and research collaborations (such as the Election Integrity Partnership). Access to official information on the electoral process and Media literacy initiatives We have regularly partnered with governments around the world to inform Snapchatters aboutelections and invite them to go vote. We believe that civic engagement is one of the mostpowerful forms of self-expression and have previously worked with election authorities in France, Netherlands, and Sweden to raise awareness of elections and encourage participation. A recentexample was the 2023 Dutch provincial election cycle. With the Dutch Ministry of the Interior,Snap developed a lens where Snapchatters could place voting bins in their living room andanswer questions about the election with ‘true’ or ‘false’. By taking this quiz Snapchatters areincreasing their knowledge about the elections and are reminded to go vote. The recent European Parliament elections saw even more first-time voters eligible to participate –following the decision by Belgium and Germany to join Austria, Malta and Greece in lowering thevoting age to 16. Ahead of these elections, we teamed up with the European Parliament on aspecial AR elections Lens that encourages people to get out and vote. During the election, weshared this Lens with all EU Snapchatters along with a message to remind them to vote and a linkto the Parliament’s election website. 141 Guidelines for providers of VLOPs and VLOSEs on the mitigation of systemic risks for electoral processes, April2024, url. 236 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Snapchat partnered with the European Parliament and European Commission to promote their‘Use your vote’ information campaign on elections, including a dedicated Lens, and their awareness campaign on the risks of disinformation and deceptive content. Snap sent a pushnotification to over 50 million users to urge them to vote in the elections. Although out of scopeof this Report, we note that we also further instructed My AI to avoid engaging on political topics.We are proud to have done our part to contribute to the highest observed turnout of the last 30years, with 51.08% of the 357 million eligible citizens participating in the election. Measures to provide users with more contextual information One key way in which we mitigate the risk is through intentional product design choices. Ourplatform does not, for example, provide an unvetted feed of algorithmically curated politicalinformation; we disallow all political content from Spotlight (our broadcast platform for UserGenerated Content) and pre-moderate that surface to ensure that such political content is notdistributed.142 This safeguard ensures that Snap is not algorithmically promoting politicalstatements from unvetted sources, and generally reflects Spotlight’s function as an entertainmentplatform. (Consistent with our commitments to fundamental rights of expression and access toinformation, Snapchat provides other, non-algorithmically amplified spaces for users to expresstheir views and political observations, such as Chat and My Story; users can also seek access topolitical information from known publishers and creators whom Snap has on-boarded fordistribution on the Stories tab). 142 For these purposes, “political content” means content related to political campaigns and elections, governmentactivities, and/or viewpoints on issues of ongoing debate or controversy. This includes content about candidates orparties for public office, ballot measures or referendums, and political action committees, as well as personalperspectives on candidate positions, government agencies/departments or the government as a whole. 237 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Snap’s policies expressly prohibit content that undermines the integrity of elections and civicprocesses. Drawing from expert research from the Election Integrity Partnership,143 we orient thispolicy around four pillars of risk: ● Procedural interference: misinformation related to actual election or civic procedures,such as misrepresenting important dates and times or eligibility requirements forparticipation. ● Participation interference: content that includes intimidation to personal safety or spreadsrumors to deter participation in the electoral or civic process. ● Fraudulent or unlawful participation: content that encourages people to misrepresentthemselves to participate in the civic process or to illegally cast or destroy ballots. ● Delegitimization of civic processes: content aiming to delegitimize democratic institutionson the basis of false or misleading claims about election results, for example. We take steps to explain our policy approach to safeguarding democratic informationenvironments through our Community Guidelines and periodic blog posts. As technologies have evolved, we have updated our policies to cover all content formats –whether created by a human or generated by artificial intelligence (including deep fakes). Inpreparation for the recent EU elections, we also: ● Signed up to the AI Elections Accord, alongside other technology firms, where wepledged to work collaboratively on tools to detect and limit the spread of AI generatedcontent which aims to deceive voters. ● Introduced contextual symbols to help our community understand when they areinteracting with Snap generated AI content. Snap does not allow Lenses that encourage a particular political perspective. In line with thisapproach, politically related Lenses are disabled in Discover. Snap also rejects Lenses thatperpetuate false information to elections (e.g. the wrong date). AR moderators are given strictguidance during elections to escalate misinformation. As a result, when it comes to the inscope content services of Snapchat, rather than takingmeasures to provide users with more context around disinformation and Foreign InformationManipulation and Interference (FIMI) content through labels and other indications, Snap’sapproach is to take steps to avoid recommending such content to a public audience in the firstplace (see below) and to remove such user generated content promptly when it is detected orreported. To the extent political content is distributed on in-scope services (i.e. political ads), Snaphas safeguards in place, which are detailed in the political advertising section below. 143 Election Integrity Partnership, ‘Evaluating Platform Election-Related Speech Policies, October 2020, url. 238 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Recommender Systems Content that is approved for broader audiences must comply with both our CommunityGuidelines and our Content Guidelines for Recommendation Eligibility. All Spotlight andnon-professional user generated Discover content goes through both automoderation, and oftenhuman review, for compliance with these guidelines before it is eligible for recommendation to awide audience. As an additional safeguard, we monitor content that is achieving large-scalereach (and ensure a human reviews it) as a sort of “virality circuit breaker” and a means ofchecking that our pre-moderation systems are working effectively. Any content that is reportedwill be reviewed against the guidelines again for compliance. Political Advertising Political content is only eligible for broadcast (aka algorithmic distribution) on Snapchat onsurfaces reserved for publishers or creators with whom Snap engages in partnership, or throughadvertising. Our political ad policies ensure that any political advertisements are subject to reviewand fact-checking before they are eligible for placement on Snapchat. We also preventadvertisers from manipulating small audiences with micro targeted campaigns, particularly forpolitical ads. We do so by requiring a specific minimum audience tobe targeted (including Dynamic Ads on Snapchat | Snapchat for Business). In 2021 Snap joined the Dutch Code of Conduct for political ads.144 Under this Code onlineplatforms agreed to acknowledge a responsibility in maintaining the integrity of elections andavoid dissemination of misleading content and messages inciting violence or Hate Speech ontheir platforms, committed to making key data on online political advertising available publiclyand help avoiding foreign interference in elections by banning political advertisements fromoutside the European Union, and putting in place a user-friendly response mechanism to answerquestions or solve problems related to the Dutch elections. In preparation for the European Parliament elections we also partnered with Logically Facts, aleading fact checking organisation and signatory of the EU Disinformation Code of Practice, tohelp fact check political ad statements across the EU. we do not require ads to label when advertisement includes generative AI content nordo require advertisers to disclose to us the tools they used to edit or create their ad creative.Instead, our approach is to subject all of our ads to a review process, and political ads are alsosubject to fact checking. Deceptive ads are rejected, irrespective of whether they use AI,photoshop, or other digital editing tools. Ads that are not deceptive, and otherwise comply with 144 For more details url. 239 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT our Ad Policies, are approved to run (and if they are a political ad, they must include a “paid forby” disclaimer and are catalogued in Snap’s political ads library). Influencers Our commercial content policy requires all organic content posted by influencers to be markedappropriately. Commercial content that relates to the following is not permitted: ● Election-related content about candidates or parties for public office, ballot measures orreferendums, political action committees, and content that urges people to vote orregister to vote. ● Advocacy or issue content concerning issues or organisations that are the subject ofdebate on a local, national or global level, or of public importance. Examples include:content about abortion, immigration, the environment, education, discrimination and guns. We now offer a “Paid Partnership” tag tool that influencers and users may use when they postcommercial content to help them comply with this policy and their legal obligations. We makeclear that Snap restricts the paid promotion of political messaging to traditional ad formats. This isin order to be responsible to our community and to maintain transparency. Demonetisation of disinformation content The policies and other mitigations highlighted in this Section ensure that the placement ofadvertising does not provide financial incentives for the dissemination of disinformation and FIMIwith regards to electoral processes and hateful, (violent) extremist or radicalising content that caninfluence individuals in their electoral choices. Integrity of services As explained in this Section, we have appropriate procedures to ensure the timely and effectivedetection and disruption of manipulation of the service when this has been identified by them asa relevant systemic risk, taking into account the best available evidence. We explicitly prevent theuse of “any robot, spider, crawler, scraper or other automated means or interface to access”Snapchat; use of Snapchat “in any manner that could interfere with, disrupt, negatively affect orinhibit other users from fully enjoying” Snapchat and any “attempt to circumvent anycontent-filtering techniques we employ” on Snapchat. When we determine that a user has violated our Terms, we may remove the offending content,terminate the relevant account, and/or notify law enforcement. We may also briefly limit thevisibility of content suspected of being illegal or otherwise violating our terms if needed to enabletime for human moderators to review and provide confirmation (known as “temporary softremoval”). See Section 5.5 for more information. 240 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Third party security and research The severity of these risks is reflected in the resourcing Snapchat has committed to partnershipsand collaborations with leading researchers and civil society organizations who are analyzingthreats to democratic information environments, including the Atlantic Council’s Digital ForensicsResearch Lab, the Center for a New American Security, the Stanford Cyber Policy Center andUniversity of Washington, and the Poynter Institute (which is also secretariat for the InternationalFact-Checking Network). Also reflecting its serious approach to this risk, Snapchat has agreed onvoluntary rules for the 2021 Dutch elections in a Code of Conduct, which governs transparencycommitments regarding online political advertisements during election campaigns (see below formore detail).145 Snap is also subject to audit under the DSA which includes a review of Snap’s compliance with itsrisk assessment and mitigation obligations. Fundamental rights As set out in Section 4.2 of this Report, in line with the requirements of the DSA, when assessing its risks and mitigations, Snap has paid due regard to: ● the protection of fundamental rights enshrined in the Charter of Fundamental Rights ofthe European Union, in particular the right to freedom of expression and of information;and ● the impact of measures to tackle illegal content such as public incitement to violence andhatred to the extent that such illegal content may inhibit or silence voices in thedemocratic debate, in particular those representing vulnerable groups or minorities. As explained above, our platform does not, for example, widely distribute an unvetted feed ofalgorithmically curated political information. Under our Content Guidelines for RecommendationEligibility, Political content is also not eligible for promotion in Spotlight, limiting the ability of anyuser to share political content with strangers on Snapchat, unless it’s from trusted news partnersand creators, and pre-moderate that surface to ensure that other such political content is notdistributed. Mitigation measures linked to generative AI Snap maintains robust policies – applicable to both the dissemination and the creation ofgenerative AI content – that function to mitigate risk and advance safety. Creation On-platform features for creating generative AI content are not part of Snap’s inscope servicesand are out of scope of this Report (save for certain commonplace ad creation tools).Nevertheless, outside of its DSA obligations, we note that Snap has developed several internalpolicies relating to generative AI. In particular, 145 The Dutch Code of Conduct Transparency Online Political Advertisements, url. 241 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT (1) Content and Product policies: We have developed a suite of policies that disallow thegeneration of harmful content (including deceptive political content). Our policy andmoderation teams work in partnership with engineering and data science colleagues toensure that our AI products are responsibly trained on these policy parameters.(2) Acceptable Use: We have similarly developed Acceptable Use Policies that prohibit theuse of our AI tools to attempt to generate violative content at the prompt-level. These aligned very closely with the rules for content dissemination, which are explained below. We have also introduced contextual symbols to help our community understand when they areinteracting with Snap generated AI content. We have created a generative AI support page toexplain our approach to Snapchatters and other stakeholders. Dissemination In the context of dissemination of content on Snapchat’s online platform, in scope of the DSA, weunderstand well that online platforms may have a negative effect on the electoral processes andthe exercise of political rights by amplifying digital disinformation or deceptive content relating topolitical matters or processes. Our Community Guidelines and Terms of Service set out the rules on what content is allowed onSnapchat. They are focused on preventing harm to Snapchatters and the broader communityfrom content and behaviour, whether or not caused by generative AI or any other form of IT tools(such as Photoshop). These rules apply to all content formats across our platform, includingcontent that is AI-generated. While the rules are agnostic to content format or creative tools, theCommunity Guidelines specifically note: “We implement safeguards designed to help keepgenerative AI content in line with our Community Guidelines, and we expect Snapchatters to useAI responsibly. We reserve the right to take appropriate enforcement action against accounts thatuse AI to violate our Community Guidelines, up to and including the possible termination of anaccount.” Our rules and internal enforcement guidance include clear provisions related to content risks forCivic Discourse and electoral processes. In particular, our Community Guidelines prohibitspreading false information that causes harm or is malicious, such as denying the existence oftragic events, unsubstantiated medical claims, undermining the integrity of civic processes, ormanipulating content for false or misleading purposes (whether through generative AI or throughdeceptive editing). As technologies have evolved, we have updated our policies to cover all content formats –whether created by a human or generated by artificial intelligence. Our Community Guidelinesrules on false information refer to a more detailed Explainer that prohibits content thatundermines the integrity of civic processes, or deep fake content or other media that is 242 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT manipulated for false or misleading purposes. The Community Guidelines further explain thatthese prohibitions extend to the following types of harmful content: ● Procedural interference: misinformation related to actual election or civic procedures,such as misrepresenting important dates and times or eligibility requirements forparticipation. ● Participation interference: content that includes intimidation to personal safety or spreadsrumours to deter participation in the electoral or civic process. ● Fraudulent or unlawful participation: content that encourages people to misrepresentthemselves to participate in the civic process or to illegally cast or destroy ballots. ● Delegitimization of civic processes: content aiming to delegitimize democratic institutionson the basis of false or misleading claims about election results, for example. Sharing such content will violate Snap’s Community Guidelines irrespective of whether it isAI-generated or user-generated, or whether it is generated on Snapchat or on another platform. Snap enforces these Community Guidelines fairly and consistently, using internal policies andguidelines, and applies outcomes that are commensurate with the severity of risk. Accounts thatwe determine are used to perpetrate serious, high-severity harms will immediately be disabled.For other violations of our Community Guidelines, Snap generally applies a three-partenforcement process: ● Step one: the violating content is removed. ● Step two: the Snapchatter receives a notification, indicating that they have violated ourCommunity Guidelines, that their content has been removed, and that repeated violationswill result in additional enforcement actions, including their account being disabled. ● Step three: our team records a strike against the Snapchatter’s account. A strike creates a record of violations by a particular Snapchatter. Every strike is accompanied bya notice to the Snapchatter; if a Snapchatter accrues too many strikes over a defined period oftime, their account will be disabled. This strike system ensures that Snap applies its policies consistently, and in a way that provideswarning and education to users who violate our Community Guidelines. The primary goal of ourpolicies is to ensure that everyone can enjoy using Snapchat in ways that reflect our values andmission; we have developed this enforcement framework to help support that goal at scale. Snap has a suite of internal policies and guidelines to help our content review and trust andsafety teams apply the Community Guidelines to user generated content disseminated via ouronline platforms (such as Spotlight and Discover). They provide more granular information for ourcontent review teams. 243 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT In preparation for the 2024 European Parliament elections, we also signed up to the AI ElectionsAccord, alongside other technology firms, where we pledged to work collaboratively on tools todetect and limit the spread of AI generated content which aims to deceive voters. However, asnoted above, Snap’s product design and policy practices outlined above have beendemonstrated to be effective in mitigating the risks of deceptive political content, includingcontent generated using AI tools, from achieving meaningful scale on Snapchat and substantiallyreducing the likelihood of negative impacts on democracy. As noted above, all of our ads aresubject to review, and political ads are also subject to fact checkingDeceptive ads are rejected,irrespective of whether they use AI, photoshop, or other digital editing tools. We continue to detect and monitor risks as outlined in Section 6 of this Report (including workingwith our Safety Advisory Board on the intersection of safety and generative AI technology) andadapt our mitigations accordingly. Cooperation with national authorities, independent experts and civil society organisations Snap has closely followed the negotiations on the EU AI Act and plans to continue to activelyengage and assess collaboration opportunities on the upcoming AI Act, as well as on the drawingof the related codes of practice for providers of general-purpose AI models and those regardingthe detection and labelling of artificially generated or manipulated content. More broadly, tackling risks stemming from generative AI requires (among others) broadindustry-wide technical solutions which have not been clearly identified so far. This is why Snap isactively engaging with its peers and industry experts in different fora to share best practices andadvance the technical debate. These partnerships, industry collaborations and efforts include: ● OpenAI: Although My AI is out of scope of this Report, the fact that My AI is powered byOpenAI’s ChatGPT, has led to a good working partnership with OpenAI. This allows thecompanies to share best practices, including with respect to content moderation. ● Tech Coalition / Working Groups on Generative AI: Snap is a member of the TechCoalition’s Working Group on Generative AI Content, and a member of the GenAI BriefingSubgroup. The Working Group on Generative AI Content meets regularly to facilitatedialogue and information- and idea-sharing around mitigating content-level generative AIrisks. The GenAI Briefing Subgroup meets periodically to plan expert briefings for TechCoalition members on topics related to Generative AI risks; such briefings have includedrepresentatives from government, law enforcement, civil society, and the researchcommunity. ● Tech Accord to Combat Deceptive Use of AI in 2024 Elections: Snap was an initialsignatory to the Tech Accord to Combat Deceptive Use of AI in 2024 Elections. Thiscompact seeks to set expectations for how signatories will manage the risks arising fromdeceptive AI election content created through their publicly accessible, large-scaleplatforms or open foundational models, or distributed on their large-scale social orpublishing platforms in line with their own policies and practices as relevant to the 244 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT commitments in the accord. The Accord was announced at the Munich SecurityConference in February 2024. ● ITI AI Futures Initiative: Through its membership in the Information Technology IndustryCouncil (ITI), Snap has participated alongside other private sector actors in the AI FuturesInitiative. Led by technical and policy experts spanning the tech ecosystem, the Initiativeis a forum through which participants are developing action-oriented recommendationsfor AI policy and working to address emerging questions around AI. Deliverables to datehave included the issuance of Global AI Policy Recommendations to help guidegovernments around the world as to develop responsible regulatory approaches toAI-related issues. ● HackerOne - Red-Teaming Collaboration: Snap partnered with HackerOne on redteaming exercises to test the strict safeguards Snap has in place around AI. Together withHackerOne, we made significant developments in the methodology for AI safety redteaming that has led to a more effective approach to surfacing previously unknownproblems. We refer to the HackerOne blog for more details: https://www.hackerone.com/ai/safety-vs-security. ● As an active member of the EU Internet Forum, Snap will support the upcoming dedicatedworking group on generative AI matters. ● We are also members of the Centre for Information Policy Leadership (CIPL) and theFuture of Privacy Forum (FPF) which work with industry stakeholders (like Snap), NGOsand government agencies in each region to advance a broad array of information topics.CIPL has been a leader in AI matters for many years through its dedicated AI Project andspecific Brazilian AI Project. Most recently, in Europe, CIPL has responded to the UKInformation Commissioner’s Office (ICO)’s consultations on Generative AI, and led variousforums on Accountable Governance of AI and AI Regulation in Brussels and the UK.Similarly, FPF is working on AI Governance and other responsible Gen AI initiatives. Further, we actively engaged in the Commission’s public consultation on its proposed DSAElection guidelines, and similar consultations and queries raised by national DSCs. As shownabove, we have worked to update our risk assessment to take into account the recommendationsin those guidelines. Specific MitigationsIn addition to the detailed highlights above, in the table below we indicate the specific measureswe have taken to mitigate this risk in respect of Snapchat’s in-scope services, using the definedlist of mitigations set out in Article 35 of the DSA. The primary purpose of the below table is toindicate whether each specific mitigation category applies to this risk and the descriptions areillustrative rather than exhaustive. As many of our mitigations apply to all of the risks assessed inthis Report, to reduce duplication in this Report, each row in the tables provides a link in the lefthand column to a full summary of the specific mitigation in Section 5 of this Report whichexplains in more detail how each mitigation operates to reduce the risk. 245 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? Snapchat Design and Function Adapting the design, features orfunctioning of their services, includingtheir online interfaces. As set out in this Section of the Report “Fundamental Rights”,in line with the requirements of the DSA, when evaluatingdesign options by assessing its risks and mitigations, Snaphas paid due regard to the protection of users’ FundamentalRights.Several aspects of Snapchat’s design and function reduce thisrisk of negative effects on the democratic and electoralprocess. ● Unlike many of our peers, Snapchat does not offer anopen news feed where unvetted publishers orindividuals have an opportunity to broadcast harmfuland violative content, does not offer a broad ‘reshare’functionality that would encourage virality, and doesnot allow user-generated content to berecommended to a wide audience without goingthrough further review. ● In particular, Snapchat does not, for example, widelydistribute an unvetted feed of algorithmically curatedpolitical information. Under our Content Guidelines forRecommendation Eligibility, Political content is alsonot eligible for promotion in Spotlight, limiting theability of any user to share political content withstrangers on Snapchat, unless it’s from trusted newspartners and creators, and pre-moderate that surfaceto ensure that other such political content is notdistributed. Terms and Enforcement Adapting their terms and conditionsand their enforcement. Snap’s policies expressly prohibit content that undermines theintegrity of elections and civic processes in accordance withexpert research from the Election Integrity Partnership146. See“Cooperation with national authorities, independent expertsand civil society organisations” above for more details. We take steps to explain our policy approach to safeguardingdemocratic information environments through our CommunityGuidelines and periodic blog posts. As technologies have evolved, we have updated our policiesto cover all content formats – whether created by a human orgenerated by artificial intelligence (including deep fakes). 146 Election Integrity Partnership, ‘Evaluating Platform Election-Related Speech Policies, October 2020, url. 246 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? Snap does not allow Lenses that encourage a particularpolitical perspective. In line with this approach, politicallyrelated Lenses are disabled in Discover. Snap also rejectsLenses that perpetuate false information to elections (e.g. thewrong date). AR moderators are given strict guidance duringelections to escalate misinformation. When we determine that a user has violated our Terms, wemay remove the offending content, terminate the relevantaccount, and/or notify law enforcement. We may also brieflylimit the visibility of content suspected of being illegal orotherwise violating our terms if needed to enable time forhuman moderators to review and provide confirmation (knownas “temporary soft removal”). See Section 5.5 for moreinformation. Moderation Adapting content moderationprocesses, including the speed andquality of processing notices related tospecific types of illegal content and,where appropriate, the expeditiousremoval of, or the disabling of accessto, the content notified, in particular inrespect of illegal hate speech or cyberviolence, as well as adapting anyrelevant decision-making processesand dedicated resources for contentmoderation. Yes, we have specific proactive and reactive moderationprocedures to prevent and remove violative content. As explained in the Moderation section in Section 5, Snapdeploys a range of automated content moderation (whichinclude abusive language detection, other keyword-baseddetection, and machine-learning-based proactive detectionmodels) to scan Stories and Spotlight submissions.Snapchatters can report violative content to us via in-appreporting options and anyone can submit a report through theSnapchat Support Site. Our in-app reporting tool also allowsusers to directly report violative content.Content that is approved for broader audiences must complywith both our Community Guidelines and our ContentGuidelines for Recommendation Eligibility. All Spotlight andnon-professional user generated Discover content goesthrough both automoderation, and often human review,against these guidelines before it is eligible forrecommendation to a wide audience. As an additionalsafeguard, we monitor content that is achieving large-scalereach (and ensure a human reviews it) as a sort of “viralitycircuit breaker” and a means of checking that ourpre-moderation systems are working effectively. Any contentthat is reported will be reviewed against the guidelines againfor compliance. 247 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? Algorithmic Systems Testing and adapting their algorithmicsystems, including their recommendersystems. For more details on our algorithmic systems and ourmeasures to regulate how political content is distributed onthe platform see “Measures to provide users with morecontextual information” and “Recommender Systems” above,in this Section of the Report. Advertising Systems Adapting their advertising systems andadopting targeted measures aimed atlimiting or adjusting the presentation ofadvertisements in association with theservice they provide. Our political ad policies ensure that any politicaladvertisements are subject to review and fact-checking before they are eligible for placement on Snapchat. For moreinformation on our advertising policies and partnershipsaimed at preventing violative advertising practices see“Political Advertising” and “Demonetisation of disinformationcontent” in this Section of the Report. Ongoing Risk Detection andManagement Reinforcing the internal processes,resources, testing, documentation, orsupervision of any of their activities inparticular as regards detection ofsystemic risk. Yes, for example, Snap runs specific prevalence testing andtransparency reporting which we use to help detect andmanage violations of our Community Guidelines and policies. Snap is also subject to audit under the DSA which includes areview of Snap’s compliance with its risk assessment andmitigation obligations. Trusted Flaggers Initiating or adjusting cooperation withtrusted flaggers in accordance withArticle 22 and the implementation ofthe decisions of out-of-court disputesettlement bodies pursuant to Article21. Yes, see the information relating to the Guidelines above,under “Internal Process” and “Access to official information onthe electoral process and Media literacy initiatives” and“Cooperation with national authorities, independent expertsand civil society organisations” and “Third party security andresearch” Codes and Crisis Protocols Initiating or adjusting cooperation withother providers of online platforms or ofonline search engines through thecodes of conduct and the crisisprotocols referred to in Articles 45 and48 respectively. We engage with experts in the information integrity anddemocracy and human rights community to inform ourapproach. This includes collaborations and engagement withindividual experts (such as former US Ambassador to the UNHuman Rights Council Eileen Donahoe, global democracyscholar and Stanford Professor Larry Diamond, and severalothers), as well as think tanks (such as the Atlantic Council’sDigital Forensics Research Lab) and research collaborations(such as the Election Integrity Partnership). Additionally, wepartner with governments around the world to informSnapchatters about elections and invite them to go vote.More information is also available above, under “InternalProcess” and “ 248 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? Access to official information on the electoral process andMedia literacy initiatives” and “Cooperation with nationalauthorities, independent experts and civil societyorganisations” and “Third party security and research”. Transparency Taking awareness-raising measuresand adapting their online interface inorder to give recipients of the servicemore information. Yes, we provide guidance on our terms, harms, moderationand enforcement practices (see the Annex), as well as how toget help in our Safety Center and via in-app resources (HereFor You and Safety Snapshot).We make available robust reporting tools; and we provideguidance to parents on the web (see below). We proactively encourage our users to go to vote throughinteractive campaigns Access to official information on theelectoral process and Media literacy initiatives" section, Snapregularly partners with governments and election authoritiesto encourage voter participation, using creative tools like ARLenses and quizzes. Past collaborations include France, theNetherlands, and Sweden, with recent examples in the 2023Dutch provincial elections and the 2024 European Parliamentelections, where Snap reached young voters across the EUwith interactive reminders to vote. Protection of Minors Taking targeted measures to protectthe rights of the child, including ageverification and parental control tools,tools aimed at helping minors signalabuse or obtain support, asappropriate. We limit exposure to political content to Teens, but doeducate Teens with trusted new sources on current eventsand inform users how they can participate in a democraticsociety. We offer Family Center; we make available robustreporting; and we provide guidance to parents on the web.Our parents site provides additional guidance for parents andcarers on risks and support.147 Content Authenticity Ensuring that an item of information,whether it constitutes a generated ormanipulated image, audio or video thatappreciably resembles existingpersons, objects, places or otherentities or events and falsely appearsto a person to be authentic or truthful isdistinguishable through prominentmarkings when presented on their We recognise the risk that generative AI could be used togenerate harmful false misinformation, including deep fakes.Snap has taken steps to mitigate the risk that (i) its generativeAI tools are used for creating illegal or otherwise violatingcontent and (ii) illegal or otherwise violating content createdusing generative AI tools on any online platform aredisseminated on Snapchat’s inscope services. More information is also available in this Section of the Reportunder “Mitigation measures linked to generative AI”. 147 https://parents.snapchat.com. 249 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? online interfaces, and, in addition,providing an easy to use functionalitywhich enables recipients of the serviceto indicate such information. Conclusion Snap considers the overall risk potential of negative impact on democratic or electoral processesto be in the Level 3 category, given severity of potential harm. However, as described above,Snap has put in place numerous specific mitigations, such as algorithmically preventing thepromotion of political content in Spotlight, enforcing political ad policies, and disallowing Lensesencouraging political perspectives. Further, the design and function of Snapchat is such that it isnot conducive for the widespread distribution of viral content and we provide robust in-appreporting, which further mitigates this harm. Snap recognizes the importance of Democratic andElectoral Processes, and in fact has created interactive campaigns to raise awareness andencourage users to vote. Our prevalence data and our continuing monitoring efforts cited aboveshow that our safeguards are effective at mitigating these risks on Snapchat. We have taken intoaccount the Commission’s recommendations set out in the Guideline for providers of VLOPs andVLOSEs on the mitigation of systemic risks for electoral processes when carrying out ourassessment. We have concluded therefore that Snapchat’s in-scope services have reasonable,proportionate, and effective mitigation measures for the risk of Negative Effects onDemocratic and Electoral Processes. There is no change in this conclusion from our 2024Report. 4.3.2 Negative Effect on Civic Discourse We recognize that without adequate mitigations, digital content platforms like Snapchat cancontribute to Negative Effects on Civic Discourse. Across Snap’s various products, these riskscould include: ● The potential for personalized content and algorithmic biases lock users into echochambers, reinforcing existing beliefs and potentially leading to polarized communities,which hinders open dialogue. ● The risk of amplified dis- and misinformation negatively impacting public opinion onimportant civic issues. ● The possibility of amplification of extreme or sensational content to retain user attentionleading to heightened polarization and a hostile online environment. 250 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Likelihood All of the risks we track on Snapchat have a low prevalence compared to the prevalence of theseissues elsewhere online and offline. To aid our prioritization, our methodology seeks to assessthe relative likelihood between the risks we track (even though all are low in absolute terms). While it is difficult to quantify the likelihood of this social issue, we can draw on the reporting dataavailable to us. Although we have not encountered any specific reports identifying this exact riskon Snapchat, we relate it to existing risks linked to harmful false information (see Section 4.1.10)and Hate Speech (See Section 4.1.2). Our own reporting data indicates that violations in these categories - which we consider potentialsources of harm to civil discourse - are rare. In particular, in our 2024 Report, the prevalence ofharmful false information and illegal hate speech were measured atan extremely low percentage. As of April 2025, we have subsequently observed a furthersubstantial decrease in the prevalence of content falling within these categories. Moreover, when content related to Hate Speech or False Information was detected (whetherproactively through automated tools or reactively following a user report), our Safety teams actedswiftly. According to our latest European Union Transparency Report (covering the second half of2024), the median turnaround time for enforcement action was 36 minutes for Hate Speech and2 minutes for False Information. Consequently, we continue to conclude that this risk still falls within our Extremely Low likelihoodcategory. 251 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Severity At Snap, we take these risks seriously and classify it as such, despite the apparent lack ofprevalence on our platform. Credible studies have shown these risks to fall within our severe. Forexample, a study from the European Parliament148 concludes that the consequences ofdisinformation are extensive and disruptive to democratic societies. Disinformation - particularlywhen widespread on social media - undermines public trust in institutions, distorts politicaldiscourse, and exacerbates social divisions. The study emphasizes that disinformation doesn'tmerely mislead individuals; it actively reshapes public opinion and decision-making bymanipulating emotions, reinforcing bias, and eroding the shared foundation of facts thatdemocratic debate depends on. Moreover, according to the study, beyond its effects on individual users, disinformation alsocompromises the integrity of elections and weakens democratic institutions. It can beweaponized by both domestic and foreign actors to destabilize political systems, influence voterbehavior, and sow discord within and across communities.149 Accounting for the documented risks of these harms across other platforms, we understand thatthe digital platforms play a significant role in potentially negatively impacting civil discourse.However, we assess that our platform architecture and approach to information integrity combineto provide unique safeguards against these threats to civil discourse. DSA Risk Factors In accordance with Article 34(2), our risk assessment also addresses our recommender systems,content moderation systems, applicable terms and conditions, systems for the selection andpresenting of advertisements and any of our data-related practices. These factors have beenlisted and explained in Section 3 on the Risk Assessment Methodology and applied throughout Section 4. We also considered the risk factors in the context of Negative Effects on CivicDiscourse. As many of these factors pose similar risks, and are mitigated in a horizontal manner(i.e. by measures that cut across all systemic risks), we did not include them in this section againbut refer to our explanation in Section 4.1.2 on on Illegal Hate Speech, Section 4.1.10 on HarmfulFalse Information, and Section 4.3.1 on Negative Effects on Democratic and Electoral Processes. Overall potential risk prioritization Snap considers the dissemination of information with actual or foreseeable Negative Effects onCivic Discourse to fall within our severe harm category. 149 148 ). 252 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT (compared to other third party platforms) to navigate for thepurpose of broadly distributed harm. Terms and Enforcement Adapting their terms andconditions and their enforcement. Yes, we take steps to explain our policy approach to safeguardingcivil discourse information environments through our CommunityGuidelines and periodic blog posts. Snap’s policies prohibit the spread of “Harmful False Information,”which we define as false content that may result in broadlydistributed harm, or is malicious. Referencing our internal policyguidance, Snap enforces content as Harmful False Information ifboth of the following elements are present: ● Information is determined to be false ● The false information could cause “broadly distributedharm”. “Broadly distributed harm” refers to harms thatundermine societal- or community-level safety or security;harms that undermine public health; harms that underminecivic processes or the exercise of political rights; and harmsthat denigrate the memory or history of peoples and tragicevents. In addition to our internal policies, Snap’s Community Guidelinesalso note that Harmful False Information is prohibited and includesdenying the existence of tragic events, unsubstantiated medicalclaims, or undermining the integrity of civic processes – all of whichcould contribute to negative impacts on Civic Discourse. Snap policies also prohibit the use of Hate Speech, hate symbols,and/or content that valorizes the perpetrators of, or denigrates thevictims of, human atrocities such as genocide. We define Hate Speech as content that demeans, or promotesdiscrimination towards, an individual or group of individuals on thebasis of their race, color, caste, ethnicity, national origin, religion,sexual orientation, gender identity, disability, veteran status,immigration status, socio-economic status, age, weight, orpregnancy status. Our policies note that Hate Speech may includereferences to people that are dehumanizing or that comparehumans to animals on the basis of these traits and categories. HateSpeech also includes the valorization of perpetrators––or thedenigration of the victims––of hateful atrocities (e.g., genocide,apartheid, slavery, etc.), as well as the promotion of hate symbols. Under Snap’s policies, hate symbols include imagery that isintended to represent hatred or discrimination toward others, 254 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT including those featured in the hate symbols database maintainedby the Anti-Defamation League (ADL).150 Moderation Adapting content moderationprocesses, including the speedand quality of processing noticesrelated to specific types of illegalcontent and, where appropriate,the expeditious removal of, or thedisabling of access to, the contentnotified, in particular in respect ofillegal hate speech or cyberviolence, as well as adapting anyrelevant decision-makingprocesses and dedicatedresources for content moderation. Yes, all Spotlight content goes through both automoderation andhuman review before it is eligible for distribution to a wideaudience. Content that is approved for broader audiences mustcomply with our Community Guidelines and our Content Guidelinesfor Recommendation Eligibility. Any content that is reported will bereviewed against these guidelines again for compliance. Algorithmic Systems Testing and adapting theiralgorithmic systems, includingtheir recommender systems. Yes, our algorithmic systems mitigate risks to Civic Discourse; thisincludes the absence of algorithmically promoted groups, whichhave been shown to contribute to echo chambers and to bevectors for misinformation, with negative consequences for civildiscourse.151 Advertising Systems Adapting their advertisingsystems and adopting targetedmeasures aimed at limiting oradjusting the presentation ofadvertisements in association withthe service they provide. Yes, our political ad policies ensure that any political advertisements are subject to review and fact-checking before theyare eligible for placement on Snapchat. We prevent advertisersfrom manipulating small audiences with micro targeted campaigns,particularly for political ads, by requiring an audience of at least Ongoing Risk Detection andManagement Reinforcing the internalprocesses, resources, testing,documentation, or supervision ofany of their activities in particularas regards detection of systemicrisk. Yes, for example we have specific prevalence testing andmonitoring moderation and enforcement data which we use to helpdetect and manage harmful false misinformation. To remain vigilantagainst threats to civil discourse, Snap engages with experts fromacross civil society and the research community who studyinformation integrity and resilience to online harms. Theseengagements include consultations and collaborations with onlinesafety experts (including those represented on Snap’s SafetyAdvisory Board), with organizations combating online hate (such asthe Anti-Defamation League), and engagement with researchorganizations, including the Atlantic Council Digital ForensicsResearch Lab and the Digital Wellbeing. 151 The Verge, ‘Facebook will stop recommending health groups’, September 2020, url. 150 The ADL database is available at: url. 255 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Trusted Flaggers Initiating or adjusting cooperationwith trusted flaggers inaccordance with Article 22 andthe implementation of thedecisions of out-of-court disputesettlement bodies pursuant toArticle 21. Yes, we cooperate with trusted flaggers, our trusted flaggers mayalso report misinformation, but this rarely happens because of thelimited amount of misinformation on the platform. Codes and Crisis Protocols Initiating or adjusting cooperationwith other providers of onlineplatforms or of online searchengines through the codes ofconduct and the crisis protocolsreferred to in Articles 45 and 48respectively. Yes. We engage with experts in the information integrity anddemocracy and human rights community to inform our approach.This includes collaborations and engagement with individualexperts (such as former US Ambassador to the UN Human RightsCouncil Eileen Donahoe, global democracy scholar and StanfordProfessor Larry Diamond, and several others), as well as think tanks(such as the Atlantic Council’s Digital Forensics Research Lab) andresearch collaborations (such as the Election Integrity Partnership). Snap also works closely with French regulator Arcom, whichmonitors industry action against misinformation. We have alsoworked closely with the Commission and other stakeholders duringthe recent EU elections. Transparency Taking awareness-raisingmeasures and adapting theironline interface in order to giverecipients of the service moreinformation. We proactively encourage our users to go to vote throughinteractive campaigns Access to official information on the electoralprocess and Media literacy initiatives" section, Snap regularlypartners with governments and election authorities to encouragevoter participation, using creative tools like AR Lenses and quizzes.Past collaborations include France, the Netherlands, and Sweden,with recent examples in the 2023 Dutch provincial elections andthe 2024 European Parliament elections, where Snap reachedyoung voters across the EU with interactive reminders to vote. Protection of Minors Taking targeted measures toprotect the rights of the child,including age verification andparental control tools, tools aimedat helping minors signal abuse orobtain support, as appropriate. Yes, we limit exposure to political content to Teens, but do educateTeens with trusted new sources on current events and inform usershow they can participate in a democratic society. We offer FamilyCenter; we make available robust reporting; and we provideguidance to parents on the web. Our parents site providesadditional guidance for parents and carers on risks and support.152 Content Authenticity We recognise the risk that generative AI could be used to generateharmful false misinformation, including deep fakes. Snap has taken 152 https://parents.snapchat.com. 256 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Ensuring that an item ofinformation, whether it constitutesa generated or manipulatedimage, audio or video thatappreciably resembles existingpersons, objects, places or otherentities or events and falselyappears to a person to beauthentic or truthful isdistinguishable through prominentmarkings when presented on theironline interfaces, and, in addition,providing an easy to usefunctionality which enablesrecipients of the service toindicate such information. steps to mitigate the risk that (i) its generative AI tools are used forcreating illegal or otherwise violating content and (ii) illegal orotherwise violating content created using generative AI tools onany online platform are disseminated on Snapchat’s inscopeservices. We also label political advertisements, and maintain apolitical ads library. Conclusion Snap categorizes the risk of negative impacts on civil discourse as Level 3, given the potentialharm from dis/misinformation and online echo chambers. Mitigations, many overlapping withthose for democracy and elections, include proactive content moderation, enforcement ofCommunity Guidelines and Terms, restricting political content, and engagement with outsideexperts. We also take proactive steps, such as encouraging voting and participation in civil discourse, andsetting audience minimums to prevent ad microtargeting. We monitor and act on Harmful FalseInformation (Section 4.1.10) and Illegal Hate Speech (Section 4.1.2), provide in-app tools to reportcontent, and hold advertisers to standards that prohibit false or misleading ads. Our goal is toprevent harmful content from reaching wide audiences while supporting positive, respectfulengagement on Snapchat’s in-scope services. As a result, we have concluded that Snapchat’s in-scope services have reasonable,proportionate and effective mitigation measures against Negative Effects on Civic Discourse.There is no change in this conclusion from our 2024 Report. 4.3.3. Negative Effect on Public Security Without appropriate mitigations, we recognise that digital platforms may present risks to PublicSecurity, particularly in the form of harmful, dangerous, or inciteful content; these risks maybecome compounded when such content may be amplified at great scale and distributed withhigh velocity. The design of Snap’s products and platform architecture scrupulously accounts forthese risks; accordingly, we’ve implemented a number of key safeguards that help to advanceboth the safety of Snapchatters and the interests of Public Security across our services. 257 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Likelihood All of the risks we track on Snapchat have a low prevalence compared to the prevalence of theseissues elsewhere online and offline. To aid our prioritization, our methodology seeks to assessthe relative likelihood between the risks we track (even though all are low in absolute terms). To assess the likelihood of Snapchat’s inscope services having a Negative Effect on PublicSecurity, we have reviewed the sources of data relating to the following illegal and otherwiseviolating content categories considered to have a particular impact on undermining PublicSecurity: Category Relative likelihood of riskoccurring on Snapchat 4.1.2 Dissemination of Illegal Hate Speech Lowest Relative Likelihood 4.1.4 Dissemination of Terrorist Content Lowest Relative Likelihood 4.1.9 Dissemination of content encouraging or engaging in Violent or DangerousBehavior Lowest Relative Likelihood 4.1.10 Dissemination of harmful false misinformation Lowest Relative Likelihood The low prevalence rate of these harms supports our continued assessment that the volume ofcontent presenting risks to Public Security is quite low on Snapchat, and, consequently, it isuncommon to encounter these harms on Snapchat. In terms of likelihood, this risk would fallwithin our Extremely Lowlikelihood category. Severity We have assessed that digital platforms can have consequential negative impacts on PublicSecurity. For example, harmful and dangerous content such as Hate Speech, violent or gorevideos and dis- and misinformation can be shared on the platform, contributing to (the incitementof) real-world harm. In light of these risks, we have undertaken important steps to minimize thelikelihood of such impacts for Snap’s public surfaces. Snap considers the dissemination of information with actual or foreseeable Negative Effects onPublic Security to be a serious risk. For this reason, our policies and practices reflect acommitment to safety, and identify acute areas of risk, such as imminent threats to public placesand content related to terrorism and violent extremism. Security and safety, as well as the dignity of victims, are seriously threatened by the proliferation 258 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT of terrorist materials online and the rising accessibility of such material.153 The EuropeanCommission has outlined that online extremist propaganda has been crucial in radicalizing andmotivating so-called 'lone wolves' to carry out recent terrorist strikes in Europe.154 Researchsuggests that - while not surpassing offline radicalization - there is an increase in onlineradicalisation among young people and women.155 The European Commission has pointed outthat Terrorist Content not only has profound detrimental effects on individuals and society as awhole, but that it also erodes internet users' trust and harms the business plans and reputationsof those companies that are affected.156 The Global Internet Forum to Counter Terrorism (GIFCT)’s 2024 transparency report flagged howthe GIFCT shared 120 reports, 62 of which highlighted attempts by terrorists or violent extremiststo exploit GIFCT member platforms.157 Non-terrorist threats of violence are especially high risk as well. Data from the US National Centerfor Education Statistics shows an increase in school shootings with casualties across public andprivate schools in the US.158 In 2020-21, there were a total of 93 school shootings, the highestnumber in two decades. Victims of school-related violent deaths may include not only studentsand staff, but also others like students' parents and community members.159 For example, theexperience of school shootings is shown to have severe negative effects on surviving youth, withlong lasting consequences to their mental health, educational and economic trajectories.160 Real-world examples show the potential impact of the dissemination of harmful content (e.g. HateSpeech) on Public Security, e.g. amplifying hate-crimes against Rohingya muslims in Myanmar,161 fueling anger of Trump supporters later on contributing to the Capitol Riots,162 and riots in Londonfuelled by misinformation and far right supporters.163 163 BBC, The real story of the news website accused of fuelling riots, url. 162 The Washington Post, ‘Inside Facebook, Jan. 6 violence fueled anger, regret over missed warning signs’, October2021, url. 161 Amnesty International, ‘Myanmar: The social atrocity: Meta and the right to remedy for the Rohingya’, September2022, url. 160 Stanford Institute for Economic Policy Research (SIEPR), Surviving a school shooting:Impacts on the mental health, education, and earnings of American youth’, url, June 2022. 159 V. Irwin, K. Wang, J. Cui, A. Thompson, ‘National Center for Education Statistics. Report on indicators of SchoolCrime and Safety 2021’, url, June 2022. 158 V. Irwin, K. Wang, J. Cui, A. Thompson, ‘National Center for Education Statistics. Report on indicators of SchoolCrime and Safety 2021’, url, June 2022. 157 GIFTC, ‘Transparency Report 2024’, url, 2024. 156 European Commission, ‘Proposal for a Regulation of the European Parliament and of the Council onpreventing the dissemination of terrorist content online’ (COM(2018)640 final), url, 12 September 2018. 155 N. Hamid \& C. Ariza, ‘Global Network on Extremism and Technology. Offline Versus Online Radicalisation: Which isthe Bigger Threat?’, url, 21 February 2022. 154 European Commission, ‘Proposal for a Regulation of the European Parliament and of the Council on preventing thedissemination of terrorist content online’ (COM(2018)640 final), url, 12 September 2018. 153 European Commission, Tackling Illegal Content Online Towards an enhanced responsibility of online platforms (COM(2017) 555 final), url, 28 September 2017. 259 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT To assess the likelihood of Snapchat’s inscope services having a Negative Effect on PublicSecurity, we have reviewed the sources of data relating to the following illegal and otherwiseviolating content categories considered to have a particular impact on undermining PublicSecurity: Category Relative likelihood of riskoccurring on Snapchat 4.1.2 Dissemination of Illegal Hate Speech Significant harm industrywide 4.1.4 Dissemination of Terrorist Content Serious harm industry wide 4.1.9 Dissemination of content encouraging or engaging in Violent or DangerousBehavior Significant harm industrywide 4.1.10 Dissemination of Harmful False Misinformation Significant harm industrywide As these range from significant to serious, and given the context outlined above showing seriousconsequences of a Negative Effect on Public Security, we assess that this category would fallwithin a ‘serious’ harm category. DSA Risk Factors In accordance with Article 34(2), our risk assessment also addresses our recommender systems,content moderation systems, applicable terms and conditions, systems for the selection andpresenting of advertisements and any of our data-related practices. These factors have beenlisted and explained in Section 3 on the Risk Assessment Methodology and applied throughout Section 4. We also considered the risk factors in the context of Negative Effects on PublicSecurity. As many of these factors pose similar risks, and are mitigated in a horizontal manner (i.e.by measures that cut across all systemic risks), we did not include them in this section again butrefer to our explanation in Section 4.1.2 on Hate Speech, Section 4.1.4 on Terrorist Content, Section 4.1.9 on Violent and Dangerous Behaviour, and Section 4.1.10 on Harmful FalseInformation. Overall potential risk prioritization Taking into account the real-world examples illustrating the potential disruptive effects on PublicSecurity, this is a severe risk if not mitigated. However, we are encouraged––based on relevantprevalence data cited above––that our safeguards are substantially effective at mitigating theserisks on Snapchat. The combination of low prevalence and severe nature results in a Level 3 overall potential risk prioritization categorisation. There is no change in this assessment from our2024 Report. 260 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? In addition, as noted in the Civic Discourse section, many of oursurfaces are not ideal vehicles to cause risks to Public Security. Forexample, unless saved to your Public Profile, Public Stories are onlyavailable for a maximum of seven (7) days (and often much shorter),which limits their arc of influence. Similarly, there is considerable technical expertise required to createa Lens, making it a difficult surface (compared to other third partyplatforms) to navigate for the purpose of broadly distributed harm. Terms and Enforcement Adapting their terms andconditions and theirenforcement. Snap’s terms prohibit content that may have a negative impact onPublic Security, including harmful, dangerous, and inciteful content,and they are strictly enforced. We take several steps to ensure that we are addressing this riskacross Snap’s products and services, including enforcement ofseveral relevant platform policies and internal crisis protocols formanaging high-risk scenarios. Snap’s policies include several prohibitions that are enforcedvigorously and equitably to support the interests of Public Security.These policies include a prohibition against spreading Harmful FalseInformation. Internal policy guidance instructs that violations of thesepolicies include risks to Public Security such as Snaps denying theHolocaust or a school shooting, or information obtained illegally thatis being shared to embarrass the person from whom the informationwas stolen. Snap’s policies also include prohibitions on content promotingterrorism or violent extremism, as well as “content that attempts toincite, glorify, or depict real violence that results in personal injury ordeath,” and “depictions of human violence, child abuse, animalabuse, or gore.” We may also consider off-platform behavior when assessing risks toPublic Security. Our Community Guidelines state expressly that“Snap reserves the right to remove or restrict account access forusers whom we have reason to believe, in our sole discretion, pose adanger to others, on or off of Snapchat. These include leaders ofhate groups and terrorist organizations, individuals with a reputationfor inciting violence, perpetrating severe harms against others, orbehavior that we believe poses a threat to human life.” 262 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? Taken together, these several policy provisions provide a basis forappropriately actioning any content that poses an acute risk to PublicSecurity. In addition, we have internal operational protocols for responding topublic crises (see Section 5.12). These protocols include the followingsteps: ● Our vendor teams carefully apply the Community Guidelines and Content Guidelines for Recommendation Eligibility toensure the content is assessed appropriately against ourrules (for example, routinely distinguishing between documenting violence and advocating for violence). ● When breaking news happens, such as ongoing violentprotests, the vendor teams connect with our full-timecontent review team to summarize the kind of content theyare encountering (e.g., violence, property damage, fires,expressions of criticism or support for various politicalpositions), and summarize how they are currently actioningthat type of content against our existing guidelines. ● That summary list comes to our Platform Policy team forreview. Almost all of the time, Policy’s answer is that they'reactioning content correctly. (To cite a recent example, in thecase of French protests over the course of summer 2023,our team determined that existing policies and procedureswere working as intended.) ● In the event that the Platform Policy team determines thatthe policies are not being applied appropriately, the teamwill expeditiously draft clarifying guidance for vendors andcontent review teams The draft guidance will be sharedamong relevant internal leaders for review before beingdistributed to operational teams. Separately, we maintain tight internal protocols for escalatingTerrorist Content or other imminent threats to the appropriate legalor emergency authorities. In such cases, vendors and review teamsare trained to preserve relevant information and immediately send areport to Snap’s Law Enforcement Operations team, who areprofessionally trained to appropriately engage with legal andemergency authorities. 263 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? Moderation Adapting content moderationprocesses, including the speedand quality of processing noticesrelated to specific types of illegalcontent and, where appropriate,the expeditious removal of, orthe disabling of access to, thecontent notified, in particular inrespect of illegal hate speech orcyber violence, as well asadapting any relevantdecision-making processes anddedicated resources for contentmoderation. Yes, we have specific proactive and reactive moderation proceduresto prevent and remove violative content. As explained in the Content Moderation section in Section 5 of thisReport, Snap deploys a range of automated content moderation(which include abusive language detection, other keyword-baseddetection, and machine-learning-based proactive detection models)to scan Stories and Spotlight submissions. Snapchatters can reportviolative content to us via in-app reporting options and anyone cansubmit a report through the Snapchat Support Site. Our in-appreporting tool also allows users to directly report violative content. Furthermore, all Media Partners are vetted prior to being permittedto distribute their content broadly on Snapchat by a team of editors.Media Partners go through an editorial review of their content, areputational search (to evaluate if a Media Partner has a historydamaging press, legal actions, etc.), and compliance review beforethey’re able to distribute content. Algorithmic Systems Testing and adapting theiralgorithmic systems, includingtheir recommender systems. Yes, unlike many of our peers, Snapchat does not offer an opennews feed where unvetted publishers or individuals have anopportunity to broadcast violative content, does not offer a broad‘reshare’ functionality that would encourage virality, and does notallow user-generated content to be recommended to a wideaudience without going through review. Our algorithmic systems do not knowingly recommend violativecontent content, in particular content that may have a negativeimpact on Public Security, including harmful, dangerous, and incitefulcontent. As explained in the Content Moderation section in Section 5 of thisReport, on our high-reach surfaces, like Spotlight and Discover, wetake a proactive approach to moderating any content that mayviolate these rules prior to the content being recommended to awide audience. Advertising Systems Adapting their advertisingsystems and adopting targetedmeasures aimed at limiting oradjusting the presentation of Yes, other mitigations listed here also apply to our AdvertisingSystems. 264 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? advertisements in associationwith the service they provide. Ongoing Risk Detection andManagement Reinforcing the internalprocesses, resources, testing,documentation, or supervision ofany of their activities in particularas regards detection of systemicrisk. Snap runs specific prevalence testing and transparency reporting forcontent that may have a negative impact on Public Security. Trusted Flaggers Initiating or adjustingcooperation with trustedflaggers in accordance withArticle 22 and theimplementation of the decisionsof out-of-court disputesettlement bodies pursuant toArticle 21. Yes, we cooperate with trusted flaggers, our trusted flaggers mayalso report content that may have a negative impact on PublicSecurity, but this rarely happens because of the limited amount ofthis type of content on Snapchat. Codes and Crisis Protocols Initiating or adjustingcooperation with other providersof online platforms or of onlinesearch engines through thecodes of conduct and the crisisprotocols referred to in Articles45 and 48 respectively. Yes, we cooperate with other providers through various industrygroups. Transparency Taking awareness-raisingmeasures and adapting theironline interface in order to giverecipients of the service moreinformation. Yes, we provide guidance on harms and how to get help in ourSafety Center. We make available robust reporting tools; and weprovide guidance to parents on the web (see below). Protection of Minors Taking targeted measures toprotect the rights of the child,including age verification and Yes, we have protective measures to limit Teen contact withstrangers; we offer Family Center, reporting, and guidance. Our newparents site provides additional guidance for parents and caregiverson risks and support.164 164 https://parents.snapchat.com. 265 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? parental control tools, toolsaimed at helping minors signalabuse or obtain support, asappropriate. Content Authenticity Ensuring that an item ofinformation, whether itconstitutes a generated ormanipulated image, audio orvideo that appreciablyresembles existing persons,objects, places or other entitiesor events and falsely appears toa person to be authentic ortruthful is distinguishablethrough prominent markingswhen presented on their onlineinterfaces, and, in addition,providing an easy to usefunctionality which enablesrecipients of the service toindicate such information. Yes, Snap has taken steps to mitigate the risk that (i) its generative AItools are used for creating illegal or otherwise violating content and(ii) illegal or otherwise violating content created using generative AItools on any online platform are disseminated on Snapchat’s inscopeservices. Conclusion Snap considers the negative impact to Public Security to have a Level 3 overall potential riskgiven the potential disruptive effects of content that can, among other things, harm, put in danger,and incite the public at large. That being said, Snapd has put in place a range ofmitigation measures to bring the likelihood of this risk from coming to fruition into the lowestcategory. These measures include our proactive content moderation which is designed to detectand prevent hateful, dangerous, and inciteful content from reaching a broad audience onSnapchat’s in-scope services. As noted in other sections, we continue to invest in measures thatprevent this type of content from reaching a broad audience on Snapchat, as well as provide ourusers with tools to report content to Snapchat and law enforcement, and support our communityvia online and in-app support tools. We have concluded therefore that Snapchat’s in-scope services have reasonable,proportionate, and effective mitigation measures for the risk of Negative Effects on PublicSecurity. There is no change in this conclusion from our 2024 Report. 266 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 4.4 Category 4: Negative Effects on Public Health (Article 34.1.d / DSA Recital 83) In this part of the Report, we explain the results of our assessment on actual or foreseeablenegative effects of Snapchat’s in-scope services on Public Health as required by Article 34.1.dand Recital 83 of the Digital Services Act. We have assessed in particular Negative Effects onPublic Health, Gender-Based Violence, Minors, as well as serious negative consequences to aperson’s Physical and Mental Well-Being. We have considered risks relating to the design,functioning or use, including through manipulation such as by coordinated disinformationcampaigns related to Public Health or from online interface design that may stimulate behavioraladdictions of recipients of the service. Note that for all harms, where there is (1) a risk of significant damage to the physical or emotionalwell-being of Snapchatters, and (2) imminent, credible risk of severe harm, including threats tohuman life, safety, and well-being, we treat this as a severe harm and an Level 1 overall riskprioritization. Category 4 - Negative Effects on Public Health Category Relative likelihoodof risk occurringon Snapchat Harmclassificationindustry wide Risk Prioritization ConclusionSnap’sMitigations 4.4.1 NegativeEffects on PublicHealth Extremely LowLikelihood Severe harmindustry wide Level 3 Low Risk / Reasonable,proportionate andeffectivemitigations 4.4.2 NegativeEffects onGender-BasedViolence Extremely LowLikelihood Serious harmindustry wide Level 2 Low Risk / Reasonable,proportionate andeffectivemitigations 4.4.3 NegativeEffects on Minors Varies Severe harmindustry wide Level 1 Reasonable,proportionatemitigationmeasures havebeenimplemented tosafeguard minorsfrom identifiedharms, with theCommission’sguidance onArticle 28 taken 267 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT into account andcontinuing toinform thisapproach. 4.4.4 SeriousNegativeConsequences onPhysical andMental Well-Being Extremely LowLikelihood Severe harmindustry wide Level 1 Low Risk / Reasonable,proportionate andeffectivemitigations 4.4.1 Negative Effects on Public Health We recognize that without adequate mitigations, digital content platforms like Snapchat couldcontribute to Negative Effects on Public Health. We believe the health and wellness of the publicand our users is paramount to our goal to be a platform of fun and freedom of expression. While we believe these risks to be probable in the absence of mitigations, we assess that Snap’smitigations appreciably reduce the likelihood of encountering these harms on our in scopeservices. Likelihood All of the risks we track on Snapchat have a low prevalence compared to the prevalence of theseissues elsewhere online and offline. To aid our prioritization, our methodology seeks to assessthe relative likelihood between the risks we track (even though all are low in absolute terms). With regards to coordinated disinformation campaigns related to Public Health, as well as anydissemination of content that promotes harmful/unhealthy behavior (e.g., eating disorders orother Self-Harm content), we are encouraged that available data suggests prevalence of contenton Snapchat related to these risks is quite low: 268 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ● In our 2024 Report, we observed that we had a low prevalence of Harmful FalseInformation (including health misinformation) to be extremely low and Self-Harm andSuicide content is extremely low based prevalence testing. ● We are pleased to have subsequently observed a further fall in prevalence of this content, Moreover, our testing indicates a continued year-on-year decline in the prevalence of informationrelated to the sale of prohibited products or services on Snapchat, which covers both legal orillegal products that could potentially lead to health-related issues. At present, content associatedwith the sale of illegal goods has a prevalence rate of 0.0037%, while content related toregulated (but not illegal) activities stands at 0.0175%. Therefore, we continue to assess there is an extremely low likelihood of Negative Effects onPublic Health arising from Snapchat’s in-scope services. Severity Accounting for real-world examples of negative impacts to Public Health, we assess this topresent a severe risk for digital content platforms that must be effectively mitigated. The severityof these risks was perilously illustrated by the spread of misinformation related to the Covid-19pandemic, which promulgated false claims about remedies; resulted in harmful behavior; andjeopardized the containment of the virus. Reports have also shown the impact some social media might have on the mental health ofTeens.165 Commenting on the impact of social media on eating disorders amongst users, the USNational Eating Disorders Associations clarified that social media does not cause eatingdisorders, however it can contribute to eating disorders because of potentially triggeringcontent.166 The European Parliament’s CULT Committee also acknowledges the risk of youngpeople encountering content that promotes eating disorders, body image dissatisfaction anddistorted values and attitudes.167 Moreover, and as outlined in Section 4.1.3, we are conscious of the serious concerns raised byvarious organizations — including Dutch health experts and youth organizations — regarding thealleged illegal sale and promotion of vape-related products, particularly flavoured e-cigarettes, tominors on the platform. We continue to engage with NGOs and law enforcement authorities toadopt measures aimed at preventing such illegal sales. 167 European Parliament, requested by the CULT Committee, ‘The influence of social media on the development ofchildren and young people’, url, 2023. 166 The New York Times, ‘Eating Disorders and Social Media Prove Difficult to Untangle’, url, October 2021. 165 The Guardian, ‘Facebook aware of Instagram’s harmful effect on teenage girls, leak reveals’, url, 14 September2021; E. Bozola e.a., ‘The Use of Social Media in Children and Adolescents: Scoping Review on the Potential Risks’, url, August 2022.; A.M. Memom e.a., ‘The role of online social networking on deliberate self-harm and suicidality inadolescents: A systematized review of literature’, url, October 2018. 269 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT As many of our mitigations apply to all of the risks assessed in this Report, to reduce duplicationin this Report, each row in the tables provides a link in the left hand column to a full summary ofthe specific mitigation in Section 5 of this Report which explains in more detail how eachmitigation operates to reduce the risk. Mitigation Category Applies to this risk? Snapchat Design and Function Adapting the design, features orfunctioning of their services,including their online interfaces. Snapchat’s in-scope services have been adapted to includeproactive moderation to reduce the spread of Harmful FalseInformation, including unsubstantiated medical claims, and theglorification of self-harm, including the promotion of self-injury,suicide or eating disorders. Snapchat offers well-being features designed to educate andempower members of the Snapchat community to support friendswho might be struggling with their social or emotional well-being.These features include “Here for You” content Snap has developedwith the intention of educating Snapchatters about the importanceof mental health, and ways to seek support. In response totroubling search inquiries or content indicating mental or emotionaldistress, our products and teams intervene to surface mentalhealth resources and support (either automatically, or at thediscretion of Trust and Safety personnel). These resources aretailored to a user’s geographic region. Moreover, Snapchat does not offer a marketplace for the sale ofgoods. Terms and Enforcement Adapting their terms andconditions and their enforcement. Our Terms prohibit the spread of Harmful False Information,including unsubstantiated medical claims, and the glorification ofself-harm, including the promotion of self-injury, suicide or eatingdisorders. Our policies elaborate that such prohibited contentincludes any content that, for example, recommends untestedtherapies for preventing the spread of Covid-19; or that featuresunfounded conspiracy theories about vaccines. We have strict enforcement policies. However, since Snapchat isused for communication with friends and family, it is important to usthat our enforcement actions do not deprive users’ friends andfamily of important distress signals and an opportunity to intervene.Accordingly, we instruct reviewing agents that: ○ Reported depictions of suicide or self-harm that reflect anemergency situation should be removed and possiblyescalated to law enforcement or emergency authorities. 271 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ○ Content glorifying or inciting self-harm must be removed andis subject to an enforcement “strike.” ○ Depictions of self-harm or suicidal ideation that do not reflectan emergency situation are permitted so that the communityof people around this person can offer help and support. Our Terms also explicitly prohibit the sale of prohibited products orservices. Moderation Adapting content moderationprocesses, including the speedand quality of processing noticesrelated to specific types of illegalcontent and, where appropriate,the expeditious removal of, or thedisabling of access to, the contentnotified, in particular in respect ofillegal hate speech or cyberviolence, as well as adapting anyrelevant decision-makingprocesses and dedicatedresources for content moderation. Specific proactive and reactive moderation proocesses are in placeto prevent the sale of prohibited products and services andremove Harmful False Information, including unsubstantiatedmedical claims, and the glorification of self-harm, including thepromotion of self-injury, suicide or eating disorders. Algorithmic Systems Testing and adapting theiralgorithmic systems, includingtheir recommender systems. Yes, our algorithmic systems do not categorize or recommendcontent concerning the sale of prohibited products or services,Harmful False Information or content that glorifies self-harm. Advertising Systems Adapting their advertising systemsand adopting targeted measuresaimed at limiting or adjusting thepresentation of advertisements inassociation with the service theyprovide. Yes, other mitigations listed here also apply to our AdvertisingSystems. Ongoing Risk Detection andManagement Reinforcing the internal processes,resources, testing, documentation,or supervision of any of theiractivities in particular as regardsdetection of systemic risk. Yes, we have specific prevalence testing and transparencyreporting related to the sales of prohibited products and services,Harmful False Information and self-harm content. Trusted Flaggers Yes, we cooperate with trusted flaggers in relation to illegal content 272 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Initiating or adjusting cooperationwith trusted flaggers inaccordance with Article 22 andthe implementation of thedecisions of out-of-court disputesettlement bodies pursuant toArticle 21. that harms Public Health. We also cooperate with trusted flaggers in relation to the sale ofprohibited products or services, in particular the National CrimeAgency (NCA - particularly in relation to the sale of drugs). Codes and Crisis Protocols Initiating or adjusting cooperationwith other providers of onlineplatforms or of online searchengines through the codes ofconduct and the crisis protocolsreferred to in Articles 45 and 48respectively. Yes, we cooperate with other providers through various industrygroups e.g. EUIF. To inform a responsible approach to mitigatingthese risks to Public Health, Snap regularly engages with expertsfrom across the field of online safety, health, and wellbeing. Our Safety Advisory Board includes several such experts (including, forexample, Dr. Michael Rich, pediatrician, founder and director of theDigital Wellness Lab \& Clinic for Interactive Media and InternetDisorders, with affiliations at Boston Children's Hospital andHarvard Medical School). These experts have been consultedspecifically on Snap’s approach to wellness and mitigating risksrelated to mental and emotional duress, eating disorders, andother forms of self-harm. Snap has also been partnering with third party providers, NGOsand law enforcements at local level to identify appropriatemeasures to prevent the illegal sale of vape related products.Although this work has focused on the private services ofSnapchat, which are out of scope of this Report, the work has alsoresulted in improvements to mitigations on the in-scope serviceson Snapchat. Transparency Taking awareness-raisingmeasures and adapting theironline interface in order to giverecipients of the service moreinformation. Yes, we provide guidance on our terms, harms, moderation andenforcement practices (see the Annex), as well as how to and howto get help in our Safety Center. Protection of Minors Taking targeted measures toprotect the rights of the child,including age verification andparental control tools, tools aimedat helping minors signal abuse orobtain support, as appropriate. We seek to protect all users from these harms. We offer FamilyCenter; we make available robust reporting; and we provideguidance to parents on the web. Our parents site provides additional guidance for parents andcarers on risks and support.168 168 https://parents.snapchat.com. 273 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Content Authenticity Ensuring that an item ofinformation, whether it constitutesa generated or manipulatedimage, audio or video thatappreciably resembles existingpersons, objects, places or otherentities or events and falselyappears to a person to beauthentic or truthful isdistinguishable through prominentmarkings when presented on theironline interfaces, and, in addition,providing an easy to usefunctionality which enablesrecipients of the service toindicate such information. Yes, Snap has taken steps to mitigate the risk that (i) its generativeAI tools are used for creating illegal or otherwise violating contentand (ii) illegal or otherwise violating content created usinggenerative AI tools on any online platform are disseminated onSnapchat’s inscope services. This would include Harmful FalseInformation, such as deep fakes. Conclusion Snap recognises that, without adequate safeguards, digital content platforms can negativelyimpact Public Health. To address this, we have implemented a range of measures, notablyproactive content moderation to detect and prevent harmful material from reaching a wideaudience. Prevalence rates for Harmful False Information and Self-Harm or Suicide content havefallen substantially and now remain at extremely low levels, indicating our mitigations areeffective. We continue to invest in preventing such content from spreading and in providing ourcommunity with online and in-app support resources. We have concluded therefore that Snapchat’s in-scope services have reasonable,proportionate, and effective mitigation measures for the risk of Negative Effects on PublicHealth. There is no change in this conclusion from our 2024 Report. 4.4.2 Negative Effects on Gender-Based Violence We strongly oppose content that promotes Gender-Based Violence. We recognise that withoutmitigations, a recipient of an online platform’s services could seek to publish this type of content.We take this issue very seriously and have put in place mitigation measures to address this risk. Likelihood There have been well documented examples of individuals, like Andrew Tate, using onlineplatforms to promote content considered to be violent and misogynistic169. Based on surveyscarried out by the EU's Fundamental Rights Agency in 2012 and 2019,170 it estimates that between 170 European Union Agency for Fundamental Rights, survey results of 2012 (url) and 2019 (url). 169 See example at: url. 274 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 4 and 7 % of women aged over 18 in the EU-27 experienced cyber-harassment in the previous 12months, and between 1 and 3 % experienced cyberstalking. The study finds that prevalence hasrisen with greater use of the internet and social media, and is likely to increase further. Snap does not track Gender-Based Violence as a specific, separate category in its TransparencyReports and as part of its prevalence testing. However, this type of content is captured within thescope of each of the following broader categories tracked by Snapchat including content relatingto Hate, Harassment and Bullying, Harmful Information, Adult Sexual Content (in particularsextortion) and Violent and Dangerous Behaviour. We have observed low levels of prevalence ofthis type of content on Snap’s in- scope services: ● In our 2024 Report, we were encouraged by data (second half of 2024) suggesting thelikelihood of encountering such risks on Snapchat is within the lowest level. ● As at 30 April 2025, we are pleased to have subsequently observed a fall in prevalenceacross all of these content types, ● We received 132,611 reports of Hate Speech content in the EU in the second half of 2024,which led to enforcement action being taken against 12,625 unique content items and55,891 accounts. This suggests users are able and willin to report content and accountsas needed on Snapchat (note these numbers relate to the whole of Snapchat, includingprivate spaces that are out of scope of the DSA). We are encouraged by evidence that ourapproach has contributed to a low prevalence of Hate Speech content on the in- scopeservices of Snapchat. From this, we continue to conclude that content promoting gender- based violence falls withinthe Extremely low likelihood category relative to other risks we have assessed. Severity The risks of Negative Effects on Gender-Based Violence stemming from online platforms iswell-documented. In our 2024 Report we highlighted one example, a study from the National Democratic Institute ofInternational Affairs documents the ways in which online misogyny and harassment has chillingeffects on the exercise of political rights––both online and offline––that disproportionately impactwomen.171 Based on this research, such harms can take various forms across platforms, including 171 National Democratic Institute, ‘Tweets That Chill: Analyzing Online Violence Against Women in Politics’, 2019, url. 275 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT gender-based disinformation, Hate Speech, sexual harassment, non-consensual intimate imagery(NCII), sextortion, and human trafficking. We also highlighted that the European Parliament hasproposed a legislative-initiative report calling for EU legislation to fight gender-basedcyber-violence.172 A March 2021 EPRS European added value assessment (EAVA) ongender-based cyber-violence stresses the need for better data at EU and national levels.173 More recently, ‘technology facilitated gender-based violence’ has been recognised as a seriousglobal-scale problem that has increased with improvements and availability of generative AItechnologies.174 Teenage boys are believed to be among the most vulnerable to gangs using realand fake images to blackmail victims and there are reports that teachers in the UK have beenasked to help spot signs their pupils are becoming victims of sextortion.175 We take these risks seriously. The harms stemming from online Gender-Based Violence are notlimited to the digital realm. Studies have suggested for example that gender-based disinformationnot only presents a risk to women online, but also poses threats to national security.176 Moreover,the U.S.-based National Center for Victims of Crime has noted that “the sharing ofNonconsensual Intimate Images can have devastating effects on victims and survivors. Whenimages are shared online without consent, many victims feel ashamed, fearful, guilty, and theactions of sharing non consensual intimate images can lead to real-world implications anddangers.”177 Given its harmful effects and high prevalence in society, Snap continues to qualifythis risk as serious. DSA Risk Factors In accordance with Article 34(2), our risk assessment also addresses our recommender systems,content moderation systems, applicable terms and conditions, systems for the selection andpresenting of advertisements and any of our data-related practices. These factors have beenlisted and explained in Section 3 on the Risk Assessment Methodology and applied throughout Section 4. We also considered the risk factors in the context of Gender Based Violence. As manyof these factors pose similar risks, and are mitigated in a horizontal manner (i.e. by measures thatcut across all systemic risks), we did not include them in this section again but refer to ourexplanation in Sections 4.1.2 on Hate Speech, Section 4.1.6 on Adult Sexual Content, Section 4.1.7 on Harassment and Bullying, Section 4.1.9 on Violent and Dangerous Behaviour, and Section4.1.10 on the Harmful False Information. 177 StopNCII.org, via url. 176 Brookings, ‘Gendered disinformation is a national security problem’, March 2021, url. 175 Teachers warned to be on lookout for victims of sextortion in UK schools, The Guardian - Kevin Rawlinson, April 29,2024, url. 174 Exposing Technology-Facilitated Gender-Based Violence in an Era of Generative AI, 2023, url. 173 European Parliament, ‘Combating gender-based violence: cyber violence - European added value assessment’,March 2021, url. 172 European Parliament, ‘Combating gender-based cyber-violence’, December 2021, url. 276 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? their services, includingtheir online interfaces. Snapchat’s in-scope services that provide an opportunity to reacha larger audience. ● Snapchat has been designed to limit the prevalence of sexuallysuggestive content. ● Snapchat’s in-scope services have been adapted to includeproactive moderation for illegal hate speech and violence, whichincludes Gender-Based Violence. ● Snapchat is not an attractive platform for spreadingmisinformation, in particular because it is difficult to reach a broadaudience and content is deleted by default. ● Snap has made conscious design decisions to restrict the abilityfor content to go viral and limiting the remix functionality tospecific content types and applying short retention to content. As part of our effort to take Gender-Based Violence into considerationacross the design of our services, for example, we have further reviewedthe design of our Lenses. In particular, Snap has removed tips to “Try withFriends” to some Lenses where there is a risk for bullying or harassment,including in relation to Gender-Based Violence. In risky cases, Snap won’tencourage users to try a Lens with friends or Snap disables the Lens forbeing used with the rear camera (e.g. disabling this for the Pride Lenslimits the ability to out someone else). These restrictions only apply toLenses created by Snapchat. For Lenses submitted to Snapchat, we reject harmful Lenses to reducethe likelihood that they are distributed on Snapchat. Terms and Enforcement Adapting their terms andconditions and theirenforcement. Snap takes a multifaceted approach to mitigating risks that may negativelyimpact Gender-Based Violence. Our policies include several prohibitionsagainst content that may contribute to such risks, including sextortion,sexual harassment, NCII, Harmful False Information (which may includegender-based disinformation campaigns), Hate Speech, and humantrafficking. In particular, Snap’s Terms and Community Guidelines expressly prohibit Violent and Dangerous Behaviour, includingGender-Based Violence, and they are strictly enforced. Our terms andcommunity guidelines also prohibit misinformation, Hate Speech, as wellas Harassment and Bullying. We have a specific Harmful False orDeceptive Information explainer which explains our approach toenforcement and a Harassment and Bullying explainer with guidance onhow we apply this policy. Arda Gerken, president of Offlimits, the Dutch hotline formerly known asEOKM, noted “For young males who have experienced a sextortionincident — and the majority are males — they regularly tell us that whenthey share the situation with their parents, they feel relieved (...) We 278 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? advise them to report to hotlines and helplines; to report to the platforms;and to tell their parents, a friend or a trusted adult. They should not begoing through this alone.” Our in-app reporting tool allows users todirectly report threats, violence or dangerous behaviours, includingGender-Based Violence, and anyone can submit a report through theSnapchat Support Site. We promptly enforce against accounts found to besharing this content: ● Snap removes such content for all users. ● Accounts we discover engaging in prohibited activities will alsobe promptly disabled. ● Where appropriate, accounts engaging in violation of thesepolicies are reported to law enforcement as appropriate. Additionally, when we learn of content suggesting that there is anemergency situation involving imminent danger of death or serious bodilyinjury involving any person, we prioritise our response. We may alsoproactively escalate the report to law enforcement in certaincircumstances, and we have processes for referring such content to therelevant authorities as appropriate. We note that escalations to lawenforcement for this category are rare. The overwhelming majority of thecases that fall within this category are not illegal, but do violate ourCommunity Guidelines. When hateful content is reported, our teams will remove any violatingcontent and users who engage in repeated or egregious violations willhave their account access locked. Lenses identified with Hate Speechwere rejected when found during submission and disabled in Discoverupon review if subsequently identified. As an additional measure, weencourage Snapchatters to block any users who make them feel unsafeor uncomfortable. Snap removes violating Hate Speech as soon as webecome aware of it, and will promptly disable accounts dedicated to HateSpeech, hate symbols or groups, or the glorification of hate groups ormembers of a hate group. Specific rules178 apply to our Lenses. Moderation Adapting contentmoderation processes,including the speed andquality of processingnotices related to specifictypes of illegal content and,where appropriate, the Yes, we have specific proactive and reactive moderation procedures toprevent and remove violative content, including content representing orencouraging gender based violence. As explained in the Content Moderation section in Section 5 of thisReport, Snap deploys a range of automated content moderation (whichinclude abusive language detection, other keyword-based detection, andmachine-learning-based proactive detection models) to scan Stories andSpotlight submissions. Snapchatters can report violative content to us via 178 https://businesshelp.snapchat.com/s/article/Lens-Restrictions?language=en 279 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? expeditious removal of, orthe disabling of access to,the content notified, inparticular in respect ofillegal hate speech or cyberviolence, as well asadapting any relevantdecision-making processesand dedicated resourcesfor content moderation. in-app reporting options and anyone can submit a report through theSnapchat Support Site. Our in-app reporting tool also allows users todirectly report violative content. If Lenses are found to be violating our rules and promoting misogynistcontent, Snap takes enforcement action against such Lenses (forexample, we have removed a few Lenses promoting Andrew Tate). Algorithmic Systems Testing and adapting theiralgorithmic systems,including theirrecommender systems. Unlike many of our peers, Snapchat does not offer an open news feedwhere unvetted publishers or individuals have an opportunity tobroadcast harmful and violative content, does not offer a broad ‘reshare’functionality that would encourage virality, and does not allowuser-generated content to be recommended to a wide audience withoutgoing through further review. Our algorithmic systems do not categorize or recommend Violent andDangerous Behaviour, Harassment and Bullying, Hate Speech content orAdult Sexual Content, which would include Gender-Based Violencecontent, as further outlined in the previous sections. Similarly, we do notrecommend content encouraging or engaging in misinformation, includingpotential misogynistic content, i.e. there is no ‘misinformation’ interestcategory. We take steps to prevent content with misleading orsensationalist headlines. In addition, we would note that sensitive content distribution is limited onboth Spotlight and Discover: ● In Spotlight, we limit the distribution of sensitive content based onthe following rules: ○ We do not recommend sensitive content to users under18 by default. ○ We do not recommend sensitive content to new users(i.e. users with less than 200 views in the past 28 days). ○ For all other users, by default, we ensure the initial videowatched in a session is not sensitive and after that weensure that sensitive content is only shown sparingly (i.e.1 in 7 videos). ● In Discover, as in Spotlight, we limit the display of sensitivecontent for all users. We also do not show sensitive content tousers under 18 by default and display of sensitive content can bedisabled entirely in the Family Center. 280 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? Advertising Systems Adapting their advertisingsystems and adoptingtargeted measures aimedat limiting or adjusting thepresentation ofadvertisements inassociation with the servicethey provide. Yes, other mitigations listed here also apply to our Advertising Systems. Ongoing Risk Detectionand Management Reinforcing the internalprocesses, resources,testing, documentation, orsupervision of any of theiractivities in particular asregards detection ofsystemic risk. For example, Snap runs specific prevalence testing and transparencyreporting which we use to help detect and manage Violent andDangerous Behaviour, Adult Sexual Content (including sextortion),Harassment and Bullying, Hate as well as misinformation. Our Safety Advisor Board also has several anti-bullying experts which wecall on for independent review and expertise. We also undertakeintentional efforts to help all stakeholders understand these problemsacross the online community. As part of our Year Two Digital Well-Beingstudy, we conducted a deeper drive into teens’ and young adults’exposure to “sextortion” across platforms and services. The targetcountries were Australia, France, Germany, India, the UK, and the U.S,which includes three of the largest European countries, two of which arein the EU). We have continued this research during 2024 (“Year Three”),and also investigated teens’ and young adults’ attitudes and sentimentsaround reporting problematic content to platforms and services,authorities and others. More information on this research can be found in Section 6.6. Trusted Flaggers Initiating or adjustingcooperation with trustedflaggers in accordance withArticle 22 and theimplementation of thedecisions of out-of-courtdispute settlement bodiespursuant to Article 21. We do not have a specific trusted flagger on Violent and DangerousBehaviour in general but we do engage with several trusted flaggers onspecific behaviors. For example, for certain threats, abusive and coercivebehaviours we cooperate with Refuge. We cooperate with trusted flaggers in relation to illegal hate speech. Snap cooperates with trusted flaggers in relation to Non-ConsensualIntimate Image Abuse (NCII), notably Stop Fisha in France. Codes and Crisis Protocols Initiating or adjustingcooperation with otherproviders of online We also undertake intentional efforts to help all stakeholders understand Gender-Based Violence across the online community. As part of our YearTwo Digital Well-Being study, we conducted a deeper drive into teens’and young adults’ exposure to “sextortion” across platforms and services. 281 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? platforms or of onlinesearch engines through thecodes of conduct and thecrisis protocols referred toin Articles 45 and 48respectively. The target countries were Australia, France, Germany, India, the UK, andthe U.S, which includes three of the largest European countries, two ofwhich are in the EU). We have continued this research during 2024 (“YearThree”), and also investigated teens’ and young adults’ attitudes andsentiments around reporting problematic content to platforms andservices, authorities and others. More information on this research can befound in Section 6.6.Snap cooperates with other providers through various industry groupse.g. e.g. EUIF which has expanded its remit to also tackle the trafficking ofhuman beings (which is often driven by sexual crimes or pornography). We are not working with other providers on Violent and DangerousBehaviour specifically. However, Snap is a member of a number of EUtrade associations to contribute to the policy debate to support thedevelopment of a proportionate regulatory framework to promote onlinesafety. We cooperate with other providers through various groups in relation toHate Speech. Snap remains a signatory of the EU Code of Conduct tocounter Hate Speech online and has worked hard to ensure Snap meetsthe requirements (including with respect to recent revision of that Code). Transparency Taking awareness-raisingmeasures and adaptingtheir online interface inorder to give recipients ofthe service moreinformation. Yes, we provide guidance on our terms, harms, moderation andenforcement practices (see the Annex), as well as how to get help in ourSafety Center and via in-app resources (Here For You and SafetySnapshot).. We make available robust reporting tools; and we provide guidance toparents on the web (see below). Protection of Minors Taking targeted measuresto protect the rights of thechild, including ageverification and parentalcontrol tools, tools aimed athelping minors signalabuse or obtain support, asappropriate. We offer Family Center; we make available robust reporting; and weprovide guidance to parents on the web. Our parents site providesadditional guidance for parents and carers on risks and support.179 Content Authenticity Snap has taken steps to mitigate the risk that (i) its generative AI tools areused for illegal or otherwise violating content and (ii) illegal or otherwise 179 https://parents.snapchat.com. 282 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MitigationCategory Applies to this risk? Ensuring that an item ofinformation, whether itconstitutes a generated ormanipulated image, audioor video that appreciablyresembles existingpersons, objects, places orother entities or events andfalsely appears to a personto be authentic or truthful isdistinguishable throughprominent markings whenpresented on their onlineinterfaces, and, in addition,providing an easy to usefunctionality which enablesrecipients of the service toindicate such information. violating content created using generative AI tools on any online platformare disseminated on Snapchat’s inscope services. This includes HateSpeech and violent content. Conclusion Similar to the related Hate Speech category, Snap considers Gender-Based Violence to fall withinour Level 2 overall potential riskIn response it has put in place a range of mitigation measures. This includes in particularour proactive content moderation which is designed to detect and prevent Hate Speech,including Gender-Based Violence related content from reaching a broad audience on Snapchat’sin-scope services. Although we do not specifically document and report on Gender-BasedViolence as a category, this type of content would primarily fall within the Hate Speech bucket,which has an extremely low prevalence (PVP) on Snapchat. We take this matter very seriously,and continue to invest in measures that prevent this type of content from reaching a broadaudience on Snapchat, as well as provide our users with tools to report content to Snapchat andlaw enforcement, and support our community via online and in-app support tools, such as HereFor You and our Safety Center resources. We believe our approach to these challenges reflectsour commitment to responsibly mitigating harms that may negatively impact Gender-BasedViolence. We are encouraged by evidence that our approach has contributed to a low prevalenceof CSEAI and Hate Speech content on the inscope services of Snapchat. We have concluded therefore that Snapchat’s in-scope services have reasonable,proportionate and effective mitigation measures for Gender-Based Violence. There is nochange in this conclusion from our 2024 Report. 283 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 4.4.3 Negative Effects on Minors We understand that without mitigations, online platforms could have a negative impact on minors.While studies conducted by credible health organizations like the American PsychologicalAssociation (APA) have concluded that digital platforms are not inherently harmful to youngpeople, they suggest that adolescents’ experiences online are affected by the features of theplatforms they use.180 Almost a year after APA issued its health advisory on social media use inadolescence, the APA has noted that society continues to wrestle with ways to maximize thebenefits of these platforms while protecting youth from the potential harms associated withthem.181 Other reports have suggested the impact social media might have on the mental healthof Teens.182 The Committee on the Rights of the Child, the oversight body of the Convention onthe Rights of the Child (CRC), affirms that the CRC also applies to online and digital media in itsGeneral comment no. 25 (2021) on children’s rights in relation to the digital environment.183 TheCommittee underscores that children and Teens need to be protected from risks of all forms ofviolence in the digital environment stating that “such risks include physical or mental violence,injury or abuse, neglect or maltreatment, exploitation and abuse, including sexual exploitationand abuse, child trafficking, gender-based violence, cyber aggression, cyberattacks andinformation warfare.” The Committee of Ministers of the Council of Europe considers it as theirkey aim in the digital environment to offer an open, inclusive and secure internet to children andTeens, while ensuring the protection of their human rights in its RecommendationCM/Rec(2018)7.184 The impact of online platforms on minors has also been a subject of consideration in regulatoryreports from other authorities in Europe. For example, Ofcom’s Children Register of Risks185 explains how UK children are frequently exposed to online hate and bullying targeting protectedcharacteristics such as gender, sexual orientation, race, religion, disability, and transgenderidentity. The same report shows that social media is the primary source of exposure - 78% ofrespondents encountered hateful or discriminatory content there, and 69% reported seeingmisogynistic content. Moreover, other research, including Wired’s report from 2024,186 confirms that social mediacontinues to serve as a significant vector for illegal drug promotion and access among 186 Wired, ‘Drug Dealers Have Moved on to Social Media’, url, (2024) 185 Ofcom, Ofcom Register of Risks, url, (2024). 184 Council of Europe, Recommendation CM/Rec(2018)7 of the Committee of Ministers to Member States onGuidelines to respect, protect and fulfill the rights of the child in the digital environment, July 2018, url. 183 Committee on the Rights of the Child, General comment no. 25 (2021) on children’s rights in relation to the digitalenvironment, CRC/C/GC25, March 2021, url. 182 The Guardian, ‘Facebook aware of Instagram’s harmful effect on teenage girls, leak reveals’, url, 14 September2021; E. Bozola e.a., ‘The Use of Social Media in Children and Adolescents: Scoping Review on the Potential Risks’, url, August 2022.; A.M. Memom e.a., ‘The role of online social networking on deliberate self-harm and suicidality inadolescents: A systematized review of literature’, url, October 2018. 181 American Psychological Association, Potential risks of content, features, and functions: The science of how socialmedia affects youth, url. 180 American Psychological Association, Health advisory on social media use in adolescence,’ url. 284 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT In general, therefore, children and Teens suffer a risk of greater harm from the issues we haveidentified and we have chosen to place the severity of harm arising from an issue that negativelyaffects children in our ‘severe harm’ category. DSA Risk Factors In accordance with Section 3 (Methodology), we have also taken into account, in particular,whether and how the following service risk factors referenced in Article 34(2) of the DSAinfluence the risk of this harm on Snapchat’s in-scope services. As set out below, while thefollowing risk factors could in principle influence this systemic risk, their overall impact is limitedgiven Snap’s existing mitigations, which are described later in this chapter and in Chapter 5. Service Risk Factor How does it apply to Snapchat and this harm? (a) the design of recommendersystems and any otherrelevant algorithmic system; Our recommender systems take user age into account toprovide age-appropriate recommendations. Spotlight andDiscover content for Teens is subject to stricter eligibility rules,moderation, and filtering to prevent sexually suggestive orotherwise age-inappropriate material from being shown.Detailed information regarding the mitigations relating to ourrecommender systems can be found in Section 5 (see the Algorithmic Systems subsection). (b) content moderation systems; Snap has implemented specific proactive and reactivemoderation procedures for minors. These include age-gatingof sensitive content, escalation guidance for moderators,removal of reported content, and Family Center settings that 291 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT allow parents or guardians to adjust access to sensitivematerial and review their Teen’s activity. We provide moreinformation in Section 5 (see Moderation subsection) (c) the applicable terms andconditions and enforcement; Our Term of Service requires public content to be suitable forall Snapchatters (i.e. 13+). This helps ensure Snapchat issuitable for Teens and non-Teen users and reduces risksacross all of the risk categories identified for Snapchat. Weprovide more information in Section 5 (see the Terms and Enforcement subsections). (d) systems for selecting andpresenting advertisements;and Our advertising systems require agreement to advertisingpolicies and guidance that prohibit adverts from displayinginformation that violates the law or causes certain harms tominors. We do not permit ads that target or appeal specificallyto children, and ads unsuitable for minors are not served toTeen accounts. We check advertisers are complying with theirobligations via our advertising review process. Our advertisingsystems use a mix of automation and human review to reviewadverts before they are published. We provide easymechanisms for users to hide and report advertisements thatviolate our policies or the law. We monitor ad rejection,reporting and enforcement data to monitor the effectiveness ofour approach. We provide more information in Section 5 (see the Advertising Systems subsection) (e) our data related practices We have strong data principles, practices and privacy, safetyand security by design processes. Snap applies Privacy byDesign and PASS reviews across products, with privacyexplainers in our Privacy Center written for a 13+ audience.Teens and their parents can access “Privacy by Product” pagesand videos that explain how data is used and what controls areavailable. We provide more information in Section 5 (see theTransparency sub-section) and Section 6 (see the PlatformPrinciples Framework and Privacy and Safety by Design subsections). We have also analysed whether and how the risk of Negative Effects on Minors is influenced bythe following general factors: General Risk Factor How does it apply to Snapchat and this harm? 292 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Intentional manipulation, includinginauthentic use or inauthentic use orautomated exploitation of the service There are two key ways in which we consider our systemscould be manipulated:(1) Users could seek to share novel illegal and violatingmaterial that is not detected by our automatedsystems. We are constantly working to adjust oursystems and policies to address this. We provide moreinformation on our approach in Section 5 (in particular Moderation) and Section 6 (Ongoing Risk Detectionand Management).(2) Users could abuse our content moderation processesand report non-violating content / accounts in badfaith. We have processes to combat misuse and moreinformation can be found in Section 5 (ContentModeration and Enforcement). Amplification and potentially rapid andwide dissemination of illegal contentand of information that is incompatiblewith their terms and conditions. Snapchat’s in-scope services have a number of features anddesign configurations that act to limit the amplification andpotentially rapid and wide dissemination of content harmful tominors, in particular: 1. Snapchat’s design limits virality for minors. Teenaccounts cannot create Public Profiles by default,Spotlight and public content are moderated beforewide distribution, and Teen Spotlight posts areanonymised and subject to stricter moderation andreply controls. Content flagged as sexually suggestiveor otherwise sensitive is filtered from Teen feeds. We provide more information in Section 5 (see SnapchatDesign / Function).2. Snap has implemented specific proactive and reactivemoderation procedures to prevent minors fromaccessing content that is harmful to them. We providemore information in Section 5 (see ContentModeration).3. Content recommended to users on Spotlight andDiscover, our video sharing platforms, is moderatedusing a combination of auto-moderation and humanmoderation, and is human moderated before beingwidely distributed. Lens and Ads are subject to reviewprocesses before submission. We provide moreinformation in Section 5 (see Content Moderation) Specific regional or linguistic aspects,including when specific to a MemberState. We recognise that our users may come from different MemberStates and content may be shared in different languages. Toaddress this, ● Snapchat is provided in multiple EU languages and 293 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 295 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 297 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 298 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ● A more detailed run though of our mitigations to protect Teens on Snapchat is set out in Section5.8 Protection of Minors). Taken together, these mitigations contribute to a safe and responsibleenvironment for young Snapchatters. Specific MitigationsIn the table below we indicate the specific measures we have taken to mitigate this risk in respectof Snapchat’s in-scope services, using the defined list of mitigations set out in Article 35 of theDSA. The primary purpose of the below table is to indicate whether each specific mitigationcategory applies to this risk and the descriptions are illustrative rather than exhaustive. As manyof our mitigations apply to all of the risks assessed in this Report, to reduce duplication in thisReport, each row in the tables provides a link in the left hand column to a full summary of thespecific mitigation in Section 5 of this Report which explains in more detail how each mitigationoperates to reduce the risk. 300 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Mitigation Category Applies to this risk? Snapchat Design and Function Adapting the design, features orfunctioning of their services,including their online interfaces. Yes, Snapchat’s in-scope services have been adapted to includeproactive safety by design features and content moderation forTeens. For example: ● We have created a different product experience for Teens andadults. For example, we don’t show sexually suggestivecontent to Teens. ● All content on Discover has to be appropriate for 13+. ● Regulated goods don’t appear in ads to Teens. ● Snap Map is designed to mitigate particular risks to Teens. Forexample, location sharing is off by default. Terms and Enforcement Adapting their terms andconditions and their enforcement. Yes. For example, our Terms require that all content is appropriatefor 13+, we require all users on our platform to be over the age of 13,and we strictly enforce our terms. If we discover that a user is underthe age of 13 we will remove their account. Moderation Adapting content moderationprocesses, including the speedand quality of processing noticesrelated to specific types of illegalcontent and, where appropriate,the expeditious removal of, or thedisabling of access to, the contentnotified, in particular in respect ofillegal hate speech or cyberviolence, as well as adapting anyrelevant decision-makingprocesses and dedicatedresources for content moderation. Yes, specific proactive and reactive moderation procedures to agegate and ensure age-appropriate content (for example restrictingTeens access to suggestive content), adjust content settings as designated in Family Center and remove reported content fromview. Algorithmic Systems Testing and adapting theiralgorithmic systems, includingtheir recommender systems. Yes, our algorithmic systems take user age into account to provideage appropriate recommendations. Advertising Systems Adapting their advertisingsystems and adopting targetedmeasures aimed at limiting oradjusting the presentation ofadvertisements in associationwith the service they provide. Yes, other mitigations listed here also apply to our AdvertisingSystems. We have also launched changes to Snapchat’s in-scope services sothey no longer display advertisements based on profiling for ourunder 18 accounts in the EU. 301 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Ongoing Risk Detection andManagement Reinforcing the internalprocesses, resources, testing,documentation, or supervision ofany of their activities in particularas regards detection of systemicrisk. Yes, we have specific prevalence testing and transparency reportingfor violations, including for example in relation to CSEAI. Trusted Flaggers Initiating or adjusting cooperationwith trusted flaggers inaccordance with Article 22 andthe implementation of thedecisions of out-of-court disputesettlement bodies pursuant toArticle 21. Yes, we cooperate with numerous trusted flaggers for child safetywho are able to flag other CSEAI or other illegal and violatingactivities involving Teens. Codes and Crisis Protocols Initiating or adjusting cooperationwith other providers of onlineplatforms or of online searchengines through the codes ofconduct and the crisis protocolsreferred to in Articles 45 and 48respectively. Yes, we cooperate with other providers through various industrygroups e.g. Technology Coalition, WeProtect Global Alliance, EUIF,Alliance and CIPL to better protect minors online. We continue toreview our measures against the recommendations in the recentlyreleased Article 28 Guidelines to assess if further reasonable,proportionate and effective measures are needed. See Protectionof Minors for more information. Transparency Taking awareness-raisingmeasures and adapting theironline interface in order to giverecipients of the service moreinformation. Yes, we provide guidance on our terms, harms, moderation andenforcement practices (see the Annex), as well as how to and howto get help in our Safety Center. All information on our Privacy and Safety Center or our SupportCenter is drafted for 13+. For example, Privacy By Product - PrivacyFeatures | Snapchat Privacy provides Teens with ample opportunityto understand the Snapchat features. We also provide Family Center as a resource to Teens and theirparents or trusted adults. Protection of Minors Taking targeted measures toprotect the rights of the child,including age verification andparental control tools, tools aimedat helping minors signal abuse orobtain support, as appropriate. Yes, Snapchat’s in-scope services have been adapted to includeproactive safety by design features and content moderation forTeens. We make available robust reporting and enforcement of ourterms. Our Family Center - Parental Control For Teens | Snapchat Safety provides Teens and their parents or trusted adults a suite ofresources and guidance. Our parents site provides additional 302 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT guidance for parents and carers on risks and support.190 Content Authenticity Ensuring that an item ofinformation, whether it constitutesa generated or manipulatedimage, audio or video thatappreciably resembles existingpersons, objects, places or otherentities or events and falselyappears to a person to beauthentic or truthful isdistinguishable throughprominent markings whenpresented on their onlineinterfaces, and, in addition,providing an easy to usefunctionality which enablesrecipients of the service toindicate such information. Yes, Snap has taken steps to mitigate the risk that (i) its generativeAI tools are used for creating illegal or otherwise violating contentand (ii) illegal or otherwise violating content created usinggenerative AI tools on any online platform are disseminated onSnapchat’s inscope services. We display an icon in some Lensesthat manipulate an image of a Snapchat to make them look younger. Conclusion Although the prevalence of public content that may have negative effects on children on Snap’sin-scope services is generally very low, we recognize that Teens are at risk of greater harm ifexposed and we take the safety and wellbeing of our community, particularly its youngestmembers, very seriously. As such, we have assessed this risk to be in our higher risk prioritizationcategory, Level 1, relative to other risk categories. In response, Snap has put in place a range of mitigation measures. This includes general platformsafeguards such as our Teen friendly terms and support pages, our moderation and enforcementprocesses, our parental tools – Family Center, in-app reporting, and Teen specific contentmoderation and restrictions. Plus, additional safeguards have been put in place to help Teensunderstand and recognize Lenses and ensure that advertisers and advertisements on ourplatform comply with our requirements. We have concluded therefore that Snapchat’s in-scope services have reasonable,proportionate, and effective mitigation measures for the risk of negative effects on Teens andchildren under 18. We continue to review our measures against the recommendations in therecently released Article 28 Guidelines to assess if further reasonable, proportionate andeffective measures are needed. We strongly advocate for further guidelines on the role of‘gatekeeper’ services (such as device operating systems, app stores and web browsers). 190 https://parents.snapchat.com. 303 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 4.4.4 Serious Negative Consequences on Physical and Mental Well-Being Snapchat focuses on helping Snapchatters communicate with their close friends in anenvironment that prioritizes their safety and privacy. It is purposely designed differently fromtraditional social media. It doesn’t open to a public news feed powered by an algorithm with likesand comments. Instead, as outlined earlier in this Report, Snapchat opens to a camera and hasfive tabs: Camera, Chat, Map, Stories, and Spotlight. Additionally, conversations on Snapchatdelete by default to reflect real-life conversations. Before social media, our fun, spontaneous, andsilly interactions with friends only lived on in our memories. Snapchat is designed to mirror thatdynamic, to help people feel comfortable expressing themselves without feeling pressure orjudgment. We will discuss these risks and our mitigations in more detail below. Likelihood All of the risks we track on Snapchat have a low prevalence compared to the prevalence of theseissues elsewhere online and offline. To aid our prioritization, our methodology seeks to assessthe relative likelihood between the risks we track (even though all are low in absolute terms). Snap assesses that serious negative consequences on physical and mental wellbeing are high inlikelihood in the absence of appropriate mitigations. Without mitigations, users of digital platformsmay be exposed to content affecting their mental health, contributing to body dissatisfaction andlow self-esteem. They may also be exposed to content inciting physically harmful activities, suchas dangerous pranks or challenges. On Snapchat, data related to relevant policy enforcements suggests a low prevalence of contentassociated with harm to physical well-being on Snapchat. For example: ● In our 2023 Report, we measured the prevalence (PVP) of Self-Harm content (includingthe promotion or glorification of unhealthy behaviors) and the prevalence of contentpromoting dangerous activities to be extremely low. In 2024, we have subsequentlyobserved a significant decrease in the prevalence of all of these categories of content, ● As of April 30, 2025, the prevalence of Self-Harm content has decreased further, ● 304 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ● We have also assessed the average time spent, as well as the time of day, that Teens useSnapchat and note that the majority of time is spent in the evening and that average timethe average times are not excessive. As noted in the mitigations section below, manydevices now include well-being settings such as turning on bedtime mode by default andproviding screen time controls for parents / responsible adults. 307 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ● The majority of adolescents (60%) experienced unity in negative effects of social media,suggesting that social media use is a contributor to mental health issues. Moreover, 13.6%of adolescents experienced duality in effects, indicating that social media usesimultaneously harms and benefits different dimensions of their mental health. ● The positive and null effects associated with Snapchat and WhatsApp indicate that weshould avoid a blanket condemnation of all social media platforms. ● Snapchat scores a 41.4% positive effect on well-being, 23.7% on self-esteem and 71.5% onfriendship closeness, as shown in the figures and table below: 309 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT On Safer Internet Day, 6 February 2023, we launched our inaugural Digital Well-Being Index(DWBI), a measure of Generation Z’s online psychological well-being across different onlineservices and platforms. To gain insight into how teens and young adults are faring online – acrossall platforms and devices, not just Snapchat – and to help inform our Family Center and thebroader online ecosystem, we polled more than 9,000 people across three age demographics insix countries. Not surprisingly, the research showed that social media plays a major role in GenZ’s digital well-being, with more than three-quarters (78%) of respondents saying social mediahad a positive influence on the quality of their lives. We have repeated this research in 2024. The third Digital Well-Being Index for the six geographies covered stands at 63, one percentage pointhigher than the previous two years, and still a somewhat average reading on a scale of 0 to 100 –neither particularly favorable, nor especially worrisome. 10% of participants described theirexperience online as extremely positive, 44% of them described their overall online experienceas being overall positive, 40% rated their experience as mixed while only 6% reported to haveconsistently encountered negative experiences and outcomes. Further information can be foundin Section 6.6 (DWBI Initiative). Accordingly, while Snap assesses these risks across digital platforms to be high in the absence ofsafeguards and mitigations, we are encouraged by research and data indicating that ourapproach to mitigating these risks is effective at reducing the likelihood of such negative impactson physical and emotional wellbeing on Snapchat. We continue to assess there to be a lowlikelihood of encountering this content on Snapchat. 310 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Severity Snap is deeply committed to the safety and well-being of its community; we recognize thatnegative experiences on digital platforms can have a detrimental impact on mental health andwellness, and therefore work intentionally to ensure that our policies and practices reflect ourcommitment to fostering joyful, creative, and expressive products that contribute positively to thelives of our users. Researchers at Harvard’s Chan School of Public Health note that the current body of scientificliterature “characterizes the link between social media use and health in at least two ways. Onebody of literature considers social media use as a normal social behavior with positive ornegative effects on health-related outcomes, while the other focuses on problematic use andassociated effects.”194 While such studies have shown both positive and negative potentialimpacts on users’ health and wellbeing, the risks of negative impacts are well documented(particularly for teenagers of a particular age).195 Research on screen time shows that an increasein screen time reduces physical activity among children and young people substantially.196 The excessive use of screen-based media among young individuals is an evident and growing publichealth issue that requires significant focus and ongoing research to stay abreast of the rapid andprofound transformations in screen media technology and its usage patterns. Additionally,addiction to social media is a major contributing factor to the rapid increase in several mentalhealth issues197 We note also that in May 2023 the (US) Surgeon General’s Advisory issued a warning regardingsocial media and youth mental health, in particular with regards to exposure to hate-basedcontent and suicide/self-harm-related material198 and that studies continue into the impact ofdigital screen media on physical and mental wellbeing.199 On the other hand, other research hasconcluded that there is no evidence that screen time harms children’s thinking abilities orwellbeing200 and others have presented strong criticism of existing research201. Many haveconcluded that there is not yet enough evidence.202 202 Science doesn’t yet support broad restrictions on teens’ access to social media, experts say LA Times – CorinnePurtill – December 13, 2023. 201 See for example: https://www.peteetchells.com. 200 Children’s brains ‘not harmed by more screen time’, Kat Lay, The Times, 18 Nov 2023. 199 See for example: Impact of digital screen media activity on functional brain organization in late childhood:Evidence from the ABCD study, Jack Miller a, Kathryn L. Mills b, Matti Vuorre a d, Amy Orben c, Andrew K. Przybylski,2023. 198 https://www.hhs.gov/sites/default/files/sg-youth-mental-health-social-media-advisory.pdf. 197 S. Vatsa e.a., ‘Social Media and its Effects on Mental Health, March 2020, European Scientific Journal, url. 196 European Research Council, ‘Immediate and long-term health risks of excessive screen-based media use’, January2023, url. 195 The New York Times, ‘Does Social Media Make Teens Unhappy? It May Depend on Their Age’, March 2022, url. 194 Bekalu e.a., ‘Association of Social Media Use With Social Well-Being, Positive Mental Health, and Self-Rated Health:Disentangling Routine Use From Emotional Connection to Use’, November 2019, url. 311 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT facilitating engagement with friends and family and Snap has put in place significant measures tosubstantially diminish the likelihood and impact of Snapchat's in-scope services having an impacton the Physical and Mental Well-Being of users. In the table below we indicate the specific measures we have taken to mitigate this risk in respectof Snapchat’s in-scope services, using the defined list of mitigations set out in Article 35 of theDSA. The primary purpose of the below table is to indicate whether each specific mitigationcategory applies to this risk and the descriptions are illustrative rather than exhaustive. As manyof our mitigations apply to all of the risks assessed in this Report, to reduce duplication in thisReport, each row in the tables provides a link in the left hand column to a full summary of thespecific mitigation in Section 5 of this Report which explains in more detail how each mitigationoperates to reduce the risk. MitigationCategory Applies to this risk? Snapchat Design and Function Adapting the design, features orfunctioning of their services,including their online interfaces. Several aspects of Snapchat’s design and function reduce this risk. ● Starting with the aforementioned decision to open to thecamera and not a news feed. This encourages selfexpression, communication, and exploration through our ARLenses. ● Snapchat and third parties have created Lenses centered onmovement, fitness, yoga poses, breathing activities. Inaddition to this, there are several partnered lenses thatprompt Snapchatters to talk about wellness, mental healthand their experiences. ● Our user generated content feature, Spotlight, has bothcreator and viewer protections in place. On Spotlight, we put in place protections for both creators and views: ● Creator protections ○ Users can post to Spotlight and choose to disablecomments. ○ If comments are not disabled, Spotlight commentsare auto-moderated for abusive language beforethey are viewed by the creator and all comments canbe reported to human moderation. This protects thecreator from seeing harmful comments. ○ Teens are protected on Spotlight by not having theirusernames displayed. ○ We limit the recommendation of content fromyounger users to older users on Spotlight. This is toprotect Teens from being contacted by older users. 313 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ○ We provide users the ability to post content toSpotlight anonymously. ○ Creators can choose to approve comments on theirSpotlight Stories prior to publication. ○ We do not show view-counts on Spotlight with lessthan a certain number of views. This is to preventembarrassment over low view numbers. ○ We aim to distribute content created by Teens toTeens. This is to prevent Teens from building afollowing that is not their own age. ○ Creators are in control of adding hashtags / topics totheir videos. This provides creators some controlover how their content is categorized. ● Content on Spotlight does not auto-advance. ● We do not have public “favorites”, i.e. a user’s likes andinterests are not public. ● Viewers can “hide” either content or a creator. Subsequently,the user will have a lower likelihood of seeing content of suchnature or content from the creator that has been “hidden”. ● We survey a subset of our users quarterly to understandwhether they find their time spent on our experienceentertainment and satisfactory. We use this to track whetherour product changes are improving viewers' overallperception of the app. ● We provide a diversity of perspectives. We have multipleprograms to foster a more diverse content community andsurface different perspectives (e.g. Black Creator Acceleratorprogram). ● We ensure there is always a large mix of content fromcreators from viewers’ home country and content in thelanguage in which they have set their device. ● We add diversity to every viewer’s feed in terms of theaccount they see, and the categories of content we surfaceto them. This prevents users from entering an echo chamberor filter bubble of seeing the same content repeatedly. Weuse machine learning to understand content categories anddiversify it. For example, we allow users with access to a Public Story to turn offall story reply messages so they don’t see messages from users whoreply to their Stories. We also give users control over Story Repliesand filter out words they don’t want to see. Users can input wordsthat they don’t want to receive in the Story replies from theirsubscribers. If a Story reply contains an inputted word, the user doesnot receive the story reply (and any other story replies) from the 314 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT sender. Additionally, we allow creators to block repliers or reportthem. Terms and Enforcement Adapting their terms andconditions and theirenforcement. Snap’s Community Guidelines prohibit a range of behaviors andcontent that may negatively impact wellbeing, including Harassmentand Bullying; content or Lenses that glorify unhealthy behaviors orpromote unrealistic beauty standards; violent or disturbing content, orcontent that promotes dangerous activities; and content thatpromotes suicide or self-harm. Snap enforces such Community Guidelines along with its Terms. Moderation Adapting content moderationprocesses, including the speedand quality of processingnotices related to specific typesof illegal content and, whereappropriate, the expeditiousremoval of, or the disabling ofaccess to, the content notified,in particular in respect of illegalhate speech or cyber violence,as well as adapting any relevantdecision-making processes anddedicated resources for contentmoderation. Yes, we have specific proactive and reactive moderation proceduresto prevent and remove prevent Harassment and Bullying, content orLenses that glorify unhealthy behaviors or promote unrealistic beautystandards, violent or disturbing content, or content that promotesdangerous activities, and content that promotes suicide or self-harm. As explained in the Content Moderation section in Section 5 of thisReport, Snap deploys a range of automated content moderation(which include abusive language detection, other keyword-baseddetection, and machine-learning-based proactive detection models)to scan Stories and Spotlight submissions. Snapchatters can reportviolative content to us via in-app reporting options and anyone cansubmit a report through the Snapchat Support Site. Our in-appreporting tool also allows users to directly report violative content. If, for example, Lenses are found to be violating our rules andglorifying unhealthy behaviours or promoting unrealistic beautystandards, Snap takes enforcement action against such Lenses. Algorithmic Systems Testing and adapting theiralgorithmic systems, includingtheir recommender systems. Unlike many of our peers, Snapchat does not offer an open newsfeed where unvetted publishers or individuals have an opportunity tobroadcast harmful and violative content, does not offer a broad‘reshare’ functionality that would encourage virality, and does notallow user-generated content to be recommended to a wideaudience without going through further review. Our algorithmic systems do not categorize or recommend contentthat our Community Guidelines prohibit. Our Content Guidelines for Recommendation Eligibility furtherdescribe how sensitive and disturbing content is demoted fordistribution on Spotlight and Discover. For example, glorification ofviolence is not suggested content to users on Spotlight or Discover 315 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT and any discussion on self-harm, including eating disorders isdemoted to users based on their age, location, or personalpreferences. In addition, we would note that sensitive content distribution is limitedon both Spotlight and Discover: ● In Spotlight, we limit the distribution of sensitive contentbased on the following rules: ○ We do not recommend sensitive content to usersunder 18 by default. ○ We do not recommend sensitive content to newusers ○ For all other users, by default, we ensure the initialvideo watched in a session is not sensitive and afterthat we ensure that sensitive content is only shownsparingly (i.e. 1 in 7 videos). ● In Discover, as in Spotlight, we limit the display of sensitivecontent for all users. We also do not show sensitive contentto users under 18 by default and display of sensitive content can be disabled entirely in the Family Center. Advertising Systems Adapting their advertisingsystems and adopting targetedmeasures aimed at limiting oradjusting the presentation ofadvertisements in associationwith the service they provide. Yes, other mitigations listed here also apply to our AdvertisingSystems. For example, ads for diet and fitness products or servicesmust not demean the user, or shame anyone on the basis of bodyshape or side. Ongoing Risk Detection andManagement Reinforcing the internalprocesses, resources, testing,documentation, or supervisionof any of their activities inparticular as regards detectionof systemic risk. For example Snap runs specific prevalence testing and transparencyreporting which we use to help detect and manage for Harassmentand Bullying and Self-Harm and Suicide and other prohibited contenton Snapchat that may impact users mental wellbeing. Our Safety Advisor Board also has several anti-bullying experts whichwe call on for independent review and expertise. Trusted Flaggers Initiating or adjustingcooperation with trustedflaggers in accordance withArticle 22 and theimplementation of the decisions Yes, we cooperate with trusted flaggers in relation to illegal hatespeech and child safety. 316 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT of out-of-court disputesettlement bodies pursuant toArticle 21. Codes and Crisis Protocols Initiating or adjustingcooperation with otherproviders of online platforms orof online search enginesthrough the codes of conductand the crisis protocols referredto in Articles 45 and 48respectively. Snap cooperates with other providers through various industrygroups e.g. EUIF. In 2017 Snap joined FSM and has signed the FSM Code of Conductwhich aims to protect users from content offered on digital servicesthat could endanger or impair their development. Transparency Taking awareness-raisingmeasures and adapting theironline interface in order to giverecipients of the service moreinformation. Yes, we provide guidance on our terms, harms, moderation andenforcement practices (see the Annex), as well as how to get help inour Safety Center and via in-app resources (Here For You and SafetySnapshot). We make available robust reporting tools; and we provide guidanceto parents on the web (see below). Protection of Minors Taking targeted measures toprotect the rights of the child,including age verification andparental control tools, toolsaimed at helping minors signalabuse or obtain support, asappropriate. We offer Family Center; we make available robust reporting; and weprovide guidance to parents on the web. Our new parents site provides additional guidance for parents andcarers on risks and support.204 In addition, as we have explained in the mitigations section of thisReport, in particular Section 5.8 (Protection of Minors), teenagers,parents and other responsible adults are able to set time limits fortheir teenagers, amongst other controls, via the device operatingsystem’s family tools (e.g. Google Family Link, Apple device parentalcontrols and Family Sharing controls and Microsoft Family Safety).Mobile devices now also commonly provide default settings for latenight usage, such as bedtime modes that turn off device and appnotifications and turn the screen the black and white to encouragesleep. Content Authenticity Ensuring that an item ofinformation, whether itconstitutes a generated ormanipulated image, audio or Snap has taken steps to mitigate the risk that (i) its generative AItools are used for illegal or otherwise violating content and (ii)illegal or otherwise violating content created using generative AItools on any online platform are disseminated on Snapchat’sinscope services. We are displaying an icon in some Lenses that 204 https://parents.snapchat.com. 317 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT video that appreciablyresembles existing persons,objects, places or other entitiesor events and falsely appears toa person to be authentic ortruthful is distinguishablethrough prominent markingswhen presented on their onlineinterfaces, and, in addition,providing an easy to usefunctionality which enablesrecipients of the service toindicate such information. manipulate an image of a Snapchat to make them look younger. Conclusion Given the heightened potential for negative consequences on Physical and Mental Well-Beinginherent to online platforms, specifically social media, despite the prevalence on Snapchat beinglow, we consider the risk prioritization to be Level 1. In response, Snap has made deliberate design and policy decisions to reduce the potential forharm on Snapchat. Snap has implemented numerous protections for both creators and viewers ofSpotlight content and undertaken considerable efforts to understand users’ wellbeing onSnapchat and other platforms. We have concluded therefore that Snapchat’s in-scope services have reasonable,proportionate, and effective mitigation measures for the risk of Negative Effects on Physicaland Mental Well-Being. There is no change in this conclusion from our 2024 Report. 318 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 5\. Specific Mitigations Article 42(4)(b) of the Digital Services Act requires providers of Very Large Online Platforms toreport on the specific mitigation measures that they have put in place pursuant to Article 35(1) ofthe DSA. Article 35(1) of the Digital Services Act requires providers of Very Large Online Platformsto put in place reasonable, proportionate and effective mitigation measures, tailored to thespecific systemic risks identified pursuant to Article 34 of the DSA, with particular consideration tothe impacts of such measures on fundamental rights, including where applicable the definedcategories of measures set out in Article 35(1)(a)-(k). In Section 4 of this Report above, we reported on our: (i) assessment of the specific systemic risksapplicable to Snapchat’s in-scope services; (ii) summary of the mitigation measures that Snap hasin place tailored to those risks and (iii) conclusion as to whether those mitigation measures arereasonable, proportionate and effective. In this Section 5, we have provided details of the specificmitigations that Snap has put in place, as are summarized in Section 4, to comply with ourobligation under Article 42(4)(b). 5.1 Snapchat Design and Function 5.1.1 Introduction From day one, Snap has made conscious design decisions to mitigate systemic risks fromoccurring on its platform, including privacy and safety by design decisions such as shorterretention periods, default Story visibility to just friends, not promoting likes on a user’s Story, nothaving public friend lists, and maintaining proactive content policies. Snap has developed aDesign Policy; prohibits the use of dark patterns \& misleading nudge techniques; has created anOnline Design Interface Process to guide Snap Engineering through the process to develop, test,adapt, and deploy changes to the interface that follow Snap’s Design Policy; and has establishedclear roles and responsibilities for review and approval of changes to the system as part ofSnap’s overall Safety and Privacy by Design Process. Snap understands that these measuresalone are not sufficient to address all harms, therefore Snap has implemented additionalmeasures as further outlined in the remainder of this Report. 5.1.2 Oversight and Administration Roles and Responsibilities Roles Responsibilities Legal Teams ● Outlines roles and responsibilities for review of changes to the design,features, or functioning of Snapchat services. ● Reviews proposed feature changes prior to launch for potential darkpatterns on online interfaces. 319 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Design, Product, andEngineering Teams ● Responsible for adhering to Snap’s Dark Patterns Design Policy whendeveloping, testing, adapting, and deploying changes to Snapchatinterface and functionality. DSA Cross-FunctionalGovernance Team ● Reviews Snap’s Dark Patterns Design Policy on an annual basis to ensurethe incorporation of relevant regulatory requirements. DSA Compliance Officer ● Ensures compliance of Snapchat’s online interfaces and organization withDSA requirements. 5.1.3 Adaptations and Mitigations As a result of our privacy and safety by design approach (described in Section 6.3 of this Report),Snapchat was designed from the outset with core features and functionalities that mitigate therisks described in Snap’s Risk Assessment Report. We have made these key foundational design decisions from day one. We hear fromSnapchatters about the benefits of these choices all the time, as well as consulting with expertand teen stakeholders (such as those forming part of our Safety Advisory Board and TeenCouncil) and we believe that these foundational design decisions directly influence those results. Although not all of the features listed below are in scope of the risk assessment, we haveincorporated a summary of holistic mitigations that we have put in place to demonstrate ourprivacy and safety by design approach below. This is not intended to be a comprehensive list. Friending, Chat and Private Stories Friends First, by default users need to accept bi-directional friend requests or already have each other intheir contact book to start communicating directly with each other. This design decision addsfriction and prevents users from communicating with each other prior to accepting a friendrequest or being in one’s contact book. This is also an important mitigation to prevent strangersfrom contacting users on Snapchat. Private friend lists Second, once users have accepted friend requests, the friend lists remain private. Snapchat doesnot disclose the friend lists of users to other users, nor do we expose the total number of friendsthat a user has. This protects the privacy of the user and their friends. On most other platformsfriend lists are public by default or there is an option to share them publicly. These types offeatures create the ability for strangers to contact vulnerable groups (e.g. younger users) andinfiltrate friend groups by going from friend list to friend list. 320 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Open to the Camera not a feed Third, Snapchat opens to the Camera and invites people to express themselves. At the surface,this may sound like a small design decision, but it directly impacts the user behavior on theplatform. Instead of inviting users to scroll a feed of content, the invitation to users is to expressthemselves, live in the moment and share a moment with their close friends. Stories are by default set to be viewable by friends, not the public Fourth, once users decide to share a Snap via My Story, by default only friends can view it.Snapchatters can choose to share to everyone, only to friends, or to a customized few. Thisemphasis on sharing with friends and giving users controls over who can view their content are inline with how Snap takes into account privacy and safety when designing its features. No focus on public vanity metrics Fifth, once a user posts to their Story, we don’t show vanity metrics, such as likes on that Storycontent. The goal is not to create a popularity contest around who has the most friends orlikes.205 The design choice is to provide all users with a more authentic form to expressthemselves. As a result of our privacy and safety by design approach, each of Snapchat’s in-scope serviceshas been designed with features and functionalities that mitigate the risks described in Section 4 above. Spotlight and Discover SpotlightSpotlight offers creators at all stages of their career a variety of opportunities and tools to helpthem grow their audiences, build sustainable businesses and make content creation a full-timecareer. The content shown in Spotlight is personalized to provide viewers with a more relevantexperience, that ‘spotlights’ the best content on Snapchat. We have made following designdecisions to protect our creators and users: ● Creator protections ○ Users can post to Spotlight and choose to manually approve or deny comments. ○ Spotlight comments are auto-moderated for abusive language before viewed bythe creator and all comments can be reported to human moderation. This protectsthe creator from seeing harmful comments. ○ Adults cannot comment on Teen’s Stories on Snapchat. ○ Teens are protected on Spotlight by not having their usernames displayed on theirSpotlight posts. 205 See also our More Snapchat campaign https://www.moresnapchat.com/ 321 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ○ We restrict Teens' ability to reach a large audience on Spotlight to prevent olderusers from seeing content from younger users. This is to protect Teens from beingcontacted by older users. ○ We aim to distribute content created by minors to minors. This is to prevent minorsfrom building a following that is not their own age. ○ Creators are in control of adding hashtags / topics to their videos. This givescreators control over how their content is categorized. ● Viewer protections ○ Content on Spotlight does not auto-advance. ○ We do not have public “favorites”, i.e. a user’s likes and interests are not public. ○ Viewers can “hide” either content or a creator. Subsequently, the user will not seemore content of such nature or content from the creator that has been “hidden”. DiscoverDiscover is dedicated to Creator Stories, which includes Media Partner content and some usergenerated content from popular users (“Creator Content”). The Creator Content that appears onDiscover includes Public Stories from Snap Stars and other users who meet a follower countthreshold. Similar to Spotlight, we made following design decisions to protect our creators andusers: ● Creator protections ○ Viewer comments are not typically available on Discover content. Wherecomments are enabled, they are subject to auto-moderation. Creators and otherusers can report comments, which leads to human review. They can also blockcommenters which will prevent them from ever seeing the blocked users’comments again on any content. ○ We do not show “views” on Discover Stories. This protects creators from feelingembarrassed or being subject to ridicule due to low number of views. ○ Content published by creators has a limited publication duration (which may bechanged by creators with a Snapchat+ subscription). This protects creators byensuring their content is not available forever. ○ Creators are free to re-publish new and saved stories at any time, provided it doesnot violate the law or our Terms. ● Viewer protections ○ Content on Discover does not auto-advance. ○ We do not have public “favorites”, i.e. a user’s likes and interests are not public. Public Profile Users with a Public Profile can post Public Stories that are publicly viewable for all Snapchatters.Additionally, Snapchatters can showcase their Public Stories and Spotlights on their profile. 322 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Snapchatters can watch Public Stories on Discover, Snap Map, Spotlight. Users can also Follow aPublic Profile. Unlike friend requests to non-Public Profile owners, Public Profile owners will notreceive a notification for new followers. We have made the following design decisions to protectusers with Public Profiles: ● Users can easily delete all of their public content. We allow users to delete all of theirpublic content in a single tap. We delete any and all content they added to their PublicProfile and that is publicly viewable. Our public options are in fact options. If Snapchattersare not or no longer interested in being a creator and showcasing content publicly, theycan simply choose to not add to their Public Profile, post to their Public Story, or share toSpotlight and to the Snap Map. ● We give users control over content that is publicly viewable by allowing users to hide orshow their Spotlights on their Public Profile both at the time of submission and aftersubmission. ● Public Profile users can turn off remixes. We allow users to decide whether their publiccontent can be remixed by other users. ● We educate users on their public options and attribution controls. When users first tap ontheir public profile, public story, and spotlight/snap map posting, we show themeducational modals that educate them about the public option. ● To ensure that users are aware when they become friends with another user so that theycan control what data that user has access to, we send notifications to the user when theybecome friends with another user (bi-directional add has occurred). ● Only users with an older teenage account (16-17) or an adult account (18+) can have aPublic Profile and Public Story. Viewers cannot distinguish between users without PublicProfiles (under 16) and users with Public Profiles (16+) who have not edited the Profile inany way. We have additional mitigations for our older teenager with a Public Profile: ○ When they first interact with their Public Profile page, post to Spotlight or SnapMap, or share a Public Story, they are shown a dedicated notice explaining whatPublic Profiles are and how to use them appropriately. This notice links to the support pages providing more information on Public Profiles; ○ they can decide whether to make each piece of content public or private whenposting; and ○ as with all Snapchatters, they have control over each piece of content they createwith intentional posting options that let them determine where Snaps are shared,who can see them, and if they are saved to their profile; ○ their Spotlight will be publicly accessible with their username until the user deletesor hides the post, but will not be recommended to others until it passes ourauto/human moderation checks; ○ their Public Stories posted by users 16-17 will be recommended only to thefollowing categories of users but not on Discover and Spotlight online platforms: ■ Friends in the Friends Story Carousel of the 4th tab 323 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ■ Followers in the Following Story Carousel of the 4th tab ■ Friends of Friends (with a significant number of mutual friends) in theFriends Carousel of the 4th tab ○ users replying to a Public Story are shown a notice explaining that their reply maybe made public; ○ they will continue not to have the option to post to Snap Map with their nameshown; accepted submissions to the Snap Map will be displayed anonymously asthey are now; ○ older teens will have more limited access to analytics on Snapchat about theperformance of their Public Stories and Spotlight videos, which creators use togrow an audience. In particular, they will not see how many people “favorited”their Stories or Spotlights, keeping the focus on creativity over pressure to collectpublic approval metrics. ● We give users control over their ability to be contacted. We allow users with access to aPublic Story to turn off all Story reply messages so they don’t see messages from userswho reply to their Stories. We also give users control over Story Replies and filter outwords they don’t want to see. Users can input words that they don’t want to receive in thestory replies from their fans. If a story reply contains an inputted word, the user does notreceive the story reply (and any other story replies) from the sender. Additionally, we allowcreators to block repliers or report them. We have also built in protections for users who engage with a Public Profile. For example, weinform users before they send a Story reply to a creator that the creator could quote the replyand make it publicly viewable (with the replier’s first name and Bitmoji). We also limit unwarrantedconnections between younger users and bad actors on the platform. Snap Map We have safeguards for creators and viewers regarding the content on Snap Map, for example: ● Creator protections ○ We filter Stories posted from users with new accounts so they do not feature onSnap Map. ○ Content posted to Public Stories will only show on Snap Map with a clear locationif there are multiple users posting in a short time nearby and a percentage ofthose posters are non-Teen accounts. ○ Currently there is no ability to comment on Snap Map content. ○ We do not show “views” for Stories on Snap Map. Protects creators from feelingembarrassed or being subject to ridicule due to low number of views. ○ Content published by creators has limited publication duration (which may bechanged by creators with a Snapchat+ subscription. This protects creators byensuring their content is not available forever). 324 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ○ Younger teen accounts (13-15) in the EU also don’t have the ability to post to PublicStories which means that their Snaps are not eligible for the Snap Map. They canpost directly to Snap Map but will not attribute their username to the post tominimise discoverability. ○ Older teen accounts (16-17) in the EU have additional public posting options.Before launching this new functionality Snap conducted extensive testing andevaluation, and presentation to the Commission and other regulators, prior tolaunch. Our monitoring of key metrics showed that the EU launch performed inline with expectations. We have summarised the additional safeguards above. ● Viewer protections ○ When users, including younger individuals, use Snap Map, Snap collects and usesprecise location data for the purpose of providing the feature to the Snapchatter These controls prevent illegitimate use of Snap Map and protects Teens from exploitation.With regards to location sharing on Snap Map, there are numerous additional design choices inplace to make Snap Map a safer space for our community. These include: ● Permission based and only Friend sharing. Processing of users’ precise location,including location information of children, is off by default. Given the sensitivity ofgeolocation data, Snap provides ‘just in time’ information to EU users about preciselocation when they access Snap Map. Clicking “Allow” on the ‘just in time’ informationnotice does not grant Snap with access to the user’s precise location, but instead opensthe user’s device settings so that they can make the location sharing choice that theyconsider is most appropriate for them. This notice facilitates users’ direct access to theprecise location settings of their device. This permission based approach ensures thatusers retain control over what services they are requesting and how and when theirprecise location data is used. ● No option to share location with strangers. We want location sharing on Snap Map to belimited to engagement with friends on Snapchat. We also want to ensure user safety bynot broadcasting a user’s location to others who are not friends of the user. Therefore,users cannot share their location with strangers. In Settings, users can choose to sharetheir location with their friends, or a subset of friends only. There is no option to sharetheir location with non-friends. Friendship must be bi-directional. ● Permission and prompts. By default, users are not sharing their location with any friends,as all users are defaulted to “Ghost Mode”. This was to ensure that location sharing wouldbe understood by users before activation, in particular younger users so they could makeinformed choices about whether to use Snap Map, whether to share their location and, if 325 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT so, with whom to share it. Snapchatters can update: (1) whether they are sharingbackground location or only while using location; and (2) who among their friends can seetheir location at any time right from the settings gear in the Map. ● Creator protections ○ Currently there is no comments on Snap Map content ○ We do not show “views” for Stories on Snap Map. Protects creators from feelingembarrassed or being subject to ridicule due to low number of views. ○ Content published by creators has a limited publication duration (which may bechanged by creators with a Snapchat+ subscription. This protects creators byensuring their content is not available forever). ○ Creators are free to re-publish new and saved stories at any time, provided it doesnot violate the law or our Terms. ● Viewer protections ○ We do not have public “favorites”, i.e. a user’s likes and interests are not public . 326 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Lenses Lenses (in popular language often dubbed as ‘filters’) are created by a relatively limited numberof community developers, and Snap’s internal Lens Team. Our Lenses are designed withprivacy-and-safety-by design principles in mind. For example, Lenses require object detectionrather than facial identification. Lenses can tell what is or isn’t a face, they do not identify specificfaces, limiting data processing for the use of Lenses. Snap does also not use any data collectedby Lenses to customize the content that the user sees in Spotlight or Discover, nor is any datacollected for advertising purposes. Besides, voice data collection of Snapchatters in the EU is offby default; it is only used to provide the service. Snap also designs every Lens with race, gender, ethnicity and cultural norms in mind. Snapleverages its ever-growing diversity training datasets, as well as feedback from communitymembers. If a Lens does not resonate with our community, as expressed through a high ratio ofuser reports, we take that feedback into consideration and will re-review the Lens with a goal toleave as-is, modify, or remove. Advertising We have also put in place risk mitigation measures for our advertising efforts. We preventadvertisers from manipulating small audiences with microtargeted campaigns, particularly forpolitical ads. We do so by requiring a specific minimum audience of Snapchatters tobe targeted (including Dynamic Ads on Snapchat ). This prevents microtargeting that can influence voters politically or push targetedmisinformation to certain populations. Our advertising systems also do not use ‘special category’personal data to target ads and we require advertisers to provide additional information forpolitical ads. 5.1.4 Integrations with other mitigations On Snapchat we have also adapted our features to integrate with our other risk mitigationsdescribed in this Specific Mitigations section of the Report, for example: Terms All public content must adhere to our Terms, for example the content must be suitable for 13+, inorder to be featured or receive broad distribution on Spotlight and Discover. This is explained inthe Terms Section and Transparency Section. Content Moderation We moderate content on Snapchat in a number of ways to mitigate the risks of users beingexposed to harmful and illegal content. This is explained in the Moderation Section and Enforcement Section. Content Distribution We have put in place risk mitigation measures to restrict the distribution of harmful content on 327 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Snap. For example: ● Content that is Sexually Suggestive and Sensitive but otherwise allowed under ourCommunity Guidelines is not distributed to Teens. ● Spotlight Comments with abusive language are removed. ● Ranking avoids ‘filter bubbles’ through demotion, ensuring similar content isn’tsequentially recommended to Snapchatters in Discover or Spotlight.This is explained in Sections 5.6 (Algorithmic Systems) and 5.7 (Advertising Systems). 5.1.5 Online Interface Design Process Snap implemented the following process and governance around online interface design: 328 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ● 329 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Online Design Principles Snap also established Online Design Principles which prohibit the use of darkpatterns \& misleading nudge techniques. ● 5.1.6 Conclusion From day one, Snap has made conscious design decisions to mitigate systemic risks fromoccurring on its platform, including privacy and safety by design decisions such as shorterretention periods, default Story visibility to just friends, not promoting likes on a user’s Story, nothaving public friend lists, and maintaining proactive content policies.Snap has implementedadditional measures as further outlined in the remainder of this Report. 330 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT As explained in Section 4, we have concluded that the adaptations made by Snap to thedesign, features and functioning of Snapchat’s in-scope services, in combination with theother mitigations explained in this Section 5, are reasonable, proportionate and effectivemitigation measures for the risks identified. 5.2 Terms 5.2.1 Introduction This document outlines Snap’s protocol for communicating its platform Terms and Conditions tousers, in compliance with the requirements of the DSA, in particular with regard to Articles 14 and27. Snap publishes its Terms and Conditions (which comprises the terms, guidelines, and policiesdefined in the section “Terms and Conditions” below) with concise summaries in clear, easilyunderstandable, unambiguous language, in a publicly available, easily accessible, andmachine-readable format. Snap’s Terms and Conditions include detail on (among other things):how use of the service may be restricted; content moderation policies and procedures;information on the use of algorithms, the parameters and criteria behind recommender systemfunctioning, and how to adjust them; instances when user access and/or content may berestricted, suspended or terminated; and instructions on the internal complaint handling system.This information is primarily provided in Snap’s Terms of Service, which are translated into allofficial EU member state languages. Snap’s Terms of Service prohibit any use of Snapchat toconduct illegal activities. In addition to the Terms of Service, Snap also publishes Community Guidelines (incorporated intothe Terms of Service by reference), Privacy Policies, product-specific terms, a CommercialContent Policy, Content Guidelines for Recommendation Eligibility, and Advertising Policies.Snap's Community Guidelines elaborate on restrictions of the use of Snapchat related to: SexualContent, Harassment and Bullying, Threats, Violence \& Harm, Harmful False or DeceptiveInformation, Illegal or Regulated Activities, and Hateful Content, Terrorism, and Violent Extremism.Notably, the sections within our Community Guidelines on Illegal or Regulated Activities expresslyprohibit users from using Snapchat to send or post content that’s illegal in their jurisdiction, or forany illegal activity. 5.2.2 Oversight and Administration Change Management On an annual basis (or sooner on an ad hoc basis should a pressing need arise), Snap'sManagement body (including Legal and Public Policy team stakeholders) review and updatevarious Snapchat Terms and Conditions (including Community Guidelines, Terms of Service, 331 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Privacy Policies, and Advertising Policies) for additional information that may result in impact onour risk and mitigation assessments, and to ensure that the Terms/Guidelines accurately reflectthe contractual relationship and/or other obligations between users of the respective Servicesand Snap and adhere to applicable legal requirements. Snap's Legal team has a formal process in place to make and track changes to the Terms andConditions and to communicate key changes to stakeholders in a timely manner. Snap’s Terms and Conditions are regularly reviewed (and updated as needed) by Legal andPolicy team stakeholders, including Commercial, Privacy, and Product Legal teams and PlatformPolicy, to ensure that they accurately reflect the contractual relationship and/or other obligationsbetween users of the respective Services and Snap and adhere to applicable legal requirements.When updates are identified, depending on the term, policy, or guideline, proposed revisions aredrafted and approved by the owner of the respective document. For certain terms, like the Termsof Service, a changelog may be created to further document the update and approval process.Once the document is finalized and approved, it is then localized in all supported languages,including all official languages of the European Union as explicitly required by the DSA. To theextent the changes to the terms, policies, or guidelines are determined to be material, Snap willprovide users with reasonable advance notice. Snap provides an in-app pop-up to notify recipients of the service of material changes to theTerms and Conditions. 332 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Roles and Responsibilities Roles Responsibilities Snap Legal ● Maintains a formal process to draft, review, update, approve, andcommunicate changes to Snap’s Terms and Conditions. Public Policy ● Consults with industry experts, including the Safety Advisory Board, onSnap’s Terms and Conditions as needed. ● Reviews proposed changes to Snap’s Terms and Conditions. DSA IndependentCompliance Officers ● Review Snap’s Terms and Conditions to ensure they meet DSArequirements. 333 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ● Provides oversight over Snap’s Content Moderation mechanisms toensure the diligent, objective, and proportional enforcement of Snap’sTerms and Conditions. 5.2.3 Terms and Conditions Snap publishes and maintains a series of legal documentation that make up our Terms andConditions and govern use of Snap’s products and services by its users: ● Terms of Service ● Community Guidelines ● Privacy Policy ● Snap and Ads ● How We Rank Content on Spotlight ● How We Rank Content on Discover ● How We Rank Content on Lenses ● How We Rank Content on Maps In addition, in response to the Digital Services Act we have provided short summaries in eachsection of our Terms of Service, as well as easy to read explainers of key sections of our Community Guidelines. Each of our Terms and how they mitigate each of the DSA risk categories is explained below. Terms of Service All Snapchatters are required to agree to Snap’s Terms of Service before they can use Snapchat. 334 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Snap publishes its Terms of Service on the website and in-app within a user’s app settings. It iseasily accessible via search engine and machine readable. The Terms of Service include information on: ● Restrictions imposed on use of services (these are elaborated upon in Snap’s CommunityGuidelines, Privacy Policy, and Advertising Policy) ● Policies, procedures, measures and tools used for the purpose of content moderation,including algorithmic decision-making and human review ● Rules of procedure of Snap’s internal complaint handling system and available remediesand redress mechanisms. ● Main parameters used in Snap’s recommender systems. 335 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Restrictions Imposed The following restrictions are included in Snap’s Terms of Service. Who Can Use the Services Our Services are not directed to children under the age of 13, and you must confirm that you are13 years or older to create an account and use the Services Respecting the Services and Snap’s Rights You must also respect Snap’s rights and adhere to the Snapchat Brand Guidelines, Bitmoji BrandGuidelines, and any other guidelines, support pages, or FAQs published by Snap or our affiliates. Respecting Others' Rights You therefore may not use the Services, or enable anyone else to use the Services, in a mannerthat violates or infringes someone else’s rights of publicity, privacy, copyright, trademark, or otherintellectual property right. Safety By using the Services, you agree that you will at all times comply with these Terms, including ourCommunity Guidelines and any other policies Snap makes available in order to maintain thesafety of the Services. 336 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Content Moderation The following Content Moderation information is included in Snap’s Terms of Service. Much of the content on our Services is produced by users, publishers, and other third parties.Whether that content is posted publicly or sent privately, the content is the sole responsibility ofthe user or entity that submitted it. Although Snap reserves the right to review, moderate, orremove all content that appears on the Services, we do not review all of it. So we cannot — anddo not — guarantee that other users or the content they provide through the Services will complywith our Terms, Community Guidelines or our other terms, policies or guidelines. You can readmore about Snap’s approach to content moderation on our Support Site. Users can report content produced by others or others’ accounts for violation of our Terms,Community Guidelines or other guidelines and policies. More information about how to reportcontent and accounts is available on our Support Site. We may restrict, terminate, or temporarily suspend your access to the Services if you fail tocomply with these Terms, our Community Guidelines or the law, for reasons outside of ourcontrol, or for any other reason. That means that we may terminate these Terms, stop providingyou with all or any part of the Services, or impose new or additional limits on your ability to useour Services. For example, we may deactivate your account due to prolonged inactivity, and wemay reclaim your username at any time for any reason. And while we’ll try to give youreasonable notice beforehand, we can’t guarantee that notice will be possible in allcircumstances. Before we restrict, terminate or suspend your access to the Services, we will take into account allrelevant facts and circumstances apparent from the information available to us, depending onthe underlying reason for taking that action. For example, if you violate our CommunityGuidelines we consider the severity, frequency, and impact of the violations as well as theintention behind the violation. This will inform our decision whether to restrict, terminate orsuspend your access to the Services and, in the event of suspension, how long we suspend youraccess. You can find out more about how we assess and take action against misuse of ourServices on our Support Site. Internal Complaint Handling The following information on Snap’s Internal Complaint Handling is included in Snap’s Terms ofService. Where we restrict, terminate or suspend your access to the Services for violation of ourCommunity Guidelines, we will notify you and provide an opportunity for you to appeal asexplained in our Moderation, Enforcement and Appeals explainer. 337 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT We hope you’ll understand any decisions we make about content or user accounts, but if youhave any complaints or concerns, you can use the submission form available here or useavailable in-app options. If you use this process, your complaint must be submitted within sixmonths of the relevant decision. Upon receiving a complaint, we will: ● ensure the complaint is reviewed in a timely, non-discriminatory, diligent andnon-arbitrary manner; ● reverse our decision if we determine our initial assessment was incorrect; and ● inform you of our decision and of any possibilities for redress promptly. Recommender Systems The following information on Snap’s Recommender Systems is included in Snap’s Terms ofService. Our Services provide a personalized experience to make them more relevant and engaging foryou. We will recommend content, advertising and other information to you based on what weknow and infer about your and others' interests from use of our Services. It is necessary for us tohandle your personal information for this purpose, as we explain in our Privacy Policy.Personalization is also a condition of our contract with you for us to be able to do so, unless youopt to receive less personalization in the Services. You can find more information onpersonalized recommendations on our Support Site. Community Guidelines In our Community Guidelines, which are explicitly incorporated into our Terms of Service, weprovide further guidance on the categories of illegal content, and content that Snap deems inviolation of its Terms. The Community Guidelines are easily accessible via Search Engine and inSnap’s Transparency Center and are machine readable and easily understandable. 338 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Our Community Guidelines are broken up into the following sections: Sexual Content,Harassment and Bullying, Threats, Violence \& Harm, Harmful False or Deceptive Information,Illegal or Regulated Activities, and Hateful Content, Terrorism, and Violent Extremism. These categories have been fine tuned over many years of content moderation on Snapchat, andencompass the illegal content that we have encountered on Snapchat over the years. For ease ofreference we have incorporated a more detailed breakdown of each category below. Sexual Content ● We prohibit any activity that involves sexual exploitation or abuse of a minor,including sharing child sexual exploitation or abuse imagery, grooming for sexualpurposes, or sexual extortion (sextortion), or the sexualization of children. ● We prohibit any communication or behaviour that attempts to persuade, trick orcoerce a minor with the intent of sexual abuse or exploitation, or which leveragesfear or shame to keep a minor silent. ● We prohibit all other forms of sexual exploitation, including sex trafficking, sextortionand deceptive sexual practices, including efforts to coerce or entice users to providenudes. ● We prohibit producing, sharing or threatening to share non-consensual intimateimagery (NCII) – including sexual photos or videos taken or shared withoutpermission, as well as “revenge porn” or behaviour that threatens to share, exploitor expose individuals’ intimate images or videos without their consent. 339 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ● We prohibit all forms of sexual harassment. This may include making unwantedadvances, sharing graphic and unsolicited content, or sending obscene requests orsexual invitations to other users. ● We prohibit promoting, distributing, or sharing pornographic content, includingphotos, videos or even highly realistic animation, drawings or other renderings ofexplicit sex acts, or nudity where the primary intention is sexual arousal. ● We prohibit offers of sexual services, including both offline services (such as, forexample, erotic massage) and online experiences (such as, for example, offeringsexual chat or video services). Additional guidance on sexual conduct and content that violates our Community Guidelines isavailable here. These Terms make clear to Snapchatters the extent to which sexual content is prohibited. Thisreduces the likelihood of several risks falling with categories identified by the DSA, including inparticular: (i) the dissemination of Child Sexual Abuse Material and Adult Sexual Content inCategory 1, (ii) the Right to Human Dignity and Children’s Rights in Category 2 and (iii) NegativeEffects on Public Health, Minors, and Gender-Based Violence in Category 4. Harassment and Bullying ● We prohibit bullying or harassment of any kind. This extends to all forms of sexualharassment, including sending unwanted sexually explicit, suggestive, or nudeimages to other users. If someone blocks you, you may not contact them fromanother Snapchat account. ● Sharing images of a person in a private space — like a bathroom, bedroom, lockerroom, or medical facility — without their knowledge and consent is prohibited, as issharing another person’s private information without their knowledge and consentor for the purpose of harassment (i.e., “doxxing”). ● If someone is depicted in your Snap and asks you to remove it, please do! Respectthe privacy rights of others. ● Please also do not harass another Snapchatter by abusing our reportingmechanisms, such as intentionally reporting content that is permissible. ● Additional guidance on how Harassment and Bullying violate our CommunityGuidelines is available here. These Terms make clear to Snapchatters that the extent to which harassment and bullying isprohibited. This reduces the likelihood of several risks falling with categories identified bythe DSA, including in particular: (i) the Right to Human Dignity, Private Life and DataProtection, and Children’s Rights, in Category 2 and (ii) Negative Effects on Public Health,Minors, and Gender-Based Violence, as well as serious negative consequences to aperson’s Physical and Mental Well-Being in Category 4. 340 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Threats, Violence and Harm ● Encouraging or engaging in violent or dangerous behavior is prohibited. Neverintimidate or threaten to harm a person, a group of people, or someone’s property. ● Snaps of gratuitous or graphic violence, including animal abuse, are not allowed. ● We don’t allow the glorification of self-harm, including the promotion of self-injury,suicide, or eating disorders. ● Additional guidance on threats, violence, and harm that violate our CommunityGuidelines is available here. These Terms make clear to Snapchatters the extent to which threats and violence areprohibited. This reduces the likelihood of several risks falling with categories identified by theDSA, including in particular: (i) the Right to Human Dignity and Property, and Child Rights, inCategory 2, (ii) Negative Effects on Civic Discourse and Public Security in Category 3 and (iii)Negative Effects on Public Health, Minors, and Gender-Based Violence, as well as seriousnegative consequences to a person’s Physical and Mental Well-Being in Category 4. Harmful, False, or Deceptive Information ● We prohibit spreading false information that causes harm or is malicious, such asdenying the existence of tragic events, unsubstantiated medical claims, underminingthe integrity of civic processes, or manipulating content for false or misleadingpurposes (whether through generative AI or through deceptive editing). ● We prohibit pretending to be someone (or something) that you’re not, or attemptingto deceive people about who you are. This includes impersonating your friends,celebrities, public figures, brands, or other people or organizations for harmful,non-satirical purposes. ● We prohibit spam, including pay-for-follower promotions or other follower-growthschemes, the promotion of spam applications, or the promotion of multilevelmarketing or pyramid schemes. ● We prohibit fraud and other deceptive practices, including the promotion offraudulent goods or services or get-rich-quick schemes, or imitating Snapchat orSnap Inc. ● Additional guidance on harmful false or deceptive content that violates ourCommunity Guidelines is available here. These Terms make clear the extent to which harmful false or deceptive information isprohibited. This reduces the likelihood of several risks falling with categories identified by theDSA, including in particular: (i) the dissemination of Harmful False Information, Fraud and Spamin Category 1, (ii) the Right to Human Dignity, Private Life and Data Protection, and Children’sRights in Category 2, (iii) Negative Effects on Democratic and Electoral Processes, CivicDiscourse and Public Security in Category 3 and (iv) Negative Effects on Public Health, Minors, 341 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT and Gender-Based Violence, as well as serious negative consequences to a person’s Physicaland Mental Well-Being in Category 4. Illegal or Regulated Activities ● Don’t use Snapchat to send or post content that’s illegal in your jurisdiction, or forany illegal activity. This includes promoting, facilitating, or participating in criminalactivity, such as buying, selling, exchanging, or facilitating sales of illegal orregulated drugs, contraband (such as child sexual exploitation or abuse imagery),weapons, or counterfeit goods or documents. It also includes promoting orfacilitating any form of exploitation, including sex trafficking, labor trafficking, orother human trafficking. ● We prohibit the illegal promotion of regulated goods or industries, includingunauthorized promotion of gambling, tobacco or vape products, and alcohol. ● Additional guidance on prohibited illegal or regulated activities that violate ourCommunity Guidelines is available here. These Terms make clear the extent to which illegal or regulated activities are prohibited. Thisreduces the likelihood of several risks falling with categories identified by the DSA, including inparticular: (i) the dissemination of illegal content, including child sexual abuse material andother types of misuse of Snapchat for criminal offences, and the conduct of illegal activities,such as the sale of products or services prohibited by European Union or Member State law,including dangerous or counterfeit products, or illegally-traded animals in Category 1, (ii) theRight to Property and Children’s Rights in Category 2, (iii) Negative Effects on Public Security inCategory 3 and (iv) Negative Effects on Public Health and Minors, as well as serious negativeconsequences to a person’s Physical and Mental Well-Being in Category 4. Hateful Content, Terrorism, or Violent Extremism ● Terrorist organizations, violent extremists, and hate groups are prohibited from usingour platform. We have no tolerance for content that advocates or advancesterrorism or violent extremism. ● Hate Speech or content that demeans, defames, or promotes discrimination orviolence on the basis of race, color, caste, ethnicity, national origin, religion, sexualorientation, gender, gender identity, disability, or veteran status, immigration status,socio-economic status, age, weight, or pregnancy status is prohibited. ● Additional guidance on hateful content, terrorism, and violent extremism that violatesour Community Guidelines is available here. These Terms make clear the extent to which Hate Speech and terrorism are prohibited. Thisreduces the likelihood of several risks falling with categories identified by the DSA, including inparticular: (i) the dissemination of illegal Hate Speech and other types of misuse of Snapchatfor criminal offenses and the conduct of illegal activities in Category 1, (ii) the Right to HumanDignity, Non-Discrimination and Children’s Rights in Category 2, (iii) Negative Effects on Public 342 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Security in Category 3 and (iv) Negative Effects on Minors, as well as serious negativeconsequences to a person’s Physical and Mental Well-Being in Category 4. We understand that each of the above categories can be nuanced and open to interpretation,that is why we have included explainers for each category. Privacy Policy Snap also publishes a Privacy Policy, which is presented when users register an account and it iseasily accessible via Search Engine as well as, online, within our Safety and Privacy Hub and inthe footer of Snap websites. It is also available on the App and in Apple/Android stores. It ismachine readable and easily understandable. Our Privacy Policy provides a detailed description of our privacy practices, including anexplanation of how Snap collects and uses personal data and how individuals can control theprocessing of their information. We recognize that policies and terms can be overwhelmingdocuments. That is why our long standing approach has been to provide additional, bite-sizedinformation on our general practices (Privacy Center), our philosophy to privacy (PrivacyPrinciples), what we do with user data (How we use your information), advertising (Snap and Ads),and specific products (Privacy by Product). In the introduction to our Privacy Policy, we state thefollowing: “We’ve done our best to write this Privacy Policy in a way that’s easy to understand for allour users and free of difficult language and legal phrases. If you want to reviewsomething later on, you can always take a look at our Privacy Center. We designed it togive you easy-to-digest summaries of our privacy practices. For example, our Privacy byProduct page gives product-specific information and links to support pages with tips andtricks. Still have questions? Just reach out to us.” 343 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Privacy by Product gives users concise and easily understandable information about ourproducts. For example, this webpage provides an overview of our approach to Snaps \& Chats, aswell as hyperlinks to more detailed information on specific aspects. Similarly, there’s a section onSpotlight, Lenses, My AI, Stories, and many more products. In addition to these documents, wealso show in-app notices that provide more information about our products and services. Product Specific Terms In addition to the Terms and Conditions described in detail above, we also have specific,publicly-available terms and policies that govern the use of additional aspects of Snapchat’sfeatures: Spotlight Snapchat users who choose to contribute content to Spotlight are required to adhere to the Creator Monetization Policy. Snap also provides users who submit content to Spotlight with clear Content Guidelines for Recommendation Eligibility, describing the policy, technical, and legalrequirements for submissions to Spotlight, as well as reminding users of the Terms (including our Community Guidelines). Discover We have specific publishing agreements with our premium partners that post content onDiscover, such as media organizations and Snap Stars, that require them to abide by our Terms(including our Community Guidelines). Lenses Snapchat users who choose to develop and submit Lenses for publication on Snapchat via LensStudio must agree to the Lens Studio Terms. Lenses must comply with our Lens StudioSubmission Guidelines, which also remind users of the Terms (including our CommunityGuidelines). Advertising Snap also publishes Advertising Policies, which outline the terms and conditions for use of Snapadvertising services. These are easily accessible via Search Engine, machine readable, and easilyunderstandable. 344 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Snapchat users who choose to advertise to other users on Snapchat must agree to our SnapAdvertising Policies, including an obligation for advertisements to comply with applicable lawsand rules in the European Union and each Member State where the update advertisements willrun. 5.2.4 Accessing Terms and Conditions Accessibility Safety and Privacy Hub Snap’s Privacy and Safety Hub was launched last year and combines our Privacy Center, SafetyCenter, and Transparency Center all under one umbrella site. This is where Snap publishes formaltransparency reports. The rationale behind the integration of these three centers is that we believe there is a naturaloverlap between these areas, and that all the information provided in those domains contributeto providing awareness and building trust with our community and other stakeholders, such asparents, teachers, journalists, trusted flaggers, law enforcement, regulators, and NGOs. The top navigation provides Policy, Privacy, Safety, and Transparency resources, as well as ourlatest News in those areas. In this section, we highlight a number of areas for illustrationpurposes, and refer to the website for further information. 345 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Policy Center Our Policy Center is a key resource for understanding the rules and policies that explain the rulesand policies applicable across Snapchat. It includes links to our Community Guidelines, ContentGuidelines for Recommendation Eligibility, Advertising Policies, Commercial Content Policy andCreator Monetization Policy. Privacy Center Our Privacy Policy provides a detailed description of our privacy practices, but we recognize thatpolicies and terms can be overwhelming documents. That is why our long standing approach hasbeen to provide additional, bite-sized information on our general practices (Privacy Center), ourphilosophy to privacy (Privacy Principles), what we do with user data (various pages, including thePrivacy Policy), advertising (Snap and Ads), and specific products (Privacy by Product). Safety Center From the Privacy Center, users can easily navigate to the Safety Center, which provides anoverview of our Safety resources, including tips on how to report a safety concern, informationabout our approach to safety partnerships, our Trusted Flagger Program, Safety Advisory Board, Digital Well-Being Index and more. Again, the goal here is to provide easy to navigate andprocess information. Transparency Center Our Transparency Center provides additional transparency resources to our users and to thepublic at large, including our Transparency Reports and EU-specific information required underthe DSA. On our EU transparency page, we publish EU-specific information required under the DSA,including the number of Average Monthly Active Recipients of our Snapchat app in the EU, andinformation about our legal representative in the EU, how EU law enforcement agencies cansubmit requests to snapchat, and the regulatory authorities that regulate us under the DSA. News Page Snap also frequently publishes related information on the Hub’s News webpage. The purpose ofthese news articles is to inform the general public about recent developments on issues relevantto privacy, safety and transparency on Snapchat, and more. 5.2.5 Support Site Our fully-searchable and thematically-organised support site contains the following terms andconditions which, again, are also accessible via links within our Terms of Service: ● How We Rank Content on Spotlight ● How We Rank Content on Discover 346 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT all users to understand what activity is prohibited on Snapchat and the consequences, whichreduces the likelihood they will engage in illegal or violating activity. In addition, our Privacy and Safety Hub and Support pages as explained in the Transparency partof our Report have also been designed to be user friendly and easily understandable. Forexample, we created our Privacy and Safety Hub, with pages such as our Privacy by Productpage, to give Snapchatters a high-level summary of our privacy and safety practices across eachof our products and features. We also created a video to visualize our privacy practices, and useicons and other best practices as recommended by privacy and safety experts and therecognised Age Appropriate Design Code. This helps all users to understand how Snapchatworks, what options they may have, how we moderate and enforce our terms and how they canget support. This reduces both the likelihood of illegal or violating activity and the severity ofharm in the event they are exposed to illegal or violating activity despite our limitations. Teensreading our Privacy Center can understand how their data is being processed by Snap and findmore information about relevant privacy settings which reduces the likelihood and severity ofnegative effects on Teens’ data protection rights. 5.2.8 Conclusion Snap provides terms and conditions for the recipients of its services, which incorporate thecontent and meet the language requirements of the DSA. As explained in Section 4, we have concluded that Snap’s terms and conditions, incombination with the other mitigations explained in this Section 5, are reasonable,proportionate and effective mitigation measures for the risks presented by Snapchat’sin-scope services. 5.3 Transparency Snap is focussed on providing users with the right level of information, at the right time. Weunderstand that our community does not always have time to read multi page documents. This iswhy we strive to provide users with bite-sized information that is easy to access and understand,while also giving them an opportunity to review more detailed information where appropriate. Information provided to users can be divided into three categories:1. Information we provide on our website;2. Information provided in app stores; and3. Information we provide in our application. 5.3.1 Information we provide on our website 348 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT At Snap we have a number of avenues to provide information to users. The two primary sourcesof information outside of our application are our Privacy, Safety, and Policy Hub and our SupportCenter. Privacy, Safety, and Policy Hub Snap’s Privacy, Safety and Policy Hub was launched in 2022 and combined our Privacy Center,Safety Center and Transparency Center all under one umbrella, (with a dedicated Policy Hubadded in 2024). The rationale behind this change is that we believe there is a natural overlapbetween these areas, and that all the information provided in those domains contribute toproviding awareness and building trust with our community and other stakeholders, such asparents, teachers, journalists, trusted flaggers, law enforcement, regulators, and NGOs. 349 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT The top navigation provides Policy, Privacy, Safety, and Transparency resources, as well as ourlatest News in those areas. In this section, we highlight a number of areas for illustrationpurposes, and refer to the website for further information. Policy Center We want Snapchat to be a safe and positive experience for everyone who uses our platform orproducts. For this reason, we created rules and policies that explain the rights and responsibilitiesof all members of our community. Our Policy Center provides a central place for our CommunityGuidelines, Advertising Policies, Content Guidelines, and Commercial Content Policy. We havealso reformatted our policies in a way that is easier and more intuitive for users to navigate,replacing our previously long, text-heavy pages with shorter, more digestible segments with clearheadings and organization by subject matter. Privacy Center Our Privacy Policy provides a detailed description of our privacy practices, but we recognize thatpolicies and terms can be overwhelming documents. That is why our long standing approach hasbeen to provide additional, bite-sized information on our general practices (Privacy Center), ourphilosophy to privacy (Privacy Principles), what we do with user data (How we use yourinformation), advertising (Snap and Ads), and specific products (Privacy by Product). In theintroduction to our Privacy Center we state the following: “Privacy policies tend to be pretty long – and pretty confusing. That’s why we did our bestto make our Privacy Policy brief, clear, and easy-to-read! 350 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT You should read our entire Privacy Policy, but when you only have a few minutes or wantto remember something later on, you can always take a look at this summary – so youcan learn or recall some of the basics in just a few minutes.” Privacy by Product gives users concise and easily understandable information about ourproducts. For example, this webpage provides an overview of our approach to Snaps \& Chats, aswell as hyperlinks to more detailed information on specific aspects. Similarly, there’s a section onSpotlight, Lenses, My AI, Stories, and many more products. Safety Center Our Safety Center provides an overview of our Safety resources, including tips on how to reportcontent, the acknowledgment that safety is a shared responsibility, as well information on ourTrusted Flagger Program, Safety Advisory Board, Digital Well-Being Index and more. Again, thegoal here is to provide information in a way that is easy to navigate and process. Since our 2023Report, we have included direct links to our existing pages for the Safety Advisory Board, DigitalWell-Being Index, our Safety Policies, Information for Parents and Information for LawEnforcement, as well as a new support page on Financial Sextortion, in the navigation bar of theSafety Center. We have dedicated a page on our Safety Center to reporting. Our community, trusted flaggers,and other stakeholders play a vital role in the safety of our platform. A primary way they do this is 351 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT by reporting content and accounts to us when they have a safety concern. That’s why we thinkit’s crucial to raise as much awareness as possible about reporting. The dedicated pagesummarizes the various ways users can report content and accounts, and provides additionalresources on how to report (e.g. a hyperlink to our Safety Snapshot episode on reporting). Thepage also links to our Reporting Quick Guide and contains a hyperlink to our web reporting form. Another important component of the Safety Center is our Safety Resources and Support page.The goal of this page is to provide users with additional resources, such as a hyperlink to MindUp, information about our Here For You tool, and country specific information. Since our2023 Report, we have also included additional resources including: ● a page dedicated to explaining Financial Sextortion; and ● a page dedicated to sexual risks and harms, in an effort to support those in distress. 352 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT MindUp is a non-profit organization that supports children ages 3 to 14 by providing them with thetools and knowledge to manage stress and thrive in school all while maintaining optimism,resilience, and compassion. This is to assist our Teens users by providing them with MindUpresources relevant to them. Our Here for You search tool, which is accessible within the Snapchat app, shows resources fromexpert localized partners when users search for certain topics related to mental health, anxiety,depression, stress, suicidal thoughts, grief and bullying. Our country-specific resources provide users with additional information about resources that areavailable to them in their country, such as children’s helplines, suicide prevention hotlines, andmore. See for example the below, for France: 353 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Parents We have a dedicated Family Center, our in-app tool for parents and caregivers. To help developFamily Center, we worked with families to understand the needs of both parents and teens,knowing that everyone’s approach to parenting and privacy is different. We also consulted withexperts in online safety and wellbeing to incorporate their feedback and insights. Our goal was tocreate a set of tools designed to reflect the dynamics of real-world relationships and fostercollaboration and trust between parents and teens. In the coming weeks, we will add a newfeature that will allow parents to easily view new friends their teens have added. In September 2023, we launched a dedicated microsite: parents.snapchat.com to provide evenmore information for parents. We recognize that not all caregivers use Snapchat. Their lack offamiliarity may create questions, and may also make it difficult for them to have a conversationwith younger users. To address this concern, the dedicated microsite contains: an updatedSnapchat 101, a specific page on Safeguards for Teens, resources about Snapchat’s FamilyCenter, Snap Map Safety, and other resources. 354 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT The Snapchat 101 page incorporates our previous ‘Parent’s Guide to Snapchat’ but lays it out inan accessible manner (including a short video). The Safeguards for Teens page summarises the key protections for teens. Transparency Center Our Transparency Center provides additional transparency resources to our users and to thepublic at large, including our Community Guidelines (see Terms Section), Transparency Reportsand EU-specific information required under the DSA. On our EU Transparency Page, we publish EU-specific information required under the DSA,including the number of Average Monthly Active Recipients of our Snapchat app in the EU, andinformation about our legal representative in the EU, how EU law enforcement agencies cansubmit requests to snapchat, and the regulatory authorities that regulate us under the DSA. Since 2015, we have also been publishing Transparency Reports twice a year, to provide insightinto Snap’s safety efforts and the nature and volume of content reported on our platform, as wellas the manner in which we enforce our Community Guidelines and respond to law enforcementrequests, as well as how we respond to notices of copyright and trademark infringements. We arecommitted to continuing to make these reports more comprehensive and informative to the manystakeholders who care deeply about our content moderation and law enforcement practices, aswell as the well-being of our community. As part of our DSA compliance, Snap will be adding new 355 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT metrics and information to its Transparency Report. Copies of our most recent and previousTransparency reports can be found on our Transparency Report and Previous Reports webpages. News Page Snap also frequently publishes Privacy and Safety related information on the Hub’s News webpage. The purpose of these news articles is to inform the general public about recentdevelopments on issues relevant to privacy, safety and transparency on Snapchat. For example, arecent article introducing Snap’s Inaugural Council for Digital Well-Being, or an article informingthe public on Snap’s approach to keeping its community safe during the 2024 Paris Olympics. 356 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 5.3.2 Information provided in app stores Prior to downloading Snapchat, we provide users with information about the Snapchat app in theApple and Google Play Stores. This includes general information on the functionalities of the app,as well as information on our data collection practices, and links to our website, Privacy Policyand Terms. This way users are able to get a better understanding of the application ahead ofusing Snapchat. 357 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 5.3.3 Information we provide in our application Once users have downloaded Snapchat, they are invited to create an account. At Snap, ourphilosophy is to provide timely notifications and generate awareness at points in time where webelieve they will be most effective. We provide a high level overview of our onboarding processand highlight examples of our “just-in-time” in-app notifications in this section. Onboarding process Step 1. When users open Snapchat, they are invited to log in (if they have an existing account) or createa new account. The first set of notices users receive relates to notification settings, and the abilityto connect their device’s contacts to find friends. 358 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Both steps are optional. The reason we prompt users to turn on notifications is that Snap isprimarily a messaging service and notifications provide an essential utility when using the service.Snap is intended for real friends and family, and requires users to accept friend requests or bealready existing contacts before they can start communicating with each other. Typically, usersalready have their close friends and family stored in their device contact book, so the “Find YourFriends” prompt is intended to make it easier for users to send friend requests to other users andto communicate with one another. Step 2. The second step of the onboarding flow requests basic account information such as the user’sfirst name, last name (optional), birthday and username. 359 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT When asking for their birthday, we show users a neutral age screen, and if a user selects an ageunder 13, they are prevented from creating an account. We don’t notify the users the reason for afailure to create an account. We have drawn on guidance from the UN Convention on the Rights of the Child206 and UKAge-Appropriate Design Code207 to adopt a risk-based approach to age verification in our agegating process. We considered the risks of the platform as well as the rights of younger user’sright to privacy, freedom to access information and freedom of expression under the Conventionand balanced them against safety risks. We believe more invasive age gates come at a privacycost for all users, and also disproportionately impact marginalized groups who may not haveaccess to government IDs.208 We have supported the UK Online Safety Bill amendment to requireApp Stores to play a more active role in sharing age signals to all app stores. We believe this isthe better upstream solution to address any systemic risks associated with underage usersaccessing platforms. 208 See for example the report on age verification issued by the Australian eSafety Commissioner, url. 207 UK Information Commissioner’s Office, Introduction to the Children’s code, url. 206 UN OHCHR, Convention on the Rights of the Child, url. 360 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT If a user has inputted an age of 13 or older, they are prompted to provide a username. We checkusernames against our Abusive Language Detection (ALD) models. If users type in an abusiveusername (i.e., one that does not comport with our Terms), they are prevented from creating anaccount and are asked to enter a username that adheres to our Terms. Step 3. The third step of the onboarding process is focussed on password creation and providing aphone number and / or an email address. These are standard steps to improve account securityand provide Snap the ability to communicate with users. Step 4. Lastly, we offer users the ability to start finding friends on Snapchat, and the option to create aBitmoji. Snapchat shows Bitmojis instead of profile pictures. Bitmojis protect the identity of users,and prevent abuse from predators who may use profile pictures as signals to reach out to theirtarget victims. 361 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Just-in-time notifications Once a user has created an account, we create awareness at a feature-specific level, typicallyusing Just-in-Time notices or “JITs”. We conduct user research and sentiment studies, andfeedback we receive from users is that JITs or icons are more effective to inform users than longtext. Below we provide some examples of JITs that create feature-specific awareness. Snap Map Snapchat’s access to the users’ precise location, including for features like Snap Map, is off bydefault. Users choose who can see their location. Since our 2023 Report, we have simplified location sharing on Snap Map. Location sharing stillrequires a two step permission to enable location sharing:1. Users will choose location permissions in device settings (e.g. for iOS these are “Never”,“Ask Next Time or When I Share”, “While Using the App”, “Always”).2. Users must also select sharing with “My friends”, “My Friends, Except” or “Only theseFriends”. Users cannot share location with non-Friends. The selected Friends will see “live location" if the user chose “Always” in device settings or “lastactive” if the user chose “While Using the App” in device settings. Users can still decide to turn 362 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT on Ghost Mode at any time when they want to disable location sharing (either for a specific timeor until the user wishes to turn off Ghost Mode). : 363 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Spotlight 364 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Before a user submits a Snap to Spotlight they are presented with a JIT informing them thatSpotlight submissions are public. This is to create awareness that Spotlight is different from MyStory submissions, which can be shared with friends only, unless the user actively chooses toshare them with “Everyone”. Thematic awareness and notices Across Snapchat, we offer a number of resources to users to raise awareness on safety topicsand protect them. For example: 1. Here for you If a user types in “selfharm” or related terms in our Search functionality, we try toprominently show them relevant ‘Here For You’ resources among the search results. 365 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 2. Safety Search terms like “safety” will direct users to our relevant Here For You resources, such asinformation on our Family Center, and to our Safety Snapshots, our official channel forsafety and privacy tips and tricks. 3. Heads up If a user types in terms related to illicit drugs in our Search functionality, we try toprominently show them our ‘Heads Up’ resources among the search results. Heads up is 366 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT our in-app tool that surfaces educational content from experts to Snapchatters if they tryto search for drug-related content. Our expert partners include the Centers for DiseaseControl and Prevention (CDC), the Substance Abuse and Mental Health ServicesAdministration (SAMHSA), Community Anti-Drug Coalitions of America (CADCA),Shatterproof, Truth Initiative, and the SAFE Project. We also run campaigns on Snapchat to raise awareness about certain themes. For example, on Global Data Privacy Day 2024, we informed the general public about our new Privacy Policy,announced the updated parents guide to Snapchat, and launched a dedicated page on Privacythrough Security, and relaunched our interactive Lenses with tips on how to stay safe online. Similarly, on Safer Internet Day 2024, we raised awareness around parents’ options to participateand monitor their child’s online activities through Snapchat’s Family Center. We publish updateson efforts and campaigns to raise awareness around the dangers of fentanyl, and continue topartner with organizations like Song For Charlie to combat illicit drugs on Snapchat. 367 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 5.3.4 Languages As explained above, our Terms of Service have been translated into all official languages of theEuropean Union as explicitly required by the Digital Services Act. However, Snapchat itself is onlyavailable in certain official languages of the European Union, not all. As a result, our in-app andpublicly accessible information is also only available in certain official languages of the EuropeanUnion. we consider it reasonable and proportionate and effective to offer our mitigationmeasures in the same languages as Snapchat as we anticipate recipients only using Snapchat ifthey understand one of the available languages. 5.3.5 Conclusion Snap offers a wide range of in-app and publicly accessible information to raise awareness aroundprivacy, safety and security to its community and external stakeholders. Our approach is thatthese tools should be easily accessible, easy to use and understand, and provided in a timelymanner. we believe that the awareness measures we have in place providereasonable, proportionate and effective mitigations. As explained in Section 4, we have concluded that Snap’s awareness raising information, incombination with the other mitigations explained in this Section 5, is a reasonable,proportionate and effective mitigation measure for the risks presented by Snapchat’s in-scopeservices. 5.4 Content Moderation 5.4.1 Approach Across Snapchat, we’re committed to advancing safety while respecting the privacy and freedomof expression of our community. We take a balanced, risk-based approach to combating harms —combining transparent content moderation practices, consistent and equitable enforcement, andclear communication to hold ourselves accountable for applying our policies fairly. Safety and privacy is a priority across Snapchat, and we use a combination of in-app reporting,automation tools, and human review to combat harms on the platform. All content must adhere toour Terms, including our Community Guidelines and Terms of Service, and some content mustalso adhere to our Content Guidelines for Recommendation Eligibility. We strive to be transparentand consistent in our practices and enforcement, while striking the right balance between privacyand safety. 368 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Snapchat Design and Function As a reminder, we have also designed Snapchat with privacy and safety in mind, and this designis key in helping to prevent the spread of harmful and illegal content. Snapchat does not offer anunmoderated, permanent news feed where unvetted publishers or individuals have anopportunity to broadcast hate, misinformation, or violent content to a wide audience withalgorithmic amplification. We think about content on our platform in three categories:1. “Public Content” is made available to the public and potentially accessible to anyone onSnapchat and/or the Internet. This includes Public Stories, Map Stories, Lenses, PublicProfiles, advertisements and content recommended for broad distribution on Spotlightand the Discover section of the Stories tab.2. “Limited Broadcast Content” is content broadcast to a selected audience and includesPrivate Stories and Community Stories.3. “Private Content” is private messaging content sent to Friends. Private Content includesChat and Group Messaging.While only Public Content services are in-scope of this Report, we have also provided informationrelating to Limited Broadcast and Private Content services for reference. More information about our mitigations relating to Snapchat’s design and function can be foundin Section 5.1 (Snapchat Design and Function). Community Guidelines and Terms of Service When considering our Content Moderation approach, it is also important to bear in mind that allcontent everywhere on Snapchat must adhere to our Community Guidelines and Terms ofService. Then, in order to be eligible for algorithmic recommendation beyond the creator’sfriends or followers, content must meet the additional, higher standards described in our ContentGuidelines for Recommendation Eligibility. More information about our mitigations relating toTerms and user awareness can be found in the Terms Section and Transparency Section. Content Moderation Our content moderation processes assess each piece of content against the above Terms,policies and guidelines to determine if that content is compliant. We assess content reactively (upon receipt of a report) and proactively (when flagged by ourautomated detection tools) using a combination of automated review tools and/or human review. 369 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 372 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 374 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 375 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 376 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 377 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 5.4.3 Broadcast Content - Proactive Moderation We use a combination of automated tools and human review to proactively moderate publicbroadcast content across Snapchat, i.e., content recommended for broad distribution onSnapchat, such as content in Spotlight, Discover, Lenses and Advertisements and non-publicbroadcast content such as stories. Proactive moderation considers compliance with our ContentGuidelines for Recommendations Eligibility. 378 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 379 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 5.4.4 Product-Specific Moderation Snap products leverage varied processes to determine whether content is eligible for distributionwithin each unique product. Products deploy varying business rules, which result in automatedcontent moderation, based on the nature of the content presented to users on each product. 380 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 381 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 382 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 383 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 384 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 385 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 386 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 387 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 390 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 391 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 392 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 394 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 395 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 396 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 397 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 398 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 400 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 5.4.6 Conclusion Safety is a priority across Snapchat, and we use a combination of in-app reporting, automationtools, and human review to combat harms on the platform. All content must adhere to our Terms,including our Community Guidelines and Terms of Service, and some content must also adhere toour Content Guidelines for Recommendation Eligibility. We strive to be transparent and consistentin our practices and enforcement, while striking the right balance between privacy and safety. As explained in Section 4, we have concluded that Snap’s measures to moderate illegal orviolating content, in combination with the other mitigations explained in this Section 5, arereasonable, proportionate and effective mitigation measures for the risks presented bySnapchat’s in-scope services. 5.5 Enforcement 5.5.1 Introduction We strive to continuously update and improve our enforcement mechanisms to protectSnapchatters and our broader communities. As explained in the Terms Section of this Report,Snap has carefully developed its Terms with a view to mitigating the systemic risks it hasidentified for the EU (see Section 4). Integral to our risk mitigation efforts are Snap’s policies andprocesses to enforce these Terms. Below, we explain how we enforce our Terms in a transparent,consistent and equitable manner, balancing our commitment to safety with respect for the privacyinterests of our community. It is important to note that increases in reporting, enforcement and proactive law enforcementreferrals over time do not necessarily indicate that Snapchat has become less safe. On thecontrary, these upward trends correlate with a continued drop in Policy Violating Prevalence(PVP) on Snapchat overall (see our prevalence testing data in Section 6.4). In other words, as weget better at detecting and enforcing against more violations, the frequency of violations onSnapchat overall continues to decrease. We are committed to continuously improving the safety of our communities on Snapchat andbeyond. We use prevalence testing to identify and adapt to changing abuse trends on Snapchatso we can be better equipped to detect and address any gaps in enforcement. CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ● This strike system helps ensure that Snap applies its policies consistently, and in a way thatprovides warning and education to users who violate our Terms when appropriate. The primarygoal of our policies is to ensure that everyone can enjoy using Snapchat in ways that reflect ourvalues and mission; we have developed this enforcement framework to help support that goal atscale. Transparency Snap publishes within its Terms information regarding its policies and enforcement mechanismsrelated to misuse of the platform, including the following: ● Snap’s Community Guidelines, including the Severe Harms Explainer and otherassociated Harm Category Explainers linked to from the Community Guidelines. ● Snapchat Moderation, Enforcement, and Appeals Explainer, which explains how ourcontent moderation practices, enforcement, and appeals processes work. This includes ashort guide to our strike system. We do not share further details about strike thresholdspublicly because strike thresholds and related timeframes are subject to evaluation andoccasionally change as part of our review processes and we do not want to give users theopportunity to “game” Snap’s enforcement system. ● Content Guidelines for Recommendation Eligibility which goes above and beyond theCommunity Guidelines, and limit other content from eligibility for recommendation that isappropriate for 13+ and is not considered illegal or harmful, but may still be unsuitable orunwanted in certain circumstances. 403 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 5.5.3 Notification of Criminal Offenses (Art. 18) Proactive referrals to law enforcement and governmental agencies In addition, in instances where we become aware of potential childsexual exploitation content on our platform, our Trust \& Safety team reviews the relevantinformation and, if appropriate, reports the content and account to NCMEC, as required by U.S.law. NCMEC then reviews those reports and coordinates with both U.S. and EU law enforcementagencies, as appropriate. Law enforcement takedown and information requests (Articles 9 and 10) EU Law Enforcement (“LE”) may submit orders for takedown of content or accounts via email tolawenforcement@snapchat.com. Law enforcement orders to provide information (Article 10) Similar to the process for takedown requests, EU LE can submit specialized Article 10 requestsvia email to lawenforcement@snapchat.com. 404 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ● 5.5.4 Notice and Appeals System Notice to Reporter After a reporter reports a piece of content or an account in-app for possibly violating our Terms orotherwise causing harm, we confirm receipt of their report and assure them that we areinvestigating it. 405 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 406 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT We endeavor to resolve all reports as quickly as possible while ensuring that we do a thoroughreview and achieve the correct result. Some reports can be resolved much more quickly thanothers, which may be more nuanced and require escalation to and/or input from other teams. Account-Level Notice and Appeals 407 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 408 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 409 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 411 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 412 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 413 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 415 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 416 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 5.5.5 Effectiveness of Enforcement 418 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT We regularly meet with NGOs and other stakeholders to discuss our measures and generallyreceive positive feedback. For example, we meet with Refuge, the UK’s largest non-profitdomestic abuse organisation for women, on a monthly basis. They have praised us for ourresponsiveness when individual cases have been escalated to us and they have positivelysingled out Snap as a receptive partner which offers direct channels of communication andcooperation. Preventing, detecting, and eradicating illegal and other violating content on our platform is a toppriority for Snap, and we continually evolve our capabilities. We continue to analyse enforcedcontent and accounts to further develop our proactive measures to detect and root out badactors. Our top ten risks are now in the ‘low likelihood’ category and we have observed steadydeclines in prevalence each year. See Section 6.4 further details. 5.5.6 Protections against Misuse (Art. 23) Suspending the Processing of Notices and Complaints Snap’s Trust \& Safety team has procedures in place to suspend the processing of notices andcomplaints from individuals who frequently submit notices or complaints that are manifestlyunfounded, for a period of up to one year. In egregious situations, we reserve the right to disablea user’s account in relation to the above. These measures will continue to be reviewed anditerated. 5.5.7 Conclusion Increases in reporting, enforcement and proactive law enforcement referrals over time do notmean that Snapchat has become less safe. On the contrary, these upward trends correlate with acontinued drop in Policy Violating Prevalence (PVP) on Snapchat overall since our 2024 Report.In other words, as we get better at detecting and enforcing against an increased number ofviolations, the frequency of violations found on Snapchat continues to decrease overall. We are committed to continuously improving the safety of our communities on Snapchat andbeyond, and use prevalence testing to identify and adapt to changing abuse trends on Snapchat,so we are best equipped to detect and address any gaps in enforcement. As explained in Section 4, we have concluded that Snap’s measures to enforce its Terms, incombination with the other mitigations explained in this Section 5, are reasonable,proportionate and effective mitigation measures for the risks identified for Snapchat’sin-scope services. 419 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 5.6 Algorithmic Systems 5.6.1 Introduction Users are able to find new content on Snapchat primarily through our algorithmicpersonalization/recommendation service. While, in general, algorithmic content recommendationsystems, like the one Snapchat uses, present a number of risks, we’ve designed our systems tomitigate these risks. This includes the use of appropriate terms, robust automated and humanmoderation, sufficient transparency with our users about the use of these systems, the ability toturn off personalisation, and the other mitigations outlined above. This section describes specific mitigation measures that Snap has put in place with regards toSnapchat’s algorithmic systems for the in-scope services on Snapchat to address the risksidentified in its risk assessment pursuant to Article 34(1), DSA. In line with Article 34(1), our risk assessment is proportionate to the risks identified taking intoaccount their severity and probability, and the design of our recommender systems and otherrelevant algorithmic systems. While Snapchat uses several algorithmic systems across all ofSnapchat’s in-scope services: Spotlight, Discover, Map, Lenses, Public Profiles, Advertising, therisks identified in our risk assessment focused on the following algorithmic systems:1. Content Recommendation Systems in Spotlight and Discover2. Advertising Systems3. Content Moderation Systems The specific mitigations put in place for our Content Moderation Systems and AdvertisingSystems are covered in Sections 5.4 and 5.7 respectively. This Section 5.6 is therefore primarilyfocused on the specific mitigations put in place for our Content Recommendation Systems inSpotlight and Discover, Map and Lenses (which we refer to in this Section as the “contentrecommender systems). 5.6.2 Content Recommendation Systems Snap provides a free personalized content experience that is intended to entertain and delightusers in the same app they use to communicate with their friends and family. Users find newcontent on Discover and Spotlight primarily through our algorithmicpersonalization/recommendation service. Through our algorithm, users can also view location based content from the Snap community onMap. While Snap uses algorithms to rank what content to show users on Snap Map based oncontent location and ‘recency’, content shown on Snap Map is not personalized. Users can alsofind Lenses that are specific to their location but also more relevant and valuable as they arepersonalized to the users’ interests. 420 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Algorithmic content recommendation systems, like the one Snapchat uses, present a number ofrisks. For example, they may give rise to, amplify and/or result in the rapid and widedissemination of illegal content and/or other harms identified in Section 4, if not adapted andtested appropriately. We have designed our systems and processes to mitigate these risks. Thisincludes the use of appropriate descriptive terminology, robust automated and humanmoderation, sufficient transparency with our users about the functionality of these systems, theability to opt out of personalization, and the other mitigations as described in the testing andadaptation section of this document. 5.6.3 How do our Content Recommender Systems work? To help users discover content they will be interested in, Snap’s content recommender systemsseek to understand the types of content viewers are interested in and not interested in. 421 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 422 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Benefits Snap’s recommender systems allow users to more easily discover interesting, entertaining, andrelevant content. With over a million submissions a day of content, discovery methods like sortingby popularity, alphanumeric, timestamp, or curation are not practical. Our recommender systems help viewers discover new interests they otherwise would have neverfound, and help creators who otherwise would not have been able to find an audience, allowusers to learn, develop, play and have fun online. Users can explore different experiences, learnabout topics of interest, and see what is happening around the world. Recommender systems aredynamic and responsive in that they can respond to viewers feedback. We know users consider personalized recommender systems to provide significant benefitbecause: ● Viewers tell us (through their actions) that they prefer recommendations over otherapproaches and access to entertaining content is one of users’ most frequent requests;and ● When we have tested removing personalization on Snapchat, we see a significant fall inuser engagement (view time). We also note that one of the reasons that traditional media services (i.e. linear television,newspapers, and magazines) are perceived to be in decline is because they are less entertainingto a diverse audience than the personalized alternatives provided by online platforms, such as Snapchat’s in-scope services. 5.6.4 Adaptation of Snap Algorithmic Systems to Mitigate Systemic Risk Enabling user choice in content prioritization Snapchatters living in the European Union have the option to disable personalized public contentrecommendations. In Discover and Spotlight, users can disable personalized content by eithertapping on '...' then 'Why am I seeing this content?' which will take you to Settings or by goingdirectly to Settings and 'European Union Controls'. When users disable personalization, publiccontent will be recommended to them with basic data only, such as the language set on thephone, age and country. Users will still see content, but it will be more random and less relevantto their interests. Users can also modify their content prioritization preferences across theplatform by modifying notifications received by type or topic, toggling on or off LifestyleCategories, and adjusting ad preferences within Settings. 423 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Considering each risk and its mitigation(s) in more detail: Illegal or violating content As explained in this Terms Section of this Report, all content on Snap must comply with our Termswhich requires all public content on Snapchat to be suitable for users as young as 13, includingour Community Guidelines. Additionally, content personalized by our algorithmicrecommendation system must also comply with our more restrictive Content Guidelines forRecommendation Eligibility. As explained in the Moderation Section of this Report, we have adapted our recommendersystems and its processes to enforce our content policies with robust automated and humanmoderation, 428 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Our restrictive Terms and robust moderation help Snapchat mitigate the risk that illegal, false, orinappropriate content will be available to be promoted by our recommendation algorithms. As explained in the Enforcement Section of this Report, users may also easily reportinappropriate and illegal content. Each piece of content in Spotlight and Discover has a menuthat allows users to report content. All reported user-generated content in Spotlight, Discoverand Ads is reviewed by human moderators. If the content violates our policies and somehowmade it through our automated and human reviews, it is made ineligible for futurerecommendations by our algorithmic systems. The effectiveness of these measures is tested through prevalence testing and by reviewingprivacy and other consumer queries raised to our community support teams, our Data ProtectionOfficer and our DSA Compliance Team. 429 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Lack of user understanding Our recommender systems are complex and the process, the signals used in ranking and howsignificant each signal is to the recommender system can be challenging for users to understand. To help users and answer frequently asked questions, and as part of our DSA compliance, wehave:1. Adapted our content to include links to articles available explaining how we personalizecontent in Spotlight, Discover and Ads here. This includes a description of the mainparameters used for our recommender systems, as well as the weighting applied to eachsignal. 2. Users may also reach out to our Support team if they have concerns or questions abouthow our algorithms work. We test this is appropriate by reviewing privacy and otherconsumer queries raised to our community support teams and our Data Protection Officer. Intrusive personalized recommendations We believe content is more relevant and entertaining when it’s personalized to a user’s interests,and not to someone else’s. However, there is a risk that some users may experiencepersonalized recommendations based on their inferred interest to be intrusive. 430 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT In Discover and Spotlight users can disable personalized content by either tapping on ‘...’ then‘Why am I seeing this content?’ which will take the user to Settings or the user can navigatedirectly to Settings and ‘European Union Controls’. When the user disables personalization, theDiscover and Spotlight experiences will be less personalized, and rely on essentials to determinewhat content to show the user, such as the language the user has set on their phone, their age,and country. Users will still see content, but it will be more random and less relevant to the user’sinterests (as required under Article 38 DSA). If the user wishes to enable personalization again,users can do so either by tapping on the favorite icon ( ) in Discover and Spotlight and thentapping ‘Enable’ in the ‘Show More Personalized Content?’ screen or by going to Settings in‘European Union Controls’.Users have the option to disable personalised Lenses through Personalisation Controls inSettings. If they choose to disable personalised Lenses, Snap will no longer recommend Lensesbased on their profile. They will still see Lenses, based on basic data only such as their countryand age, and Lenses will be more random and less relevant to their interests. Discrimination Algorithms that process special categories of personal data (as defined in GDPR) on a large scaleare considered high risk and require explicit user content. We have adapted Snapchat’srecommender systems so they do not track or identify special categories of personal data,including for the purpose of recommending content and ads. Rapid and Widespread illegal or false content \& crisis exposure There is a risk of rapid and widespread illegal or false content on Spotlight, Discover and Map, aswell as exposure to crisis situations and unexpected events like riots. We combat this risk byprohibiting illegal or false content in our Terms of Service and Community Guidelines andallowing users to report violations. More importantly, Spotlight relies on a combination ofautomated and human moderation on all submitted content before any video receives broaddistribution. On Discover, Creators209 have their Stories distributed in Discover. Those that areapproved have their Stories and the ‘tile’ art moderated. We also monitor reporting and hide rateson both Discover and Spotlight. In Map, Snap applies human and/or auto-moderation to decidewhat content is eligible to appear on Snap Map. Filter bubbles Our recommender system algorithms are designed to serve users with content that they will findengaging based on factors that include which categories of content they have previouslywatched. There is a risk therefore that, without safeguards, the algorithm will tag users who viewcontent that may not be harmful on its own as being interested in that content and that repeatedand frequent exposure to that content could be harmful. For example, while one piece of content 209 Creators include users whose content is eligible for distribution in Discover, such as Snap Stars and users whoreach a certain number of followers. 431 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT related to dieting may not be harmful, if a user sees many or frequent videos about dieting, theuser may feel inappropriately pressured to diet or may get a skewed perspective on how peoplemanage their relationship with food. We address this risk in a few ways. Firstly, we take significant steps to prevent and removecontent that may become harmful when viewed frequently on Spotlight or Discover, including asexplained above and in the Terms, Moderation and Enforcement sections of this Report.Secondly, our content categories do not include harmful content categories and so in the unlikelyevent that a user does view harmful content, this will not be used by our recommender systemalgorithm to recommend similar content. Thirdly, in our Discover, Spotlight, Map and Lensescontent recommendation systems, we have diversification rules in place to ensure that aparticular category of content will only be capped or demoted within the recommender systemfor a given user. In other words, if a user is interested in makeup videos, we’ll try to diversify thecontent by only showing a few makeup videos across a given period. We evaluate our recommendations to users in terms of the number of categories of content weare introducing to them, while at the same time ensuring we do not overwhelm them with anyparticular type of content. This helps reduce the risk of filter bubbles, since users will be serveddiverse content even if our models show they have a strong interest in certain types of content. Erroneously excluding content There is a risk that our efforts to ensure appropriate content on Snapchat results in some contentthat is appropriate being mistakenly identified and incorrectly moderated. This may create forexample, a risk to users rights to freedom of expression. To combat this ‘over-moderation’, we evaluate and work to improve our automoderation in termsof precision and recall, and currently have high auto-approval precision for Discover, Spotlight,Map and Lenses. In addition, as explained in the Enforcement section of this Report, we haveadditional moderation transparency messages (statements of reason) and a more comprehensiveappeals flow for moderated creators and content as part of our efforts to comply with the DSA. Viewers could be watching our content but not enjoying content There is a risk that the recommendation systems and models we build end up optimizing only forshort-term metrics like engagement (i.e. time spent) in the Snapchat app, rather than in support ofSnap’s mission of “empowering people to express themselves, live in the moment, learn aboutthe world, and have fun together". Our long-term objective when recommending content to userstherefore goes beyond time spent and is focused on whether our users are enjoying themselvesand are entertained and satisfied with their experience. Snap evaluates the effectiveness at achieving this objective in multiple ways, in particularensuring that we evaluate our algorithmic performance using a wide range of factors and not 432 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT solely relying on. In addition, Spotlight has been designed not to distribute sensitive (i.e. shocking) content to13-17-year-old users’ Snapchat accounts, which includes non-glorifying discussion of self-harmand suicide content (such discussion is not prohibited on Snapchat but may still be sensitive). Forusers under 18, we will remove all content labeled as sensitive. For users over 18, we will limit itsdistribution To make sure users are enjoying themselves and are entertained and satisfied with theirexperience, we enable them to “Reset Suggested Content” in their settings. This allows them to“refresh” their public content feeds. When users enable Reset Suggested Content, mostindicators used for personalisation of your public content feeds will reset but not all. Users maystill see content or creators that they have followed and content tailored to their demographic,and past blocks and dislikes will still be taken into account. We evaluate our algorithms across the above dimensions because we believe they are thedrivers to the ultimate outcomes we are attempting to deliver for users: that they be (1) satisfiedwith our experience - which we survey regularly (i.e. quarterly) across all tabs in our app and (2)continue to use it (i.e. user retention). 433 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT We take into consideration the user’s age when showing Lenses to our community. This way wecan identify Lenses that are appropriate for users of a certain age and to the best of our ability incompliance with local laws. 5.6.8 Change Management From a high level, Change Management over algorithmic systems at Snap is governed by thepreviously described Privacy and Safety by Design Review process. Material updates toalgorithmic systems and material changes to model pipelines, input data, and third party userdata are documented and reviewed. 5.6.9 Monitoring and Quality Assurance Performance Monitoring Snap monitors deployed algorithmic systems for anomalies and issues and establishes alerts tonotify Engineering teams when potential issues arise. These alerts look for relevant spikes oranomalies in statistics. Quality Assurance Snap monitors algorithmic systems related to content moderation for quality and precision on acontinuous basis. Monitoring may include: ● User Reports ● User Hides ● Content removal and user appeals ● Policy Violative Prevalence (PVP) ● Content Rejection ● User Reports ● User Hides ● Content removal and user appeals ● Policy Violative Prevalence (PVP) ● Content Rejection Snap uses dashboards to visualize content moderation statistics and set alerts for spikes incontent moderation activity. Snap Engineers may also investigate spikes in user reported contentor automatically detected violative content to identify correlation between model deployment tofeed back into broader Engineering teams. 5.6.10 Conclusion Users find new content on Snapchat primarily through our algorithmicpersonalization/recommendation service. While algorithmic content recommendation systems,like the one Snapchat uses, present a number of risks, we’ve designed our systems to mitigate 434 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT these risks. This includes the use of appropriate terms, robust automated and human moderation,sufficient transparency with our users about the functionality of these systems, the ability to optout of personalization, and the other mitigations outlined above. As explained in Section 4, we have concluded that our adaptation and testing of Snapchat’salgorithmic systems described above, in combination with the other mitigations explained inthis Section 5, are reasonable, proportionate and effective mitigation measures for the risksidentified. 5.7 Advertising Systems 5.7.1 Introduction Snap relies on online advertising to support its business. Snap recognises that without mitigationsits advertising systems also have a significant risk of giving rise to the concerns referenced inArticle 34 of the Digital Services Act. Snapchat Ads Manager includes our digital ad products andtools created for advertisers who would like to easily create and manage ads that target relevantaudiences on Snapchat. We process user information about Snapchatters to serve them with adswithin Snapchat that we think they might be interested in. However, advertising systems ingeneral might give rise to, amplify and/or result in the rapid and wide dissemination of illegalcontent and/or other harms identified in Section 4, if not adapted and tested appropriately. 5.7.2 How do our Advertising Systems Work? An overview of Snap’s ads services can be found here and here. In essence, Snapchat collectsdata about our users as they register, log in and use Snapchat. As is described in our PrivacyPolicy, this data is comprised of: ● Information the user provides us ● Information we collect as the user interacts with Snapchat ● Information we collect from third parties Snapchat Ads Manager and its various tools allow advertisers to leverage this data for targetedadvertising. Advertisers can use our Audience Insights tools to see the estimated aggregateddemographics, including age, as well as locations, interests and device overviews of theirtargeted audience. User-level data is not directly available to advertisers through thesedashboards. Some of Snap’s advertising tools allow advertisers to benefit from Snap’s use of data about theircustomers such as customer personal data provided by our advertisers and data collected fromthird-party services along with our users’ personal data, to provide and improve ad targeting andmeasurement: 435 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ● Snap Custom List Audiences \- An advertiser and/or their agent can use this service toupload customer list data to Snap via Ads Manager. See the Custom List Audiences section of our Business Help Center. Customer list data provided by advertisers is used tocreate an ‘audience’ of Snapchatters matching the information in the customer list data.This allows advertisers to target ads to that audience, or similar audiences, on Snapchat.See the Custom Audiences Overview in our Business Help Center. ● Snap Pixel and Conversion API \- An advertiser and/or their agent can also use this serviceto help target their ads on Snapchat: ○ For Pixel, advertisers install a piece of JavaScript within their web pages whichsends data to Snap when those pages are accessed by website visitors. See the Install Snap Pixel section of our Business Help Center. ○ For Conversion API, advertisers install Snap API code on their servers thatfacilitates passing web, app and offline events directly to Snap viaServer-to-Server integration. See the Conversions API section of our BusinessHelp Center. ● Advanced and Estimated Conversion are examples of the additional services that we offerto advertisers to target and measure the performance of their advertising using advancedprivacy enhancing techniques. Snap acts as a data processor of data relating to EU data subjects received from advertisers viathe Custom List Audiences, Pixel and Conversion API services. It processes the information inaccordance with advertiser instructions subject to its data processing agreement (which followsrequirements set out in Article 28 of the General Data Protection Regulation (GDPR)). Our ad ranking algorithm determines which ads are displayed to a Snapchatter who is in theselected audience for those ads. The ad ranking algorithm uses various signals, including prior adinteractions and social signals, to determine which ads that user is more likely to interact with andthen combines this with the results of advertiser ad action for that Snapchatter, to select an ad todisplay. Snap analyzes prior ad interactions to target advertisements. For example, we maydetermine that a user is likely to swipe up on certain types of ads or download certain types ofgames when they see an ad on Snapchat. We may then use this information to show that usersimilar ads. This is explained on our Snap and Ads Privacy and Transparency page. Snapchatter interactions with the ad (i.e. impression data) is then logged to (a) attributeimpressions to conversion events (such as a purchase on an advertiser website or download ofan advertiser app) to demonstrate the performance of the ad and (b) to further train the adranking algorithm. 436 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 5.7.3 Benefits Snapchat is used by millions of people in the European Union. They use Snapchat because itfosters fast and authentic communication with those who matter most to them. It is why ourcommunity continues to grow. We consider it is in the best interest of all our users, including 13-17s, for them to have access tothe best, most entertaining version of Snapchat possible, allowing them to exercise their digitalrights (such as access to information, association with others, have a voice and to play and havefun) regardless of their financial background and ability to pay. We receive feedback everydayfrom our users; calling for new features, functionality and improvements. We are only able to dothis by raising revenue from other sources. In common with many others in the industry, this hasmeant turning to advertising. Our ability to raise revenue by selling targeted advertising opportunities to advertisers meansthat: ● Snapchat is maintained and improved for the benefit of Snap and all recipients regardlessof their ability to pay. If Snapchat was only available for a fee, it would only be accessibleto those who could afford to pay the fee, restricting access to Snapchat and raising risksto fundamental EU rights to information and to access to services, particularly for Teens. ● Snapchatters benefit from being able to exercise digital rights and association with othersonline through Snapchat regardless of their financial background. This includesdeveloping their voice, having fun and access to entertainment and play. Balanced use oftheir personal data also benefits Snapchatters by avoiding seeing advertisements that arenot relevant to them (which is one complaint we have received in the past). AlthoughSnapchatters are given options to manually hide advertisements, through the use ofpersonal data, Snapchatters benefit from targeted advertising by seeing more relevant,age and interest appropriate adverts.210 The greater the revenue Snap is able to generatethe more resources Snap can dedicate to supporting access to the service and teens’development. ● Advertisers benefit from being able to promote their brand and products to a Snapchatteraudience most likely to be interested in them. This allows advertisers to focus theiradvertising and avoid spending on the display of advertisements to audiences that arenot likely to be interested. Snapchat Ads Manager also allows advertisers to bettermeasure the success of their digital marketing campaigns so their quality can becontinuously improved. Advertisers are also conscious about safety on Snapchat. Withthis in mind, in March 2024, we announced a partnership with a leading global mediameasurement and optimization platform,211 to: 211 https://forbusiness.snapchat.com/blog/snap-partners-with-integral-ad-science-brand-safety 210 N. Fourberg e.a., on ‘Online advertising: the impact of targeted advertising on advertisers, market access andconsumer choice’, 2021, url. 437 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 439 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT processes. Without transparency, alladverts have a higher riskof violating our terms or thelaw. We have adapted our systems toinclude an accessible, explorable adslibrary. We conduct pre-launch testing. We’re considering each risk and its mitigation(s) in more detail below: Invasion of Privacy – Reasonable and Proportionate Targeting We recognise that, as a platform, we have a responsibility to raise revenue in an appropriatemanner, and we take this responsibility very seriously. We want to ensure advertisers are nottargeting specific individuals on our platform and that users do not feel like their privacy is beingcompromised by our advertising. We also want to prevent advertisers from manipulating smallaudiences with microtargeted campaigns, particularly for political ads. ● Most of the ads on Snapchat, including all political ads, require a specific minimumaudience to be targeted.This prevents adverts from being micro targeted. ● Snap generally has a short retention period for user content. Unlike some of our peers,we do not store content for excessive periods solely for monetisation purposes. ● Advertisers can only use our data for ads targeting indirectly via the targeting toolsavailable on Snapchat. Amongst other things, this allows advertisers to target audiencesbased on a limited number of high level interest-based lifestylecategories (SLCs) audiences (none of which are available for targeting 13-17 year olds inEU, UK, Norway and Switzerland), which we have inferred a Snapchatter may beinterested in. They are based on high level, non-sensitive categories inferences, such asBusiness News Watchers, Sports Fans, and Fashion \& Style Gurus, that users can see andcontrol in the app, as detailed in this support page. The interest categories areintentionally short-lived (13 months), sufficient to allow a year-on-year comparison. Allusers can manage their advertising interest categories in settings and view them via ourDownload My Data tool (DMD). None of these SLCs are aimed at 13-17s specifically and theuser-level targeting data is not directly available to advertisers. 440 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ● We feel confident that our approach to advertising is reasonable and proportionate, as we have alow incidence of issues in relation to age targeting. Our approach to targeting minimums is basedon mathematical analysis by our privacy engineering teams. Special category data – No sensitive data use Special categories of data concern information revealing racial or ethnic origin, political opinions,religious or philosophical beliefs, or trade union membership, and the processing of genetic data,biometric data for the purpose of uniquely identifying a natural person, data concerning health ordata concerning a natural person’s sex life or sexual orientation. This information may have agreater risk of causing harm if used to target ads. A famous example of this concern relates tosupermarket Target, which profiled purchase information to determine if a woman was pregnant,and revealed the pregnancy to a teenage girl’s father by mailing vouchers for babyaccessories.214 Our targeting parameters such as Lifestyle Categories do not include special / sensitivecategories. In addition we require in our Terms relating to advertising that advertisers do not sendus this data from their sites. We do not allow advertisers to target audiences based on sensitivecategories. When we discover advertisers sending us this data we remove it. Our legal team has reviewed and confirmed our Lifestyle Categories do not include special /sensitive categories. Any changes must be reviewed by our legal team as part of the mandatoryproduct review which forms part of our privacy and safety by design processes. Discrimination – Special Targeting Models Certain advertisers are in regulated sectors where there are rules to prevent discrimination, suchas the housing, credit or employment sectors (particularly in the United States) and our teenageusers. In order to ensure we are not using discriminatory targeting models particularly when there issignificant legal impact to the consumers, we offer special targeting models that do not includegender or age, which we require for advertisers who are advertising in the housing, credit oremployment (HCE) spaces, so that discriminatory factors will not go into who sees these ads. Wedo not allow advertisers to build audiences for their ads based on their own data about ourteenage users regardless of those user’s own ad settings (i.e. activity data from the advertisersown online properties and the advertiser’s own customer lists). 214 Drive Research: How Target Used Data Analytics to Predict Pregnancies (url). 441 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT We use pre-launch testing and mandatory legal and privacy engineering review of any significantchanges to these models. Harmful or illegal content – Advertising policies Snap has Advertising Policies in place that direct the types of ads and targeting that areacceptable on Snap. Ads must comply with applicable laws and regulations in each geographicarea where they will run. Ads are prohibited from collecting sensitive categories of data. Thispolicy also helps ensure advertisements submitted are in line with Snap's Community Guidelines. As explained in Section 4 above, our advertisers could use our advertising systems todisseminate information that is illegal or could otherwise harm users, impact their fundamental EUrights or negatively impact public security or health. As explained in the Terms Section of this Report, we ensure advertisers are clear about theirobligations, we have robust Advertising Policies to prevent inappropriate and illegal advertisingon our platform. The systems used by advertisers to create and submit advertising (such as ourSnap Ads Manager), have been adapted to require agreement to these Terms and provide easyaccess to guidance on what is required. We test advertisers’ compliance with these Terms using our Advertising Review process beforeadvertising can be published. See below for more information. Policy-violating or illegal content – Advertising Review Notwithstanding that advertisers agree to our Terms, they may still deliberately or mistakenlyseek to publish advertisements that violate our advertising policies or the law. As explained in the Moderation Section of this Report, in particular the part relating to advertisingmoderation, we use a combination of automated and human review to prevent ads that violateour policies or the law from appearing on Snapchat. We reject hundreds of thousands of advertsglobally each month. We have a global team that supports ad moderation across 15+ languagesand is composed of both full time employees (FTEs) and contractors. Ad Review team membersare responsible for reviewing ad submissions to ensure ads abide by Snap’s creative policies andtechnical requirements. Ad Review team members use Snap’s Advertising Policies to assesscompliance. Ads must comply with Snap’s Community Guidelines and Advertising Policies inorder to be approved. Grey area ads are discussed with Snap’s Legal and Policy teams.Depending on the seniority, members of the Ad Review team also collaborate with the Salesteam to create a consistent review experience for our Snapchat partners. Fraudulent advertising accounts for the majority of these rejections and our advertising reviewteams are particularly vigilant for this form of violating advertising. This also includes ensuringinappropriate ads are not targeted at Teens. Our review takes account of the targeted audiencei.e. if the ad is for alcohol and the selected demographic for the ad includes Teens, then it will be 442 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT rejected. We use inferred age, as well as declared age, to help ensure Teen users see ads thatare appropriate for their age. Inferred age is regularly checked to ensure it is up-to-date. We monitor ad reporting and enforcement data to ensure our review process is catching areasonable and proportionate level of violating adverts. We aim to ensure that all advertising review is maintained within a 24 hour SLA window fromwhen the advertisement is created by the advertiser. More information on Snap’s ad reviewprocess, including the timeliness of review, are located on Snapchat’s For Business website. Bypassing Moderation Controls – Advertising Reporting Although we have an advertising review process in place to prevent the publication ofadvertisements with information that violates the law or our policies, it is possible that some ofthese advertisements may be missed or incorrectly reviewed and be published. As explained in the Enforcement Section of this Report, our advertising systems have beenadapted with an easy mechanism for advertisements to be reported by Snapchatters from withinthe Snapchat app as being inappropriate along with the reason for the violation. Based on thenumber of reports, we will take down the ad or send it to human review for additionalmoderation. All ads that are reported are reviewed by our human moderation team. Upon reporting the ad,Snapchatters are able to select a reason and write in comments. Both the reporting reason andthe comment are provided in the moderation task, as well as the number of reports. We closelymonitor sentiments of the ads on our platform and when ads are taken down, we inform theadvertiser. We also monitor the aggregate number of reports for advertisements on a regularbasis. We monitor ad reporting and enforcement data. Unclear Commercial Intent – Ad Markers If users are not aware when content is an ad or sponsored or other commercial content, there is arisk that this may lead to confusion, deception and exploitation. We automatically place an “Ad” marker on all paid ads that run on Snapchat. Sponsored Lensessay “Sponsored”. Our commercial content policy requires all organic content posted byinfluencers to be marked appropriately. We now offer a “Paid Partnership” tag tool thatinfluencers and users may use when they post commercial content to help them comply with thispolicy and their legal obligations. Ad marker example Sponsored Lens example 443 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT See below for examples of the “Paid Partnership” tag tool that influencers and users may usewhen they post commercial content to help them comply with this policy and their legalobligations. Add Paid Partnership Paid Partnership label Paid Partnership Explainer 444 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Political ads – Transparency Safeguards Political advertising presents a higher risk of misinformation and Negative Effects on Democraticand Electoral Processes. Snap intends to discontinue political advertising in the European Unionto comply with the European Union’s Political Ads Regulation which comes into force in October2025\. Snap ensures that ads shown are in line with Snapchat’s Advertising Policies, whichcontain a subsection on political and advocacy advertising policies. Snap allows political,election-related, advocacy and issue ads, but sets additional requirements and places additionaltransparency safeguards in relation to publishing these types of ads: ● Political advertising must comply with all applicable laws and regulations, including allnational election laws, copyright law, defamation law; ● All political advertising must include a “paid for by” message in the ad that is followed bythe name of the paying person or entity. Snap may also require a “paid for by” disclosureon ad content that links to political content, ad content for political merchandise, or inother cases in Snap’s sole discretion; ● Like all ads on Snapchat, political ads must comply with Snap's Terms of Service,Community Guidelines, and our Advertising Policies. ● We encourage political advertisers to be positive. But we don't categorically ban “attack”ads; expressing disagreement with or campaigning against a candidate or party is 445 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT generally permissible if it meets our other guidelines. That said, political ads must notinclude attacks relating to a candidate's personal life. ● Snap will review political ads on a case-by-case basis. To get started, political advertisersare required to fill out our political advertiser form. Snap reserves the right to reject, in oursole discretion, or request modifications to ads that we believe violate the standardslisted above or that are otherwise inappropriate. Our discretion will never be exercisedwith the intent to favor or disfavor any candidate, political view, or political party. ● Snap may publicly display and otherwise disclose information relating to politicaladvertising, including ad content, targeting details, delivery, spend, and other campaigninformation. ● Snap has for some time provided transparency for political ads with its political ad library. As explained in the moderation section of this Report, higher risk adverts (including politicaladverts) are subject to human review. Personal Data Use for Targeting – User Choice Opting out of Personalized Advertisements If you live in the European Union, you have the option to disable personalized public contentrecommendations in Settings under 'European Union Controls.' Snapchat prevents personalizedcontent from being served to EU users who have opted out of personalized content. Our AdServer automatically prevents targeted ad types (such as pre-defined audiences and customaudiences) from being approved for ads reaching Snapchatters who have opted out. When youdisable personalization, public content will be recommended to you with basic data only, such asthe language you have set on your phone, your age, and your country. You will still see content,but it will be more random and less relevant to your interests. Do Not TrackSnapchat respects the device iOS App Tracking Transparency setting regardless of user AdPreference choices. Ad PreferencesFor EU users who have enabled personalized content, additional ad preferences are available tomodify in Snap. Users have choices about how Snap and its third-party ad partners use information about you foradvertising purposes both on and off Snapchat. Snapchat settings allow users to select whetherto receive Audience-Based ads, Activity-Based ads, Ads from Third-Party Ad Networks, or noneof these ad options. The settings on this page are automatically disabled if you are under 18 inthe EEA or UK. 446 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Snapchat infers your interests to better suggest content to you and personalize your experience.Lifestyle categories are used to target ads (excluding users under 18 in the EU and UK) andpersonalize other content. Snapchat displays these inferences to Snap users and allows them theability to toggle off specific Lifestyle Categories as desired. Snap’s Ad Policies including agerestrictions for Alcohol and Gambling ads will control the ads you see regardless of thesesettings. Transparency and Control Some users may have specific vulnerabilities or other reasons to be concerned about any use oftheir personal data for targeting ads. If users do not understand how advertising works, they maynot be able to confirm whether they should be concerned or exercise any choices they may have. As explained in the Transparency Section of the Report, our privacy center provides extensiveinformation regarding our processing of personal information. This includes a dedicated page explaining how we use personal data for advertising purposes. We offer choices for users tocontrol the data that’s used to determine the ads they see. In the European Union, we haveintroduced controls to turn off most personalized ads except those based on real time location,language, age and device type, and this is always turned off for teen users in the European Union 447 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT and UK, Norway and Switzerland. All users can restrict our use of third party data and beingincluded in advertiser supplied audience matches for ads targeting. We use pre-launch testing and our ad review process to help ensure these controls work asdesigned. Why am I seeing this ad?Snapchat also allows Snapchattes in the EU to click “Why am I seeing this ad” to see additionalinformation on the targeting parameters for the advertisement in question. Lack of visibility – Ads Gallery There is a higher risk that advertising will violate our terms or the law, in particular contentmisleading information, if the Snapchatter community and wider society does not have visibilityinto the history of ads over the past year that have run on Snapchat and some details about thetargeting and reach of those ads. Snap has an ads library (as required under Article 39 DSA) which provides increasedtransparency for ads - not just political - that are currently running, and historically have run in thepast year, directed to EU users on Snapchat. This ads library is available to anyone, can besearched / filtered / sorted based on pre-defined parameters (e.g. country targeted, advertisername, etc) and includes an API interface as well. This allows anyone to check who has paid for an 448 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT advert and, if different, on whose behalf is the advertisement being published. In the CommercialContent section of the Ads Gallery, we also include links to all live organic content that has beenmarked with the “Paid Partnership” tag. The Ads Gallery maintains advertisements for one yearafter the advertisement airs. Users can search the Ads Gallery by ad publisher and can filter results by multiple criteria,including by country, ad status, and publication time. Information included for each ad is shown in the screenshots below. When a user clicks on the“See Details” link they are taken to the Ad Details modal on the right. Per DSA guidelines, dataincludes: Main Ad Modal ● Ad Publisher - the natural or legal person who paid for the advertisement ● Brand Advertised - the natural or legal person on whose behalf the advertisement ispresented ● Ad Start Date and Ad End Date - the period during which the advertisement waspresented ● Ad Creative - the content of the advertisement, including the name of the product, serviceor brand and the subject matter of the advertisement ● Total Impressions - the total number of recipients the service reached Ad Details Modal ● Impressions by Member State - aggregate numbers for the recipients reached by country(if 0 recipients were reached, the ad will not appear). ● Targeted devices and demographics - whether the advertisement was intended to be 449 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT presented specifically to one or more particular groups of recipients, specifically, devicesand demographics; These options do not support exclusion targeting. Ads Gallery - Ads Data Per the Advertising Review section above, we use a combination of automated and humanreview to prevent ads that violate our policies or the law from appearing on Snapchat. Ads thatwere delivered and subsequently taken down are marked as Rejected in the Ads Gallery. 450 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT The Snap Ads Gallery is maintained by the Ads API and Ads Manager teams. The ads libraryunderwent pre-launch testing to ensure it met design specifications and will continue to developbased on further testing. Freedom of Expression The purpose of Snap Ads is to amplify advertisers’ commercial messages, and as a result thecontent is rarely political or rather expressing views. We have specific procedures for politicalads. As a result, the risk of a negative impact on freedom of expression from Snap’s othermitigations listed above is low. 5.7.5 Conclusion Targeted advertising on Snapchat is necessary to ensure we can continue to provide a freeservice to all users regardless of their ability to pay. We have taken extensive steps to ensure ourapproach to targeted advertising appropriately balances the interests of Snapchatters, Snap andadvertisers.. We have also put in significant measures to preventfraudulent and other advertising that may be harmful or against the law. We reject thousands ofthem each month to keep Snapchat’s community safe. As explained in Section 4, we have concluded that our adaptation of Snapchat’s advertisingsystems described above, in combination with the other mitigations explained in this Section5, are reasonable, proportionate and effective mitigation measures for the risks identified forSnapchat’s in-scope services. 451 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 5.8.3 Overview and Approach 453 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ○ 454 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ● Age Appropriate Design Code Snap has adopted the Age Appropriate Design Code (AADC) guidance for developers toincorporate appropriate and proportionate measures to safeguard the privacy, safety, andsecurity of users aged 13-to-17 within platform products and features. This was first established bythe Information Commission’s Office (ICO) in the UK, but has been used as a global best practicestandard in other countries. This design code includes 15 core standards: 1. Best interests of the child: The best interests of the child should be a primaryconsideration when we design and develop products.2. Data protection impact assessments: Product must be covered when appropriate byminor data protection impact assessment. 3. Age appropriate application: Requires a risk-based approach to recognising the age ofindividual users to ensure we effectively apply the AADC standards.4. Transparency: The privacy information we provide to Snapchatters, such as our privacycenter, support pages and in-app notices, must be concise, prominent and in clearlanguage suited to the age of the child.5. Detrimental use of data: We should not use children’s personal data in ways that havebeen shown to be detrimental to their wellbeing, or that go against industry codes ofpractice, other regulatory provisions or government advice.6. Policies and community standards: Uphold our own published terms, policies andcommunity standards (including but not limited to privacy policies, age restriction,behavior rules and content policies).7. Default settings: Settings must be ‘high privacy’ by default (unless we can demonstrate acompelling reason for a different default setting, taking account of the best interests ofthe child).8. Data minimisation: Collect and retain only the minimum amount of personal data weneed to provide the elements of our service in which a child is actively and knowinglyengaged. Give children separate choices over which elements they wish to activate. 455 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 9. Data sharing: Do not disclose children’s data unless we can demonstrate a compellingreason to do so, taking account of the best interests of the child.10. Geolocation: Switch geolocation options off by default.11. Parental controls: If providing parental controls, give the child age appropriateinformation about this. If our online service allows a parent or carer to monitor their child’sonline activity or track their location, provide an obvious sign to the child when they arebeing monitored.12. Profiling: Switch options which use profiling ‘off’ by default unless there are appropriatemeasures in place to protect the child from any harmful effects.13. Nudge techniques: Be mindful of and avoid using nudge techniques to lead orencourage children to provide unnecessary personal data or weaken or turn off theirprivacy protections.14. Connected toys and devices: If providing a connected toy or device ensure we includeeffective tools to enable conformance to the Code. 15. Online tools: Provide prominent and accessible tools to help children exercise their dataprotection rights and report concerns. We have been actively supporting the efforts of the Commission and other stakeholders’ toestablish an EU-wide Age Appropriate Design Code and/or guidance on the application of Article28, and to consider whether further mitigation measures may be reasonable, proportionate andeffective for online platforms, ‘gateways’ and other online services. The Commission has sincepublished its guidance on Article 28 DSA, and we remain committed to working closely with theCommission and others on its implementation. We have assessed the extent to which we meetthe recommendations in the guidance in Section 4.4.3 (Negative Effects on Minors) and have alsoreferenced the guidance in Section 5.12 (Codes). Privacy, Safety, and Security of Minors on Snapchat Privacy, safety and security are key priorities of the company and at the core of our valueproposition to our users. Snap has dedicated extensive resources to incorporate protectionsaimed at safeguarding the rights of Teens on the platform, greatly reducing the likelihood ofrights infringement. At the highest level Snap follows Age Appropriate Design Codes (or similar)established by the United Kingdom, France, California, etc, as well as our own key tenetsdescribed earlier in this playbook. Snap's approach to privacy and safety by design means thatwe generally design for our youngest users first and work upwards. This means our first layer ofprotection for minors includes the mitigations that are designed for Teens but apply to all toadvance safety across our community. Snap has put in place a range of mitigation measures to help protect the privacy, safety, andsecurity of minors on Snapchat. This includes general platform safeguards such as our Teenfriendly terms and support pages, our moderation and enforcement processes, our parentaltools–Family Center, in-app reporting, and Teen specific content moderation and restrictions, 456 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT In addition to these safeguards for Teens, we consistently enforce our policies disallowing usersunder the age of 13 from creating or maintaining an account. Persons who are younger than 13will be blocked from creating an account at the time of registration; accounts that are discoveredto be operated by persons under the age of 13 are removed from the platform at the time thatSnapchat discovers such violations. Advertisements for Minors Snapchat automatically disables advertisements based on profiling for users aged 13-17 in the EU.Additionally, safeguards have been put in place to help Teens understand and recognize Lensesand ensure that advertisers and advertisements on our platform comply with our requirements. Snap has implemented additional safeguards and protections for minors related toadvertisements, as described in detail in the product-specific subsections below. Identifying Minors As the creators of a central communications tool for young people, we take seriously ourresponsibility to protect teens on our platform. We know age verification is an industry-widechallenge everyone is trying to solve, and we are already working with industry peers, regulators,and third-party technology providers on possible approaches. We look forward to continuingthese productive conversations to achieve methods that work for everyone. Snap currently takes a risk-based approach to provide an age-appropriate experience acrossSnapchat, consistent with best practices such as the UK Age Appropriate Design Code (AADC).As explained in our response to the Commission’s RFI on minors in December 2023: Registration and access to Snapchat In order to download the Snapchat app, users first need to create an account with either Apple orGoogle to access their app stores (Apple App Store and Google Play Store). Both the Apple AppStore and Google Play Store have age restrictions, they require users to create an account beforethey can access the stores, and the age restriction for those accounts is 13+ and in some cases14, 15 or even 16+ (see Apple and Google age restriction terms). Both Apple and Google rely on declared age to determine if a user is 13+. If a user provides anage under 13 account creation is persistently blocked unless parental approval is provided. BothApple and Google offer state of the art and easy to use parent tools (see Apple and Google family link terms). This means that in order to download an app - for example Snapchat - from theApple or Google Play Store a user needs to declare to be 13+ or parental approval has beenprovided. Although Snap has asked for access to Apple and Google’s parent tools and age signal to ensureconsistency, increase visibility of our guides and settings, reduce the burden on end users and 457 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ensure a level playing field with Apple and Google’s own apps, Snap does not currently havesuch access. As a result, Snap independently asks the user to confirm their age as an additional age assurancemeasure, despite age already being provided by the same user as part of the Apple and Googleaccount registration flow, as follows: Declared age to limit access to Snapchat to its target 13+ audience:a. Our declared age process has been designed to meet industry standards.b. In our Terms of Service, Privacy Policy, and other documentation, we make clear thatSnapchat is intended for users 13 years old or older. Users must affirmatively add theirbirthdate when registering for an account, and we deny users declaring they are underthe age of 13 the ability to create accounts.c. If we determine, or are otherwise made aware through an in-app report from a user,parent, or law enforcement, that an account belongs to someone younger than 13, wetake immediate action to prioritize and respond to the information. Our trained internalteam will review and disable the account, including immediately deleting the dataassociated with the account. In respect of a) ● We do not use inferred age techniques to prevent individuals under the age of 13 fromregistering or accessing the app. Reliable age inference is not feasible without data basedon user activity once registered and engaging in the app. We do not have such activitylevel data for any new user at registration, nor do we have this data at any time for usersunder the age of 13 (since all Snapchatters are declared to be 13 or older). ● As explained below, we have stronger age assurance in place to protect minors fromcertain content and features of Snapchat targeted at more mature audiences which allowus to protect against potential U18 use of adult accounts despite not having absoluteknowledge of U13 use. Our approach is stronger as it allows U18 protections to be appliedif there are changes after registration, for example, in potential situations where a parentor other adult user may register an 18+ account using their own information but thenprovide account access and usage to an U18 bypassing any static age assurance appliedon registration. ● Further, as shown in Section 1 (Snapchat Community) the vast majority of Snapchat usersaccess the app to use our messaging services to communicate with friends - not toodissimilar from traditional SMS or other messaging services, which typically do not haveany age gates at all. Such interpersonal communication services fall outside the scope ofthe DSA. 458 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT In respect of c) and our trained internal team: ● The team is trained to prioritize these tickets. When our privacy operations team receivesa ticket they act upon this promptly, often within a couple of hours. ● If our team is made aware of an account belonging to someone potentially under 13through external sources (eg. through in-app reporting, Law Enforcement requests), aticket is created and routed to our human Trust \& Safety team who is also trained toprioritize these types of tickets. The team of moderators responsible for reviewing thesereports consists of several dozen FTEs.215 We do not track the specific response time forthis type of ticket, these metrics are tracked across all reporting types. ● We provide moderators with training sessions on policies, processes, tooling, currentevents and cultural norms to be effective at their work. Our moderators are trainedthrough small group training classes and also review a multitude of scenarios whileshadowing high-performing peer moderators. Through practice and instruction, theyapply our policies and enforcement measures in a manner that protects our Snapchatcommunity. This training is conducted over a multi-week period, in which the moderator iseducated on Snap’s policies, tools, and escalations procedures. After the training,moderators must pass a certification exam before being permitted to process content. ● In addition to the general moderation training (see below), these team members receivespecific training and guidance from our (privacy) legal teams. In respect of c) and the use of keywords to detect under age users: ● In general, Snap does not scan keywords during account creation or from accountinformation to detect whether a user might be underage. As noted in Section 1 (SnapchatCommunity), more than 80% of time spent is on private surfaces. Snapchat is primarilyintended and used as a communications tool by our users with their close friends andfamily, and fundamentally different from traditional social media where the majority of thecontent is public. We apply a privacy-first approach to user communications, such asChats, and those are not subject to scanning for purposes of learning a user’s age or 215 For a more detailed breakdown of our human moderators please see Section 5.4 (Content Moderation). 459 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT age-targeted to at least 18+, or the applicable minimum drinking age in the respectivecountry where the ad is running. Our age inference model is used as an integral part of our age assurance method to limit under18 access to content and features targeted and suited to more mature audiences. The inferredage model on Snap uses a variety of influential signals , rather than only relying on the age that users provide when signing up to the platform. Thishelps, for example, prevent regulated ads from being served to those users who have declaredthemselves to be over the age restriction but we have modelled as likely to be under theappropriate age for such regulated content. For example, if a user’s self-declared age is 20 years old, yet the signals derived from the user’sactivity within the app and the ages of their friends strongly indicate that they are likely under 18years old, we can internally “override” their supplied age and flag the user as a minor, andtherefore filter regulated ad content (e.g. alcohol) from being displayed to them. The inferred age model does not utilise any third party age assurance providers. To minimisedisclosure of personal data, the model is processed within Snap. As flagged above, we do not use inferred-age techniques to prevent individuals under the age of13 from registering or accessing the app. Reliable age inference is not feasible without databased on user activity once registered and engaging in the app. We do not have suchactivity-level data for any new user at registration, nor do we have this data at any time for usersunder the age of 13 (since all Snapchatters are declared to be 13 or older). The use case for ourage inference model has always been geared toward mitigating the risks for users under 18, forexample to ensure users under 18 do not see regulated ads, such as ads for alcohol. As Snapisn’t capable of determining that a user is under 13 from our inferred age model, we have neverapplied it for the purpose of preventing users from registering an account. In line with our COPPA obligations, if Snap receives actual knowledge that a user is under 13 (for example, from a verifiedparent’s request), Snap promptly deletes the account and associated data. 462 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Oversight We have a dedicated working group overseeing our age-assurance efforts. This cross-functionalgroup consists of 10+ FTEs with representatives from the product, privacy legal, product legal,policy, and trust and safety teams. These team members bring to the table extensive experienceand knowledge in the areas of operations, policy, global privacy laws and regulations,privacy-focused product decision making and online safety. Different iterations of this group activate as needed to meet in working groups that are focusedon exploring, discussing and assessing possible ideas and concepts and solutions related to ageassurance through risk assessments, discussions with our product team, and collaboration withexternal legislators, regulators, peer platforms, vendors, experts, NGOs and other stakeholders. For example: ● This group regularly meets to discuss Snap’s age and parental assurance methods, andthe legal and regulatory requirements in this space. ● This team has assessed current industry practice with regards to age and parentalassurance, including in particular the mechanisms of: (i) device operating systems Google Family Link, Apple device parental controls and Family Sharing controls and MicrosoftFamily Safety and (ii) other online services such as Whatsapp, Tiktok, Instagram andYoutube. ● The team regularly engages in stakeholder meetings, such as those organised by the Centre for Information Policy Leadership (CIPL) Privacy in Europe. ● This group also advocates for a holistic approach to age and parental assurance. Anexample of this would be our work with the UK Government and House of Lords duringthe passage of the Online Safety legislation in Parliament to successfully achieve arequirement for Ofcom (the UK’s communication regulator responsible for regulating theUK’s Online Safety Act) to consult holistically on child safety and age assurance, includingconsidering the role that infrastructure such as app stores / device operating systemaccounts have in providing privacy friendly, secure, effective and efficient solutions. ● This team has also met with a number of industry leading third party age assuranceproviders to assess the technical, legal, financial and user impacts of those services beingintegrated into Snap. These efforts have proven successful and both Google and Applehave recently announced APIs to share age signals with app developers. We hope tobuild on this work to: (i) develop a comprehensive industry wide framework, with CIPL andthe We Protect Alliance and (ii) require Google and Apple to share further first party agesignals/software pursuant to their obligations under the Digital Markets Act. ● This team has reviewed research from external stakeholders, on the positive and negativeimpacts of age and parental assurance, as well as consulting with users of Snapchat(including our own families and friends). 463 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ● Representatives from this group presented to Snap’s Safety Advisory Board216 on Snap’sapproach to age assurance and Family Center, including potential options and challengeswith age assurances. On age assurance in particular, this group of experts advised us that: ○ This was an industry wide issue that needed broad stakeholder discussion andneed for service independent solutions (i.e. considering devices, app stores etc)that best met the needs of children and parents/responsible adults. ○ They also felt our 13+ age limit was inhibiting our ability to recognise and keeppotential younger users safe and advised us to consider lowering the age soSnapchat’s U18 experience was available to those that wish to use and lessincentive for children and parents/responsible adults to try to access via 18+accounts / bypass age assurance methods. They recognised the challenges thatCOPPA presents in this regard. ○ They felt it was better to have a safe platform for all than to rely on excessive age /parental assurance. This would limit the need for age / parental assurance to thesmaller number of mature areas. Ongoing evaluation Snap continues to evaluate its approach, and consider possible concepts and approaches withindustry peers and third-party age-assurance vendors, to ensure we keep pace with industrypractice. We are also supporting legislators and NGOs in the UK, France, and elsewhere in the EUto enhance the role of app stores, online devices, and web browsers in providing appropriateinterfaces for age assurance and parental controls to facilitate consistent, effective and efficientapproaches for the online ecosystem. Snap earned praise over years by the Children’s Advertising Review Unit (CARU) in the UnitedStates for exceeding standard protections to keep underage users off Snapchat, and forproviding numerous safeguards for our users once they are on our platform. Despite this, wecontinue to reassess our age assurance efforts, including engaging with industry partners,regulators, and third party age assurance vendors, to ensure we keep pace with developments inthe space. We actively participate as thought leaders in industry roundtable forums, as well aswith policy makers in the UK, US and the EU to understand the evolving landscape of ageassurance, and its critical importance coupled with its inherent challenges. We’ve also heldmultiple exploratory and deeper dive sessions with leading vendors across the age estimationand identity verification marketplace in recent months, as we consider third party technologiesincluding biometrics, ID scan, and financial transaction methods (among others), to enhance ourcurrent approach. As noted above, these efforts have been fruitful as both Google and Appleintend to introduce APIs to share age signals with app developers. As above, we hope to build onthis work to require Google and Apple to share further first party age signals/software throughindustry collaboration and/or pursuant to their obligations under the Digital Markets Act. 216 The Safety Advisory Board is explained in Section 6.7 (Snap Advisory Groups). 464 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT In terms of parameters, Snap consistently focuses on the potential impact to key areas whenevaluating the effectiveness of age assurance measures. Such factors include the tradeoffbetween safety of minors and compromising user privacy/data security, the accuracy andreliability of age estimation technology (particularly for younger or ethnic minority populations),the fairness of methods that may disadvantage users without official government IDs or bankaccounts, and the harm to industry competitiveness from the exorbitant cost of adopting thirdparty technology at scale. It is also worth noting that many organizations have concerns about the effects of introducing ageassurance and support device OS account and app store based solutions for age assurance tosupport online platforms’ own mitigation measures, for example ICMEC and NCOSE in the US.Prominent European children’s NGOs have expressed similar support when meeting withSnapchat. To that end we’ve seen in the US that a growing number of states have passed orintroduced legislation that requires app stores to perform age verification of all users and toshare such age signals with app developers. We remain focused on thoughtful enhancements to our risk-based, age and parental assuranceapproach that include balancing the need for safety, accuracy, fairness, and user privacy amongother important factors and taking a holistic view of the online ecosystem used by children andtheir parent(s) (or other responsible adult(s)). Taking account the results of our risks assessmentset out in Section 4 and current industry wide practices, we continue to conclude that ourapproach is proportionate, reasonable and effective. European Commission Art 28 DSA Guidelines Considering the mitigation measures outlined throughout this section and the Risk Assessment,and taking into account the recently issued Guidelines on the application of Article 28, we havecarried out an analysis of these recommendations and assessed our organisation’s position inrelation to them. This analysis seeks to map existing measures against the expectations set out inthe guidelines and evaluate whether the platform’s current practices align with the requirement toensure a high level of privacy, safety, and security for minors. The table provides an overview ofthe obligations, which serves as the benchmark for our assessment. Please note that we are conscious that not all recommendations are currently implemented; insome cases, we consider our existing measures to be proportionate and effective, while in othersfurther steps remain under consideration. In any case, we value the guidelines, which - thoughnot mandatory - provide useful direction on best practices. At the same time, it is important torecognise that each platform and online service has its own nature, and therefore measuresshould always be applied in a manner that is proportionate and adapted to be effective in thosespecific circumstances. Section Summary of the Guidelines Snap current measures 465 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT GeneralPrinciples Platforms should adopt measuresproportionate to their specific risks,always balancing safety withfundamental rights. They should respectChildren’s Rights under the Charter andUNCRC, embedding privacy, safety, andsecurity by design from the outset.Finally, services must followage-appropriate design, adaptingfeatures to minors’ cognitive andemotional development. As explained in Section 6.3., Snap embedsprivacy and safety by design and followsAge Appropriate Design Codes fromjurisdictions like the UK, France, andCalifornia, as well as its own framework. Guided by key tenets - acting in Teens’ bestinterests, enabling safe expression,ensuring access to information, supportingparental guidance, and applying heightenedsafeguards - Snap designs products withthe youngest users in mind first. These protections for Teens form thebaseline safety layer applied across ourplatform, as explained in the mitigationsection of this section. Risk Review Organizations should systematicallyassess how their products and featuresimpact Children’s Rights by identifyingrisks through the OECD’s 5Cs typology(Content, Conduct, Contact, Consumer,and Cross-cutting risks), mapping themby likelihood and severity, andevaluating both positive and negativeeffects on minors. These assessments should be reviewedannually or after significant changes,such as the introduction of AI features orrecommender systems, and shouldactively involve minors, guardians,child-rights experts, and independentstakeholders. To ensure accountability,the findings should be shared withregulators and published transparently. Snap already conducts (and publishes,when required) systematic riskassessments, mapping them by likelihoodand severity, as evidenced in this report.This approach is applied not only to meetthe DSA requirements for VLOPs, but alsoto comply with similar regulatoryframeworks in other jurisdictions, such asthe UK’s Online Safety Act. ServiceDesign Platforms should focus on robust ageassurance, with a preference for secureverification methods overself-declaration. Estimation techniquesshould be used cautiously, ensuringtransparency, accuracy, and dataminimisation. Access to high-risk content In line with Article 28 requirements and theCommission’s guidelines, Snap hasimplemented a series of service designmeasures aimed at protecting minors. Age Assurance: Snap applies a risk-basedapproach to age assurance, building on its 466 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT such as pornography, gambling, andaddictive features should be strictlylimited to verified adults, with multipleassurance methods and appealsprocesses in place. Registration flowsmust remain simple and child-friendly,collecting only essential data andavoiding nudges that encourageunderage users to bypass restrictions. To protect minors after registration,account settings should default to thehighest levels of privacy, such as privateaccounts, disabled geolocation, andrestrictions on unsolicited contact.Interfaces must avoid manipulativedesign practices (like infinite scroll anddark patterns) while offering tools fortime management and friction nudges. AI features, including chatbots andfilters, should remain optional,transparent, and easily disabled.Recommender systems must beregularly tested to prevent amplificationof harmful content, prioritize explicit userchoices over profiling, and allow minorsto reset feeds or opt out of profilingaltogether. Additionally, commercial practicesshould ban exploitative marketingtactics, mandate clear advertising labels,and safeguard children against hidden ormanipulative in-app purchases. Finally,content moderation should be clear,responsive, and continuous, combininghuman and AI systems to detect harmfulcontent across languages, prioritizeminors’ reports, and prevent harmfulAI-generated interactions such asgrooming prompts. 13+ entry threshold. Snap continues toevaluate its approach in collaboration withindustry peers and age-assurance vendors.While current measures are deemedproportionate, Snap actively participates inpolicy discussions in the EU and otherjurisdictions to strengthen consistencyacross the ecosystem (e.g., throughdevice-level or app store-based solutions). Defaults and Account Settings: Snapensures that Teens’ accounts default to thestrictest privacy settings - including limitedvisibility, restricted friending, disabledgeolocation sharing by default, and controlson who can communicate with them.Features such as Family Center allowguardians to monitor interactions in asupportive, transparent way. These designchoices align with the principle of acting inthe best interests of minors while stillpreserving their right to self-expression. Interfaces, Tools, and AI: Snap hasimplemented product review processeswith the aim to identify and preventmanipulative design patterns. Although generally out of scope of thisReport, we note that with the introduction ofAI tools, Snap has applied safeguards suchas content moderation, user warnings, andongoing red-teaming with HackerOne toidentify vulnerabilities. Recommender Systems and ContentModeration: Snapchat’s recommendersystems (e.g., Spotlight, Discover) aredesigned to reduce exposure to harmfulcontent. Moderation is carried out through ahybrid human-automated model, with 24/7coverage, trusted flagger partnerships, andescalation systems. Moreover, on Discover,our policies are written with theunderstanding that people as young as 13 467 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT may be viewing the content and should beage appropriate. Snap also invests in moderator training,support, and ongoing upskilling to ensureaccurate and safe enforcement. Commercial Practices: Snap has adaptedits advertising systems to prohibitexploitative or harmful practices. Thisincludes bans on targeted ads to minors,the rejection of thousands of harmful adsmonthly, and the use of strict reviewprocesses to block hidden or manipulativemarketing practices. ReportingSupport \&GuardianTools The guidelines recommend platforms toprovide clear, accessible, andage-appropriate tools that allow minorsto report harmful content, seek redress,and access support. Reportingmechanisms should be visible, simple,multilingual, and include feedback loopsso children understand outcomes. Complaints must be free, timely, andconfidential. In parallel, platforms shouldoffer support features such as block,mute, “show me less” options, and linksto external helplines. They should alsoprovide guardian tools to help parentsguide minors, but only as a complementto safety- and privacy-by-designprotections, ensuring Children’s Rights toprivacy, safety, and autonomy remaincentral. As explained in Section 5.4 (ContentModeration) Snap provides in-app reportingtools that are simple and accessible for allusers, including Teens, allowing them to flagharmful content, unwanted contact, orunderage accounts. These reports areprioritized when submitted by minors andhandled by a 24/7 Trust \& Safety team,which combines automated detection withtrained human moderators. Beyond reporting, Snap offers supportivefeatures such as Heads Up, which surfacesexpert educational resources when userssearch for sensitive topics, as well aseasy-to-use block and mute functions andaccess to external hotlines. Guardians aresupported through Family Center, whichenables oversight of Teens’ connectionsand interactions, and a dedicated Parents’Site with guidance and resources. Governance Organizations should establish childsafety policies and dedicated teams withsenior oversight, ensure staff are trainedon Children’s Rights, and foster child Snap has put in place a governanceframework to oversee DSA compliance(which includes child safety), led by aCross-Functional DSA Governance Team 468 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT participation in design and safetyprocesses. They must monitorcompliance regularly, share data on risksand mitigations, and keep terms andconditions transparent and adapted forminors. Ongoing evaluation with input fromchildren, guardians, and experts isrequired, while transparency obligationscall for clear, accessible explanations ofsystems and tools using plain languageand visuals. and an Independent Compliance Functionwith direct access to senior management. As explained in Sections 6.6 and 6.7,Governance is further reinforced throughexternal input from the Safety AdvisoryBoard and the Council for DigitalWell-Being, as well as systematic monitoringvia prevalence testing and the DigitalWell-Being Index. Transparency to Minors We continue to make efforts to provide users with information regarding our services in a waythat is clear and comprehensible across age groups. We verify readability of our key terms andconditions and privacy notices using automated readability tools. The vast majority of thesedocuments are shown to be understandable for our users. Our main terms and conditions is,necessarily, a formal legal document and contains longer provisions and more complex languagewhich our automated readability tools indicate may be more difficult for our younger users tounderstand. To improve readability in particular for our younger users, we arranged the terms andconditions into sections that provide a sensible flow, including appropriate and succinct sectionheaders, and added short summaries at the bottom of each section. We have tested thereadability of these short summaries, and confirmed they are understandable for our users,including Teens. In addition, we have provided short explainers for our Community Guidelines tofacilitate user understanding of this important document and know what they should and shouldnot be doing on Snapchat. Our Privacy Center was designed for our youngest Snapchatters and was intentionally developedto be easy to read and understood by all members of our community. We created our privacy andsafety hub, with pages such as our Privacy by Product page, to give Snapchatters a high-levelsummary of our privacy and safety practices across each of our products and features. We alsocreated a video to visualize our privacy practices, and use icons and other best practices asrecommended by privacy and safety experts and the recognised Age Appropriate Design Codes. As outlined in the Introduction, our EU Snapchatter community consists of a diverse range ofages and genders. Snapchat services are not primarily directed at or used by minors. WhileSnapchat does have a young demographic, only a relatively small percentage of European Unionusers fall within the 13-17 age category. The largest age category of European Union users fallswithin the 18-24 age category. 469 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 5.8.4 Safeguards In addition to our defaults for all users, we have added protections in place for Teens, to helpmitigate risks in a number of ways. App Store Level Safeguards App stores contain and facilitate a vast range of apps presenting a wide array of different risksand representing the entire spectrum of online risks. They have a special place in the ecosystemand therefore a uniquely high risk. They should thus be considered as ‘high-risk situations’. Inaddition to the specific risks presented by the individual apps hosted, app stores can generatehigher and exponential risks for a minor than the ones created by each individual service (e.g. aminor accessing harmful information on different services and combining harms). Larger app stores already recognise that they present unique risks and require additionalmitigations. In fact, larger app stores already apply age gates to prevent users from downloadingan app if their app store account age is below the app’s minimum category specified by the appprovider (and where applicable parents via the device operating system’s account level familycontrols - see below). Like most online platforms, app stores usually rely on the app storeaccount’s declared age (which is often the same account used by the device operating system).We also have noted that app stores rely on predetermined age categories which do notnecessarily capture nor fit the age categories defined by Snapchat and other developers at theapp level. A classical example is the app store category 12+, which does not align with the agethreshold of 13+ that is commonly specified by application services. There are improvements which could be made by app stores providers for the benefit of theentire ecosystem including: (i) stronger age assurance at the app store / device (i) OS accountlevel and sharing that signal with developers to support their minor protection measures; and (ii)allowing developers to set a more precise minimum age. Device-Level Safeguards Many additional controls are provided for teenagers, parents and other responsible adults. Manydevices now come with wellbeing settings, such as bedtime mode that turn off device and appnotifications and turn the screen the black and white to encourage sleep. 470 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Additional controls are also provided via the device operating system’s account level familycontrols (e.g. Google Family Link, Apple device parental controls and Family Sharing controls and Microsoft Family Safety). For example, via these controls, parents and other responsible adultsare able to view usage, set time limits, and disable access for each app which the teenagers haveon their device. 471 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT We have also noted that the providers that operate these family controls (who are alsogatekeepers pursuant to the EU Digital Markets Act) provide deeper levels of visibility and controlfor their own first party services. This level of interoperability and access would be very helpful forour own Family Centre (which is explained below) as it would increase the awareness andaccessibility for parents and other responsible adults who may not have a Snapchat account. Asexplained below, we are actively encouraging further multi-stakeholder dialogue to have drivesolutions that provide equal access and interoperability across the industry. Platform-Level Safeguards There are several protections that we put in place at a platform level to mitigate the risk ofmalicious users of Snapchat. In particular, we have inference models in place that look at platform 472 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT wide meta-data signals to identify suspicious accounts. We use this information at a product levelto implement additional safeguards for Teen and adult users. Product-Level Safeguards In addition to our defaults for all users, we have added protections in place for Teens, to helpmitigate risks in a number of ways. CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Public Content Once users decide to share a Snap via My Story, by default only friends can view it. Snapchatterscan choose to share to everyone, only to friends, or to a customized few. This emphasis onsharing with friends and giving users controls over who can view their content is in line with howSnap takes into account privacy and safety when designing its features. Teen stories are deleted by default. Their My Story view setting is defaulted to friends only.Friends lists are private. Viewing Public Content Teen accounts are restricted from access to certain content that is generally considered suitablefor 13+ but may contain certain shocking or sensitive content some may not find appropriate. 474 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Spotlight We have developed machine learning classifiers which work to identifysexually suggestive content and filter it from the experience before human intervention. Inaddition, our Spotlight content is evaluated by human moderators upon reaching a thresholdnumber of views, and before being even more widely distributed. These steps reduce thelikelihood of Teens accessing illegal or violating content, or content that may negatively affecttheir rights, security and health. We also aim to prevent older users from seeing content from younger users and to protect Teensfrom being contacted by older users. We seek to achieve this by, for example, implementing thefollowing measures: ● We limit the recommendation of content created by Teens to older users ● Adults cannot comment on Teen’s Spotlight content on Snapchat. ● Users can also choose to disable comments on any post. ● Teens are protected on Spotlight by not having their usernames displayed. Snap Map As under 16 users cannot have Public Profiles, they will not have their Public Stories featured onSnap Map when tagging a place or venue to a Public Story (which would occur for 16+ accounts).Public posting options for 16-17 accounts are more limited. 475 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Additionally, Map filters out suggestive content from being recommended to users ages 13-17 andage-gates certain types of locations to prevent them from showing on maps for minors, includingbars and tattoo parlors. Moreover, Snapchat displays a "low mutual friends" warning when a useris about to share their location with someone who has few or no mutual connections. This safetyfeature helps users make more informed decisions by flagging potentially unfamiliar individualsbefore location sharing occurs. Advertisements We restrict ads based on the user’s age. For example, ads for dating services must be targeted tousers over 18 and must not be provocative, overtly sexual in nature, or reference transactionalcompanionship. Similarly, ads for alcohol products must be age-targeted to at least 18+, or theapplicable minimum drinking age in the respective country where the ad is running. Advertisers must comply with our Ad Terms, Advertising Policies, and applicable nationaladvertising codes. We prohibit ads that address or intend to appeal specifically to childrenunder the age of 13. 476 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 477 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Our Ads API automatically prevents targeted ad types (such as pre-defined audiences andcustom audiences) from being approved for ads directed at users ages 13-17. Ads API alsoprevents personalized optimization goals from being used for ads reaching Snaphatters aged13-17 in the EU and UK (such as video views and story open). Ads Restriction We also restrict ads based on the user’s age. Reporting and Blocking ● In-App Reporting: Teens have the ability to report abuse they may observe or experiencewithin Snapchat. They can easily report Snaps, Chats, Stories, and Accounts by navigatingto the clearly marked “Report” option in the menu on each of these feature screens or bypressing and holding on the content itself. Users follow our simple reporting flow andprovide their reason for reporting and any additional comments that might be relevant.Moreover, through the "My Reports" section in the Account Settings, teens can view andtrack the status of the safety reports they've submitted. Reports are reviewed by our Trust\& Safety teams that operate 24 hours a day, 7 days a week, and violating content andaccounts are subject to enforcement. See the Enforcement section of this Report for moreinformation. 478 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ● No Public Friends Lists: Once users have accepted friend requests, the friend lists remainprivate. Snapchat does not disclose the friend lists of users to other users, nor do weexpose the total number of friends that a user has. This protects the privacy of the userand their friends. On most other platforms friend lists are public by default or there is anoption to share them publicly. These types of features create the ability for strangers tocontact vulnerable groups (e.g. younger users). ● Friend Check-Up: Prompts Snapchatters to review their friend lists and remove those theyare no longer in contact with, keeping their network up-to-date and focused on closefriends. ● In-App Warning: We provide pop-up warnings: (1) when a teen receives a message fromsomeone they don’t already share mutual friends with or have in their contacts219 and (2) ifthey receive a chat from someone who has been blocked or reported by others, or (3) isfrom a region where the teen’s network isn't typically located.220 Family Center / Parent Tools Our in-app parental supervision tool, Family Center, gives parents, caregivers, and other trustedadults visibility into their teens’ friends list and who they have messaged with in the last sevendays, as well as the the ability to: (i) restrict their teen’s access to Spotlight and Discover contenttagged as 'sensitive' by our moderation team, (ii) disable their teen’s ability to engage with the MyAI chatbot; and (iii) quickly request their teen’s location (which the teen must approve beforelocation is shared). Parents can also control whether the teens have access to sensitive content 220 https://values.snap.com/news/new-features-to-help-protect-our-community. 219 https://values.snap.com/news/new-safeguards-for-snapchatters-2023. 480 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT on their Discover and Spotlight feeds. Parents are also able to easily report accounts that may bein violation of our Community Guidelines and have access to helpful resources directly in the app. Our goal in designing Family Center was to empower both caregivers and teens, balancingparents’ desire for more insight with teens’ desire for autonomy and privacy - notably ensuringthat teens’ messages remain private. We continue to put care and time into establishing thisbalance in a thoughtful way, engaging in user research and surveys, competitive research, focusgroups and interviews with both teens and parents, feedback sessions with dozens of onlinesafety experts and academics, including members of our current Safety Advisory Board, andextensive cross-functional internal reviews, including by our Product Legal and PrivacyEngineering teams. In their annual report,221 Jugendschutz.net, the joint competence center of the German Federaland State governments for the protection of children and young people on the Internet,highlighted Family Center as a positive example in the area of parental tools and support onsocial media platforms. The report concluded that Family Center can help teens and parents talkabout negative experiences, contacts, or time spent on the platform. At the same time, it notedthe opportunities for teen control, such as having to agree to parental oversight. 221 Jugendschutz, ‘Jugendschutz im Internet - 2022 Bericht’, April 2023, url. 481 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 482 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 483 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 5.8.5 Conclusion We take the protection of minors seriously. We’ve designed Snapchat to protect their privacy,safety, and security. Our key tenets include acting in the best interests of Teens, offering strictdefault settings for all users, and respecting Teens’ freedom to express themselves safely, whilerecognizing their right to information about the world. We aim to achieve these tenets bypositioning parents and guardians to help guide teens in their responsible use of our platform,attaching a heightened safety interest to Teens using our products, and establishing processes toensure we develop products in a way that upholds these tenets. We have implemented thesetenets through the use of Family Center, focusing on age-appropriate content, reporting and 484 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT blocking mechanisms, and putting in place appropriate protections and limitations on privatemessaging, friending, public content, and advertising. As explained in Section 4, we have concluded that the targeted measures we’ve taken toprotect the rights of the child, including age verification and parental control tools, incombination with the other mitigations explained in this Section 5, are reasonable,proportionate, and effective mitigation measures for the risks identified for Snapchat’sin-scope services. We have actively worked with the Commission and others to establishguidance on a high level of privacy, safety and security for Art 28 of the DSA, and are workingthrough that guidance to consider whether further mitigation measures may be reasonable,proportionate, and effective for online platforms, ‘gateways,’ and other online services. 5.9 Content Authenticity 5.9.1 Introduction Snap is aware that there is intense interest and concern surrounding the ways in whichadvancements in generative AI technologies are impacting online platforms. Content authenticityis a very challenging topic without a silver bullet. Snap is very conscious of the issues and has implemented a number of measures. Snaprecognises the potential for AI generated or transformed content to be distributed through theinscope services of Snapchat, such as Spotlight and Discover, as explicitly called out in our Community Guidelines. Just like any other content distributed through these channels, thiscontent may constitute illegal content or information that otherwise violates Snap terms andcould contribute to the systematic risks outlined in Section 34 of the DSA. Snap continues tocarefully monitor developments and industry practice, including regarding whether and how bestto use prominent markings and other measures to distinguish content that falsely appears to beauthentic or truthful. 5.9.2 Risk Assessment Results Snap gave due consideration to the risks and harms that could arise from dissemination of usercontent in its risk assessment results section of this Report. In particular: ● Section 4.1.10 (Harmful False Information) - In this section, Snap recognised that “fakenews,” (online) “disinformation” and “deep fakes” had gained a lot of attention in themedia and academic and political debate over the last years. We recognised that suchcontent presented a risk of significant harm. This applied to all content formats, whetheror not generated using AI tools. However, when considering evidence relating toSnapchat specifically, we found very low prevalence rates of this type of harmful content. 485 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT We concluded that ‘Harmful False Information’ fell within the lowest likelihood and riskprioritisation category relative to other harms being monitored on Snapchat. ● Section 4.3.1 (Negative Effects on Democratic and Electoral Processes) - In this section,Snap recognised that online platforms may have a negative effect on the electoralprocesses and the exercise of political rights by amplifying digital disinformation ordeceptive content relating to political matters or processes. Again, this applied whether ornot generated using AI tools. However, when considering evidence relating to Snapchatspecifically, we found only limited occurrence of content harmful to democracy.Independent reports of electoral interference on Snapchat are vanishingly rare. Inconnection with a major, high-profile election in 2022, we onboarded Snap to the ElectionIntegrity Partnership (EIP),222 a partnership among leading research centers and civilsociety organizations who monitor online harms to democratic processes; as participantsin the EIP threat escalation program, our teams received only one single incident reportfrom the researchers monitoring risks on Snapchat. We concluded that ‘Negative Effectson Democratic and Electoral Processes’ fell within our lowest likelihood and riskprioritisation category relative to other harms being monitored on Snapchat. ● Section 4.3.2 (Negative Effect on Civic Discourse) - In this section, Snap recognised thatdigital content platforms could contribute to Negative Effects on Civic Discourse. Forexample, we noted: ○ The potential for personalized content and algorithmic biases lock users into echochambers, reinforcing existing beliefs and potentially leading to polarizedcommunities, which hinders open dialogue. ○ The risk of amplified dis- and misinformation negatively impacting public opinionon important civic issues. ○ The possibility of amplification of extreme or sensational content to retain userattention leading to heightened polarization and a hostile online environment.However, when considering the evidence relating to Snap specifically, we again found avery low prevalence of content related to harming Civic Discourse relative to othercategories being monitored. We concluded that ‘Negative Effect on Civic Discourse’ fellwithin the lowest likelihood and risk prioritisation category. 5.9.3 Mitigations Although there is not a high prevalence of Harmful False Information, Fraud and Spam orimpersonation, we take harmful information of this nature on Snapchat very seriously and Snaphas implemented a number of mitigation measures. Guidelines, policies, and practices Snap maintains robust policies – applicable to both the dissemination and the creation ofgenerative AI content – that function to mitigate risk and advance safety. 222 Election Integrity Partnership (2020), url. 486 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Creation Snap has developed several internal policies relating to generative AI. In particular, (1) Content and Product policies: We have developed a suite of policies that disallow thegeneration of harmful content (including deceptive political content). Our policy andmoderation teams work in partnership with engineering and data science colleagues toensure that our AI products are responsibly trained on these policy parameters.(2) Acceptable Use: We have similarly developed Acceptable Use Policies that prohibit theuse of our AI tools to attempt to generate violative content at the prompt-level. With regards to the Content and Product policies, we have drafted and implemented internalGenerative AI Policies to govern the internal development of generative AI features, such asMyAI. Our Product and engineering teams refer to this policy as they train models or adaptmodels from third parties. Our Safety team applies this policy when testing new features. 487 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ● These aligned very closely with the rules for content dissemination, which are explained below. Inaddition, our generative AI tools feature a broad range of mitigation measures, depending on thetool, and include for example: specific transparency statements, abusive language detection andquery related measures, age appropriate and/or canned responses, reporting mechanisms, off-bydefault settings, data minimisation, data sharing, testing and parental controls (see Section 5.8 onthe Protection of Minors). Although out of scope of the DSA and this Report, risks and mitigationsrelating to our generative AI tools are assessed via our privacy and safety by design productreviews (see Section 6.3). Dissemination In the context of dissemination of content on Snapchat’s online platform, in scope of the DSA, weunderstand well that online platforms may have a negative effect on the electoral processes andthe exercise of political rights by amplifying digital disinformation or deceptive content relating topolitical matters or processes. Our Community Guidelines and Terms of Service set out the rules on what content is allowed onSnapchat. They are focused on preventing harm to Snapchatters and the broader communityfrom content and behaviour, whether or not caused by generative AI or any other form of IT tools(such as Photoshop). These rules apply to all content formats across our platform, includingcontent that is AI-generated. While the rules are agnostic to content format or creative tools, theCommunity Guidelines specifically note: “We implement safeguards designed to help keepgenerative AI content in line with our Community Guidelines, and we expect Snapchatters to useAI responsibly. We reserve the right to take appropriate enforcement action against accounts thatuse AI to violate our Community Guidelines, up to and including the possible termination of anaccount.” Our rules and internal enforcement guidance include clear provisions related to content risks, forexample for Civic Discourse and electoral processes. In particular, our Community Guidelinesprohibit spreading false information that causes harm or is malicious, such as denying theexistence of tragic events, unsubstantiated medical claims, undermining the integrity of civicprocesses, or manipulating content for false or misleading purposes (whether through generativeAI or through deceptive editing). Our Community Guidelines rules on false information refer to a more detailed Explainer thatprohibits content that undermines the integrity of civic processes, or deep fake content or othermedia that is manipulated for false or misleading purposes. The Community Guidelines furtherexplain that these prohibitions extend to the following types of harmful content: 488 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ● Procedural interference: misinformation related to actual election or civic procedures,such as misrepresenting important dates and times or eligibility requirements forparticipation. ● Participation interference: content that includes intimidation to personal safety or spreadsrumours to deter participation in the electoral or civic process. ● Fraudulent or unlawful participation: content that encourages people to misrepresentthemselves to participate in the civic process or to illegally cast or destroy ballots. ● Delegitimization of civic processes: content aiming to delegitimize democratic institutionson the basis of false or misleading claims about election results, for example. Sharing such content will violate Snap’s Community Guidelines irrespective of whether it isAI-generated or user-generated, or whether it is generated on Snapchat or on another platform. Snap has a suite of internal policies and guidelines to help our content review and trust andsafety teams apply the Community Guidelines to user generated content disseminated via ouronline platforms (such as Spotlight and Discover). They provide more granular information for ourcontent review teams. For example, we explain that obvious jokes, memes, satire andnon-libelous comments about prominent social figures are OK; whereas false political narrativesmeant to undermine elections, or harmful / defamatory deepfakes, are NOT OK. In addition, our platform does not widely distribute an unvetted feed of algorithmically curatedpolitical information; we disallow all political content223 from Spotlight (our broadcast platform forUser Generated Content) unless it’s from trusted news partners and creators, and pre-moderatethat surface to ensure that other such political content is not distributed. This safeguard ensuresthat Snap is not algorithmically promoting political statements from unvetted sources, andgenerally reflects Spotlight’s function as an entertainment platform. (Consistent with ourcommitments to fundamental rights of expression and access to information, Snapchat providesother, non-algorithmically amplified spaces for users to express their views and politicalobservations, such as Chat and My Story; users can also seek access to political information fromknown publishers and creators whom Snap has on-boarded for distribution on the Stories tab). With regards to advertising, as explained in our previous communications and meetings with theCommission in response to its RFI on Gen AI and its consultation on the Guidelines for electoralprocesses, we do not require ads to label when advertisement includes generative AI content nordo require advertisers to disclose to us the tools they used to edit or create their ad creative.Instead, our approach is to subject all of our ads to a review process, and political ads are alsosubject to fact checking. Deceptive ads are rejected, irrespective of whether they use AI,photoshop, or other digital editing tools. Ads that are not deceptive, and otherwise comply with 223 For these purposes, “political content” means content related to political campaigns and elections, governmentactivities, and/or viewpoints on issues of ongoing debate or controversy. This includes content about candidates orparties for public office, ballot measures or referendums, and political action committees, as well as personalperspectives on candidate positions, government agencies/departments or the government as a whole. 489 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT our Ad Policies, are approved to run (and if they are a political ad, they must include a “paid forby” disclaimer and are catalogued in Snap’s political ads library). User Guidance on Generative AI features On-platform features for creating generative AI content are not part of Snap’s inscope servicesand are out of scope of this Report (save for certain commonplace ad creation tools).Nevertheless, outside of its DSA obligations, Snap has released a generative AI support site thatexplains what generative AI is and provides additional transparency around Snap’s practices withregard to generated images which are detailed below. To that end, we provide indicators acrossmost Snapchat experiences that involve AI. We use a range of methods to notify users that they are interacting with or viewing AI-generatedcontent. These include: ● The sparkle icon ( ) displayed alongside features or outputs powered by AI. ● Context Cards or disclaimers that explain when a feature is AI-driven. ● On-screen tool tips or labels that appear within relevant features like Dreams and AISnaps ● In some cases, visible watermarks, such as a Snap Ghost with sparkles, are added toexported or saved images created using generative AI tools. 490 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Here are examples of what these AI indicators look like in Snapchat: These signals help users understand that the content was not created by a human and may notdepict real-world events or scenarios. We are mindful of the importance of clarity and consistency. For this reason, Snap continues toexpand and refine our transparency efforts. For example: ● When users export AI-generated images to their Camera Roll, these images will ofteninclude a watermark indicating they were created using Snap’s AI-powered tools. ● When AI-generated content is shared with others on Snapchat, we may include ContextCards to ensure recipients understand that the content was created with AI. ● We are exploring new ways to further enhance visibility and user understanding of AIinvolvement across the product. 491 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT At the same time, we recognize that watermarks and labels alone are not foolproof - they can bemissed, altered, or removed. That’s why we rely on a multi-layered approach that includesproduct disclosures, interface cues, content moderation, and user reporting tools to help mitigaterisks of confusion or misuse. Snap remains focused on helping users engage safely and responsibly with generative AI. Webelieve that transparency, when done effectively and consistently, builds trust and helps ensurethat AI-powered features are understood and used appropriately. Enforcement Snap enforces these Community Guidelines fairly and consistently, using internal policies andguidelines, and applies outcomes that are commensurate with the severity of risk. Accounts that we determine are used to perpetrate serious, high-severity harms will immediatelybe disabled. For other violations of our Community Guidelines, Snap generally applies athree-part enforcement process: ● Step one: the violating content is removed. ● Step two: the Snapchatter receives a notification, indicating that they have violated ourCommunity Guidelines, that their content has been removed, and that repeated violationswill result in additional enforcement actions, including their account being disabled. ● Step three: our team records a strike against the Snapchatter’s account. A strike creates a record of violations by a particular Snapchatter. Every strike is accompanied bya notice to the Snapchatter; if a Snapchatter accrues too many strikes over a defined period oftime, their account will be disabled. This strike system ensures that Snap applies its policies consistently, and in a way that provideswarning and education to users who violate our Community Guidelines. The primary goal of ourpolicies is to ensure that everyone can enjoy using Snapchat in ways that reflect our values andmission; we have developed this enforcement framework to help support that goal at scale. Partnerships Snap continues to be actively engaged in the roll out of the EU AI Act, including with regards tothe drawing of the related codes of practice for providers of general-purpose AI models andthose regarding the detection and labelling of artificially generated or manipulated content andunder the AI Pact. More broadly, tackling risks stemming from generative AI requires (among others) broadindustry-wide technical solutions which have not been clearly identified so far. This is why Snap isactively engaging with its peers and industry experts in different fora to share best practices andadvance the technical debate. These partnerships, industry collaborations and efforts include: 492 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ● OpenAI Integration: My AI is powered by OpenAI’s ChatGPT, and Snap closely partnerswith OpenAI in relation to providing the My AI service, including sharing feedback onmoderation of content. ● Tech Coalition / Working Groups on Generative AI: Snap is a member of the TechCoalition’s Working Group on Generative AI Content, and a member of the GenAI BriefingSubgroup. The Working Group on Generative AI Content meets regularly to facilitatedialogue and information- and idea-sharing around mitigating content-level generative AIrisks. The GenAI Briefing Subgroup meets periodically to plan expert briefings for TechCoalition members on topics related to Generative AI risks; such briefings have includedrepresentatives from government, law enforcement, civil society, and the researchcommunity. ● Tech Accord to Combat Deceptive Use of AI in 2024 Elections: Snap was an initialsignatory to the Tech Accord to Combat Deceptive Use of AI in 2024 Elections. Thiscompact seeks to set expectations for how signatories will manage the risks arising fromdeceptive AI election content created through their publicly accessible, large-scaleplatforms or open foundational models, or distributed on their large-scale social orpublishing platforms in line with their own policies and practices as relevant to thecommitments in the accord. The Accord was announced at the Munich SecurityConference in February 2024. ● ITI AI Futures Initiative: Through its membership in the Information Technology IndustryCouncil (ITI), Snap has participated alongside other private sector actors in the AI FuturesInitiative. Led by technical and policy experts spanning the tech ecosystem, the Initiativeis a forum through which participants are developing action-oriented recommendationsfor AI policy and working to address emerging questions around AI. Deliverables to datehave included the issuance of Global AI Policy Recommendations to help guidegovernments around the world as to develop responsible regulatory approaches toAI-related issues. ● HackerOne - Red-Teaming Collaboration: Snap partnered with HackerOne on redteaming exercises to test the strict safeguards Snap has in place around AI. Together withHackerOne, we made significant developments in the methodology for AI safety redteaming that has led to a more effective approach to surfacing previously unknownproblems. We refer to the HackerOne blog for more details:https://www.hackerone.com/ai/safety-vs-security ● As an active member of the EU Internet Forum, Snap will support the upcoming dedicatedworking group on generative AI matters. ● We are also members of the Centre for Information Policy Leadership (CIPL) and theFuture of Privacy Forum (FPF) which work with industry stakeholders (like Snap), NGOsand government agencies in each region to advance a broad array of information topics.CIPL has been a leader in AI matters for many years through its dedicated AI Project andspecific Brazilian AI Project. Most recently, in Europe, CIPL has responded to the UKInformation Commissioner’s Office (ICO)’s consultations on Generative AI, and led various 493 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT forums on Accountable Governance of AI and AI Regulation in Brussels and the UK.Similarly, FPF is working on AI Governance and other responsible Gen AI initiatives. 5.9.4 Conclusion Content authenticity is a very challenging topic without a silver bullet. Snap is very conscious ofthe issues and has implemented a number of measures (including relevant measures identified inthe Commission’s guidelines concerning elections). Snap continues to carefully monitordevelopments and industry practice, including regarding whether and how best to use prominentmarkings and other measures to distinguish content that falsely appears to be authentic ortruthful. We have concluded that the mitigations explained in this Section 5, reasonable, proportionateand effective for the risks identified for Snapchat’s in-scope services. 5.10 Trusted Flaggers 5.10.1 Trusted Flagger Program Snap’s Trusted Flagger Program was developed to help non-profits, non-governmentalorganizations (NGOs), select government agencies, and safety partners support the Snapchatcommunity by leveraging a special channel to report content that violates Snapchat’s CommunityGuidelines. The program has been in operation for a number of years and has been developed inresponse to evolving risks and mitigations with respect to Snapchat. Trusted Flaggers send a completed report form with details of the potential violation via email toa dedicated, confidential email address or via a webform. The email and webform reports feedinto a high priority channel and reports are reviewed in less than 48 hours (with reports relating tothe most serious harms prioritized and reviewed well within this timeframe). Once a decision hasbeen reached, Snap informs the Trusted Flagger about the outcome of their report, includingwhether appropriate action has been taken. This channel can be used to report any type ofCommunity Guideline violation or otherwise illegal content and is designed to supplement in-appreporting, which is still very much encouraged. Our Trusted Flagger Program allows us to gain insight from the Trusted Flaggers over the typesof harm they are encountering, and the behavior of victims in these circumstances. In addition to providing aspecific reporting channel, the Trusted Flagger Program also allows us to build strongrelationships with Trusted Flaggers. Snap makes use of our strong relationship with TrustedFlaggers to give product safety updates, encourage the promotion of our safety tooling andprovision of safety resources (like links to our Safety Center). 494 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 5.10.2 Onboarding a new trusted flagger Snap receives reports from both Trusted Flaggers under the EU Digital Services Act and TrustedFlaggers who have entered into a direct agreement with Snap. Snap onboards the TrustedFlagger when the European Commission DSA Trusted Flagger web page is updated with thename of the appointed organisation and the contact email supplied. For the latter, typically, whenwe are considering accepting a new Trusted Flagger into our Snap program, we take intoaccount geographic coverage, area of expertise, anticipated volume of reports, among otherfactors. Once a Trusted Flagger is appointed or accepted we send them an onboarding package,which includes an overview document of the program, including our commitment to reviewreports in less than 48 hours (with reports relating to the most serious harms prioritized andreviewed well within this timeframe); instructions on how to file reports to our dedicated andconfidential email address; and contact information in case they have questions or concernsabout the program. When a Trusted Flagger wants to file a report, they leverage our instructions on which categoriesof information they should include in their reporting email. After we receive an email, Snap’s Trustand Safety teams review the report and take any appropriate enforcement action, or requestadditional information if required for full investigation. Once a decision has been made, Snap willinform the Trusted Flagger of any enforcement action the Trust \& safety team has taken inrelation to the reported content or accounts. Our teams remain in contact with the Trusted Flaggers, including when we need to discuss anyissues with their reports. Our team evaluates the reports submitted based on the completion ofthe form, the accuracy of the information provided, and whether or not the report leads toenforcement or other action. 5.10.3 DSA Trusted Flaggers We monitor the Commission’s publication pursuant to Article 22(5) of the entities that have beenawarded the status of ‘trusted flagger’ pursuant to Article 22(2) DSA. Upon receiving notice abouta new DSA Trusted Flagger, we decide whether the trusted flagger is relevant to Snap and if soestablish communication. Assuming all is well, we then follow the process outlined above. If ourteam identifies trends that are impacting the quality of the reports, we will communicate thisinformation with the DSC to identify a resolution. 5.10.4 Trusted Flagger Program Trends Europe including the UK: We continue to receive reports from and engage in cooperation withTrusted Flaggers. For the first half of 2024 and the second half of 2024 we saw 1,165 and 741reports respectively from Trusted Flaggers in the UK, Norway and several Member States of theEuropean Union. We have observed a reduction in reports from 2023, which we believe to be 495 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 500 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 5.10.5 Conclusion Snap has an existing, carefully managed Trusted Flagger Program with valued memberorganizations from a wide array of countries including many in the European Union. Snap looksforward to evolving its Program to incorporate organizations that have been awarded trustedflagger status under the DSA. As explained in Section 4, we have concluded that Snap’s Trusted Flagger Programme, incombination with the other mitigations explained in this Section 5, is reasonable,proportionate and effective for the risks identified for Snapchat’s in-scope services. 5.11 Dispute Settlement Bodies 5.11.1 Overview and Approach We invest significant resources in our community support teams who work to resolve queries andcomplaints received from Snapchatters and others. In line with DSA requirements (Article 21), weinform users of their right to seek out-of-court dispute resolution if they are dissatisfied with theoutcome of our internal complaint-handling process. 502 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT As of 14 August, we are aware of six bodies that have been established and certified by theDSCs. Recipients of the Snapchat service have the option to contact such out-of-court disputesettlement bodies to raise their case. The relevant out-of-court dispute settlement bodies arethen able to reach out to Snap via our dedicated contact point (dsa-enquiries@snapchat.com) tostart the out-of-court dispute settlement process. Snap will then engage, in good faith, with theselected certified out-of-court dispute settlement body with a view to resolving the disputefollowing Snap’s policies and procedures. 5.11.2 Enquiries From January 1st to June 30th 2025, Snap received a number of disputes submitted to certifiedArticle 21 bodies. 5.11.3 Further considerations 503 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 5.11.4 Conclusion Snap remains committed to resolving user disputes effectively and in line with DSA requirements.Furthermore, we continue to support establishing an EU-wide settlement body or an EU portal forbetter user interactions. This approach would ensure consistent application of rules across all EUmember states and provide a simplified, single point of access for operators. As explained in Section 4, we have concluded that Snap’s current approach to DisputeResolution, in combination with the other mitigations explained in this Section 5, isreasonable, proportionate and effective for the risks identified for Snapchat’s in-scopeservices. 5.12 Codes and Crisis Protocols 5.12.1 Cooperation Snap highly values cooperation with other providers and industry experts as a way to share bestpractices and learning experiences that can enhance risk mitigation strategies. We are highlycommitted to industry partnership to steer progress in the fight against illegal and harmfulcontent online. In particular, Snap is active member of the following groups: ● EU Internet Forum \- Snap is an active member and contributor of the EU Internet Forum (EUIF), which provides a collaborative environment for EU governments, the internetindustry, and other experts and partners to discuss and address the challenges posed bythe presence of malicious and illegal content online. The EUIF aims at exploring possibleresponses against abuse and exploitation of online platforms by terrorists and violentextremists, as well as other malicious actors, including those that groom children for thepurpose of sexual abuse and the production and dissemination of child sexual abusematerial online. Earlier this year, the scope of the EUIF work was expanded to tackle alsothe issues of drug sales online and the trafficking of human beings. 504 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ● Technology Coalition \- Snap is also a member of the Technology Coalition, which is analliance of global tech companies who are working together to combat child sexualexploitation and abuse online. The Tech Coalition coordinates industry’s overall effort tocombat child sexual abuse online. It provides resources, education, and capacity-buildingto tech companies, and serves as a resource for external stakeholders - from globalpolicy-makers to members of the media - on what industry is doing to tackle this issue. ● WeProtect Global Alliance \- Snap is a Board member of the WeProtect Global Alliance,which brings together the private sector, government and civil society to drive positivechange to help protect children from sexual abuse online. ● Alliance to better protect minors online \- Until the recent discontinuation of the initiativein July, Snap was also a member of the Alliance to better protect minors online. Thisself-regulatory initiative was aimed at improving the online environment for children andyoung people by steering debates and exchanges on the topic. ● CIPL \- Snap is a member of The Centre for Information Policy Leadership (CIPL). This is aglobal privacy and data policy think and do tank based in Washington, DC, Brussels andLondon. We work with CIPL and other industry leaders, regulatory authorities and policymakers to develop global solutions and best practices for privacy and responsible use ofdata, including with respect to teenagers and young adults. ● The Future of Privacy Forum \- Snap is a member of The Future of Privacy Forum (FPF).FPF is a non-profit organization that serves as a catalyst for privacy leadership andscholarship, advancing principled data practices in support of emerging technologies. Wework with FPF on a range of matters, including developing best practices related toAugmented Reality (AR), Artificial Intelligence (AI), biometric data, children’s rights, andmore. ● Centre on Regulation in Europe (CERRE) \- Snap is a member of CERRE, which is anot-for-profit think tank based in Brussels. Its goal is to support and inform aboutregulation in Europe and beyond. We work with CERRE on in-depth reports and issuepapers that address the major regulation challenges and high-quality, policy-orientedresearch undertaken by top-level academics in the tech, media and telecom sector. ● Internet Watch Foundation (IWF) \- We are a member of the Internet Watch Foundation,which is an independent, non-profit organisation that aims to prevent child sexual abuseonline. We sit on their Funding Council and our Head of Public Policy, UK \& Ireland, is anindustry trustee on the IWF Board. ● Thrive - Snap is a member of this industry signal and best practice sharing initiative whichis focused on suicide and self-harm content. Other Cooperation with industry Snap is actively involved in the work of a number of EU-based trade associations to contribute tothe policy debate to support the development of a proportionate regulatory framework topromote online safety. ○ DOT Europe \- Coordination on EU privacy, security,safety, content policy issues ○ ITI \- Coordination on EU privacy, security and safety policy issues 505 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 5.12.2 Codes of Practice The DSA establishes that the Commission and the European Board for Digital Services (‘theBoard’) shall encourage and facilitate the drawing up of voluntary codes of conduct at Union levelto contribute to the proper application of the DSA (Article 45). Snap welcomes the opportunity to support industry-wide efforts to promote risk-mitigationpractices in the form of voluntary codes. As a company with limited resources, Snap is constantly required to prioritize and ensure itsresources and efforts are focused on where the biggest risks and challenges for the companyare. As we advance in our learning curve from our DSA risk assessment, we will continue toprioritize interventions where we see the highest risks. 506 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT EU hate speech Code As part of its long-standing commitment to fight harmful and illegal content, Snap signed onto the EU Code of Conduct to counter illegal hate speech online in 2018. Since joining the code, Snap has successfully passed all the evaluations and in the course of thelast monitoring exercise (2022), and for the 5th consecutive year, Snap did not receive anynotification Additionally, in the course of 2022 Snap has worked closely with the European Commission andother signatories to further strengthen some of the Code commitments by reinforcing and betterframing the existing cooperation between IT companies and CSOs, beyond the remit of themonitoring exercises. This work led to the publication of an Annex to the existing code inDecember 2022. Snap continued to engage with the European Commission team (DG Just) andregularly cooperated with other industry signatories on a further update to the EU Hate Speechcode to bring it in line with the DSA. Since the EU Hate Speech Code was updated in line with the DSA on 20 January 2025, Snaphas complied with the Code as part of its DSA compliance program. 507 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT FSM Code of Conduct In September 2017, Snap joined 'the Freiwillige Selbstkontrolle Multimedia- Diensteanbieter e.V.(FSM), an officially recognized voluntary self-regulation association for the protection of minors inonline media. EU disinformation code Snap has not yet signed up to be a member of the EU disinformation code. Being very resourceconstrained and considering our limited exposure to this type of risk, we have so far opted not tojoin. 508 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Commission’s Disinformation team in July and planned a follow-up discussion with them aftersummer to discuss the outcome of our first DSA risk assessment. Article 28 DSA Guidance Considering the recently issued Guidelines on Article 28, we have assessed our organisation’sposition in relation to these recommendations (see Section 5.8). The analysis maps existingmeasures against the guidelines and evaluates whether our current practices ensure a high levelof privacy, safety, and security for minors. 5.12.3 Crisis Protocols Snap has set up a number of crisis management protocols to help the organization swiftly tackleunexpected incidents and help minimize their impact on our service, users and operations. 509 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 510 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Cooperation with external stakeholders is a very important element of risk mitigation for Snap.Knowledge sharing and best practice development with experts and peers are key to strengthenand increase the effectiveness of our internal risk mitigation measures. This is why the companyhas signed up to several voluntary codes and is actively engaged in many different internationalfora and associations to steer constructive debate and best practice development in areas likeCSEAI, protection of Teens, and Hate Speech (and we work closely with our global trusted flaggernetwork on these matters). We will continue to monitor our risks and prioritize interventions onthe most severe risk areas. When it comes to dealing with unexpected events resulting in 511 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT heightened levels of risks for the platform, our Content Crisis Response Protocol plays animportant role in providing a structure to our collaborative internal operations and efforts. As explained in Section 4, we have concluded that Snap’s current approach to codes ofpractice and crisis protocols, in combination with the other mitigations explained in thisSection 5, is reasonable, proportionate and effective for the risks identified for Snapchat’sin-scope services. 512 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 6\. Ongoing Risk Detection and Management Snap has developed a number of practices to detect and manage risks to Snapchat’s in-scopeservices. This includes: (1) the establishment of a Platform Risk Framework based on Snap’sproduct values, established international human rights principles, and risk-based metrics such asprevalence and severity analyses; (2) the designation of a senior, cross-functional teamresponsible for applying the framework and assessing its outcomes, including a DSA GovernanceGroup and meeting; (3) development of a repository of internal resources to support thedetection and management of risk––these include harm severity assessments; prevalencemetrics; reporting data reviews and a library of Terms and policy resources; and (4) continualimprovement and assessment through our Digital Well-Being Index (DWBI) Initiatives and SafetyAdvisory Groups (Safety Advisory Board and Council for Digital Well-Being). This Section of the Report provides further details of these practices pursuant to Article 42.4.(b)(reporting on the mitigation measures relating to Article 35.1.(f)) and Article 42.4.(e) of the DigitalServices Act. 6.1 Platform Principles-based Framework 513 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT This was an intensive and highly-consultative process that ultimately led to the implementation ofa framework that draws on a combination of Snap’s product values, established internationalhuman rights principles, and risk-based metrics such as prevalence and severity analyses. The framework is divided into two parts that borrow from relevant, longstanding elements of theinternational human rights framework: (1) identification of core platform governance values; and(2) a set of balancing principles for weighing those values against risks to our community andother harms. Reference to both of these elements in conjunction with one another provides aconsistent approach for responsibly reviewing proposed harm mitigations with attention tofoundational values. As a result, we have a responsible, rights-respecting approach to platform governance anddetecting and managing risk. The Compliance Team and Cross-Functional Working Groupsreview Snap’s approach periodically to ensure it is in line with legal requirements and global bestpractices. 6.2 DSA Compliance Team and Cross-Functional Working Groups This section sets out Snap’s approach to the establishment of governance mechanisms overSnap’s compliance with the Digital Services Act (DSA), fulfilling the requirements set out inArticles 11, 12, 13, 41, and 43. 6.2.1 Introduction This section outlines Snap’s governance mechanisms relevant to compliance with therequirements of the DSA, in particular with regard to the requirements outlined in Articles 11, 12,13, 41, and 43. 514 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT - 6.2.7 Operation of the Independent Compliance Function Responsibilities of the Independent Compliance Function The Independent Compliance Function is responsible for the following activities:- Cooperating with the relevant Digital Services Coordinator and the Commission for thepurpose of DSA compliance;- Providing oversight over the development of the Systemic Risk Assessment methodologyand the conduct of the Systemic Risk Assessment, ensuring it is conducted on the basisof the best available information and scientific insights- Ensuring that risks referred to in DSA Article 34 are identified and properly reported onand that reasonable, proportionate and effective risk-mitigation measures are takenpursuant to Article 35;- Organizing and supervising the activities related to the independent audit pursuant toDSA Article 37;- Providing oversight over the validation of controls leveraged to mitigate risks, evaluationof controls, and review of policies;- Monitoring the compliance with DSA obligations;- Reviewing and approving Transparency Reports;- Informing and advising the management and employees about relevant obligations underthe DSA;- Where applicable, monitoring the compliance with commitments made under the codes ofconduct pursuant to Articles 45 and 46 or the crisis protocols pursuant to Article 48 of theDSA. Oversight and Monitoring of Snap’s DSA Compliance The Independent Compliance Function utilizes multiple ways to exercise oversight andmonitoring over Snap’s DSA compliance:- Any relevant issues or observations are discussed within the Independent Compliance Functionas well as with relevant stakeholders and escalated to the Management Body and the CEO asneeded. The Independent Compliance Function investigates root causes of issues orobservations, develops mitigation plans and works with stakeholders and control owners to 518 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT implement such corrective actions. The Independent Compliance Function may also escalatesignificant issues / observations to the Management Body and the heads of the respectivefunction if the root cause is identified as relating to that function. DSA Management Body Snap has designated a Management Body which oversees and supports the independence ofthe compliance function and manages issues as escalated to the Body. CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Snap’s Cross-functional DSA Governance Team reviews Points of Contact and LegalRepresentative designationIf a new Point of Contact or Legal Representation is appointed, the Data Compliance Officer ordesignee will work with the web team to update the above website accordingly. Points of Contact are made publicly available in all official languages of the EU and are easilyaccessible on: https://values.snap.com/privacy/transparency/european-union Point of Contact for the Authorities Upon designation, Snap's cross-functional DSA governance team designated a single point ofcontact email address for communication with Member State authorities, the Commission, andthe Board to enable direct and effective communication between Snap and the relevantauthorities on matters related to the Digital Services Act. Upon designation Snap's cross-functional DSA governance team ensured the easily accessiblepublication of the relevant information relating to the point of contact for regulatory authorities,including the languages to be used in such communications, on the Snap website. Authorities can contact Snap at dsa-enquiries@snapchat.com, through our Support Site, whichsupports all official languages of the EU, and at Snap B.V.Keizersgracht 165, 1016 DPAmsterdam, The Netherlands The European Commission also received contact details to communicate directly with the Headof Snap’s DSA Compliance Function on all matters. Law Enforcement can contact through mechanisms described here:https://www.snapchat.com/lawenforcement Point of Contact for Users Upon designation Snap's Cross-functional DSA Governance team designated a point of contactfor users to contact Snap regarding DSA-related matters that is user friendly. 522 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Upon designation, Snap makes information on the customer service POC publicly available in aplace easily accessible to the user in a place where they would be expected to be and up todate. For general DSA inquiries, Snap can be reached through the dsa-enquiries@snapchat.com emailaddress as well as by submitting a ticket through our Support Site. The support site is available tosupport users in all official languages of the EU. Legal Representative Snap's Cross-Functional DSA Governance team has designated a legal representative (Snap B.V.)in one of the Member States where the service is provided for complying with DSA obligationsand enforcement matters. This designation includes allocation of resources and authoritiessufficient to cooperate with relevant authorities and comply with decisions issued by theEuropean Commission in relation to the DSA. We have notified our Digital Services Coordinator of the contact information for our legalrepresentative, including the name, mailing address, phone number, and email, and ensured thepublication of the information in a publicly available location. Snap has appointed Snap B.V. as its Legal Representative for purposes of the DSA. Snap’s legalRepresentation can be contacted at Snap B.V.Keizersgracht 165, 1016 DPAmsterdam, The Netherlands 6.2.10 DSA Supervisory Fee Once required Snap will pay the DSA supervisory fee following the instructions provided by theDigital Services Coordinator. In its latest assessment, the European Commission has determinedthat Snap does not meet the threshold for the supervisory fee, and Snap’s current contribution isset at EUR 0. 6.3 Privacy and Safety by Design 6.3.1 DSA Risk Management We recognize that Snap has the duty to assess new products and functionalities prior todeployment to determine whether such new products and functionalities are likely to have acritical impact on the risks identified (and therefore the mitigations specified to prevent them). 523 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT This is required under Article 34 of the DSA and reflected in other legal frameworks, including theGDPR. Snap has a Privacy and Safety by Design review process. Privacy and safety by design is acornerstone of Snap’s approach to designing and launching its products, and is built into Snap’scompliance program. Snap has an extensive privacy and safety by design review process toassess privacy and safety risks in the design and development of Snapchat. As part of its privacy and safety by design program, Snap documents a review prior to newproduct and feature releases that materially affect the privacy, safety and/or security of its users.The privacy and safety by design process is a collaborative and cross-functional process, andstakeholders from Snap’s legal and privacy engineering teams are embedded in key phases ofthe product’s development. At Snap privacy and safety by design decisions are typically made by cross-functional teams. Wehave a long standing cross functional team across Product, Eng, DSA Compliance Officers,Operations, Policy, Legal, Comms, Trust \& Safety, and Privacy teams which meets regularly toaddress risks flagged through various mechanisms such as industry reports, current events/news,internal data analyses and investigations, and feedback from regulators to assess problems,prioritize them and agree on strategy and execution plans to resolve identified risks. Internally theteam is called the Safety XFN. The team also meets in person and virtually quarterly to align onpriorities for the next quarter, and reflects on safety improvements that were made in priorquarters. These findings are also presented to senior leadership on a regular cadence. 6.3.2 Privacy and Safety by Design review process Privacy and safety by design is a cornerstone of Snap’s approach to designing and launching itsproducts, and is built into Snap’s compliance program. As highlighted above, at Snap, our missionis to empower people to express themselves, live in the moment, learn about the world, and havefun together. We believe that privacy and safety are foundational to the success of our mission. Snap already had an extensive privacy and safety by design review process to assess privacyand safety risks in the design and development of Snapchat prior to the DSA coming into force,and this continues to be the case. As part of its privacy and safety by design program, Snapdocuments a review prior to new product and feature releases that may materially affect theprivacy, safety and security of our users. 524 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 525 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 6.3.3 Holistic Digital Risk Management Formal risk assessments and mitigation obligations are being an increasingly common tool ofdigital service regulation. In the European Union, such obligations are not only imposed by theDSA, but also, for example, the GDPR (in the form of Legitimate Interest Assessments (LIAs) andData Protection Impact Assessments (DPIAs)) and also in the UK and several EU Member States,the Age Appropriate Design Code (AADC) Assessments (or their equivalent). It is important thatSnap is able to manage these, often overlapping European requirements (in addition to otherglobal requirements) in an efficient, effective and operationalised manner. In order to meet Snap’s risk assessment obligations, including with respect to the DSA, Snapcontinues to use a Digital \& Data Impact Assessment (“DDIA”) framework that combines ourprivacy, safety and security obligations into a single risk assessment. Each DDIA also coversareas related to specific features, transparency, privacy compliance, security compliance, safetycompliance, and training. The DDIA includes a template that serves as a vehicle to conduct the various risk assessments.This template supports the consideration of risk and mitigations related to a specific Snapchatproduct and includes guidance for the consideration of key factors and influencers on that risk,such as the performance of Snapchat recommender systems, the intentional manipulation of theplatform, and regional and linguistic considerations. The template also requires specificconsideration of recognised, international rights and risk assessment frameworks including the UN Convention on the Rights of the Child and the 5Cs risk categories set out by the OECD(Content, Conduct, Contact, Consumer, and Cross-cutting)225. The DDIA template is embedded with our existing privacy and safety by design process andrequires our cross-functional team to consider if a product change results in a significant impacton our existing consolidated DDIA assessment (including the DSA aspects). If so, this is requiredto be re-assessed before the product change launches. The new/updated/interim DDIA iscompleted dynamically depending on the nature of the Snapchat feature and impact of thechange being assessed. 225 https://www.oecd-ilibrary.org/science-and-technology/children-in-the-digital-environment 9b8f222e-en 526 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 6.3.4 Digital and Data Impact Assessment (DDIA) Template In order to meet Snap’s annual and ongoing holistic risk assessment obligations, including withrespect to the DSA, Snap has designed a new Digital \& Data Impact Assessment (“DDIA”)framework that combines our privacy, safety and security obligations into a single riskassessment. The DDIA templates are implemented at the product level and cover a range of requirementsbeyond the scope of the DSA. 528 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT In each case, product reviewers use the template to highlight the aspects of the risk andmitigations particularly relevant to the feature to which the DDIA relates. Through these DDIAs,Snap considers the design of its critical recommender and algorithmic systems, terms andconditions, content moderation systems, enforcement, systems for selecting and presenting adsand considerations of data related practices. The analysis from each DDIA is then combined intothis Report to enable a cross-platform view of risk. The DDIA is embedded with our existing privacy and safety by design process and requires ourcross-functional team to consider if a product change results in a significant impact on ourexisting consolidated DDIA assessment (including the DSA aspects). If so, this is required to bere-assessed before the product change launches. The DDIA is completed dynamically dependingon the nature of the Snapchat feature and impact of the change being assessed. If reviewers determine that the change does require an update to the DDIA, they will work withSnap’s Legal team (and other cross-functional Compliance team that they engage as needed) toupdate the relevant DDIA accordingly. 6.3.5 DSA Critical Impact Check Snap recognises that, as well as carrying out our annual DSA Risk Report, it must also re-assessrisk prior to deploying functionalities that are likely to have a critical impact on the risks identified(and therefore the mitigations specified to prevent them). This is required by Article 34 of theDSA, but this is also an industry standard practice to ongoing risk management and found inmany other laws requiring risk assessments (including guidance relating to DPIAs). As part of the DDIA update review, product reviewers consider whether the change amounts to acritical impact. Generally the following criteria are considered in the determination of what is acritical impact: ● Products and Features that would materially change the likelihood or severity of the risksdescribed in Section 4 and related Mitigations in Sections 5 and 6 of this Report ● Material impact to minors ● Material impact to advertising ● Material impact to algorithmic systems ● Material impact to DSA-relevant features Product reviewers use their professional judgment to determine whether a material impact isexpected based on the product-specific circumstances. They regularly consult with the DSAcompliance officers, including when they have doubts whether a new product or new featurewould have a critical impact on Snap’s System Risk Assessment and related Mitigations. 529 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT As a result, we are able to detect and manage our DSA risk assessment and mitigationobligations on an ongoing basis. 6.4 Prevalence Testing A key measure we have in place to holistically detect and manage risk of illegal and other harmfulcontent on an ongoing basis is prevalence testing i.e. testing the ‘Policy Violating Prevalence’(PVP) of Stories accessible to the public via random sampling. The sampling allows us to estimatethe percent of policy-violating views and monitor the presence of illegal and other violatingcontent on Snapchat. Through this prevalence testing, we are able to uncover blindspots andprioritize efforts to close those gaps through improvements to our proactive detectionmechanisms, infrastructure improvements and agent training. 530 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 535 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 536 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 538 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT An example of the further mitigations we have taken since our 2023 Report (and as mentioned inour Report of 2024) is an improvement to the efficacy and reduced latency of contentenforcement mechanisms. Conclusion In conclusion, prevalence testing continues to be an extremely valuable measure for our ongoingdetection and management of content risks. Our ongoing efforts to improve our prevalencetesting and our mitigations to reduce prevalence of illegal and other violating content hasresulted in further significant decreases in PVP ratesWhile our prevalence rates from oursample testing of Public content services on Snapchat are now extremely low, there is alwaysmore to do as we ultimately aim to reduce prevalence across all our violating content categoriesto as close to zero as possible. 6.5 External Request Monitoring and Review As noted in our 2024 Report, we produce a semiannual (every 6 months) Transparency Report,that captures our Community Guidelines enforcement data, law enforcement operations data,and copyright \& trademark data. The goal is to provide insight into our content moderation data,as well as our work with law enforcement and governments, in terms of how we work to keep ourusers safe. As we produce the Report, we recognize shifts in our metrics (e.g., spikes ordecreases in content and account reports and enforcements) and utilize these to informheightened awareness from our moderation teams. Internally we also continue to reviewadditional breakdowns of this data and, in preparation for our DSA compliance, we continue toreview data relating specifically to the European Union’s individual Member States. 539 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT We also continue to monitor advertising review rejections, advertising reporting andenforcements, ‘privacy, data protection and DSA’ requests and general community supportrequests. Since the DSA came into force for Snapchat on 25 August 2023, we have alsomonitored queries relating to compliance received via our dedicated dsa-enquiries@snapchat.com email address. This dedicated contact point is published on ourwebsite here, pursuant to Articles 11 and 12 of the DSA. As with our 2024 Report, we have continued to review and use this external request data tosupport the conclusions reached in this Report. 6.6 Digital Well-Being Index (DWBI) Initiative In the Spring of 2022, Snap launched a research project designed to gain insight into howGeneration Z teens and young adults are faring online. Our inaugural Digital Well-Being Index(DWBI), a measure of Generation Z’s online psychological well-being, was announced on SaferInternet Day 2023. The study asked about the risks and potential harms teens and young adultsare encountering online across all platforms, services and devices, not just Snapchat. Weconducted the research in six countries – Australia, France, Germany, India, the UK, and the U.S,which includes three of the largest European countries, two of which are in the EU) – and alsoincluded parents of teenagers between the ages of 13 and 19. In our 2024 Report, we explained that we had repeated and expanded this research in 2024(“Year Three”). For more about Snap’s Digital Well-Being Index and research, see: Our website, aswell as this explainer, the full research results, and each of the six country infographics: Australia, France, Germany, India, the United Kingdom and the United States. We took account of this andthe previous year’s research when conducting our assessment of risk and mitigations ashighlighted in our 2024 Risk Report, and have continued to do so in this Report. Lastly, it is important to note that on March 19, 2025, we hosted an event to share the latestfindings from the Digital Well-Being Index (DWBI), followed by an informal discussion withsubject-matter experts. The event received positive feedback and generated thoughtfulrecommendations for future iterations of the research. In particular, participants underscored theneed to further investigate teens’ exposure to AI-generated child sexual abuse material, as wellas the evolving role of AI tools, such as chatbots, in shaping young people's online experiences. Seven experts from four prominent organizations—5Rights, Eurochild, Missing Children Europe,and ThinkYoung—joined the conversation, offering valuable insights and perspectives thatenriched the dialogue. 540 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 6.7 Snap Advisory Groups We have continued to progress our work with the Snap Safety Advisory Board, the Snap Councilfor Digital Well-Being, and our regular outreach to civil society organisations. We haveestablished a new dedicated workshop with civil society organizations to focus specifically on ourDSA risk assessment. We have provided more detail on each of these groups below. 6.7.1 Safety Advisory Board Snap launched a new Safety Advisory Board (SAB) in April 2022 with the aim of growing andexpanding membership to include a diversity of geographies, safety-related disciplines and areasof expertise. In doing so, we initiated an application process, inviting experts and individuals fromaround the world to formally express their interest in providing guidance and direction to Snap on“all things safety.” The SAB Board was developed to educate, challenge, raise issues with, and advise Snap on howbest to keep the Snapchat community safe and counterbalance the online harms-dominatedexternal landscape. When appropriate, the SAB provides feedback on new products, features,policies, and initiatives before they are launched or released. The SAB and its individual membersdo not act as a representative or spokesperson for Snap, but rather as a collection ofindependent voices. The initiative helps to shape Snap’s approach to important safety issues andprovides Snap with strategic safety-related advice and guidance as Snap grows. Our Advisory Board currently stands at 19 members, based in 11 countries and representing 12different geographies and regions. Four of our members are based in the UK. The boardcomprises 16 professionals from traditional online safety-focused non-profits and relatedorganizations, as well as technologists, academics, researchers, and survivors of online harms.Members are experts in combating significant online safety risks, like child sexual exploitationand abuse and lethal drugs, and have broad experience across a range of safety-relateddisciplines. In addition, the Board has three members who are young adults and youth advocates.We selected these applicants to ensure the Board has ready access to the all-important “youthvoice” and viewpoint; to make certain a portion of the Board includes committed Snapchat users;and to seek to balance professional views with practical perspectives from a core demographicof the Snapchat community. The SAB meets three times annually: twice virtually and oncein-person at Snap headquarters for an in-depth strategy session to help prepare Snap for thecoming year’s planning. In June 2025, at the third in-person board meeting of the SAB, members were divided intoworking groups to discuss various topics such as age assurance, screentime, and financialsextortion. They were also given updates on some new efforts, including our youth-focusedprogram (see Snap Council for Digital Well-Being below). The SAB’s input and feedback wasmemorialized and shared with Snap executives and others that were unable to attend in-person. 541 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 6.7.2 Snap Council for Digital Well-Being Snap formally launched a new youth-focused program in January 2024 - Snap's first “Council forDigital Well-Being (CDWB)”. The Council is a pilot program in the U.S. designed to encouragesafer online habits and practices among teens with the aim of having these young peoplechampion their knowledge and insights in their schools and communities. For the first interaction of this program, we opened applications from U.S.-based teens, aged 13to 16. The inaugural cohort was selected and announced in May. Following two virtual monthlymeetings, the group traveled to Snap HQ in Santa Monica, California, USA, in July 2024 for thefirst Council Summit. The 2-½-day program consisted of breakout sessions for both the teencohort and their parents/chaperones, full-group discussions, and guest speakers. The teens alsogot a glimpse into working at a technology company, as they were treated to a 90-minute“speed-mentoring” session with 18 Snap employees representing different roles and teams. The Summit yielded interesting conversations and insights on topics such as online pitfalls,parental tools, and the differences and similarities between digital and in-person social dynamics.By the end of the Summit, the full group, chaperones included, was extremely motivated to bemore involved in their own local communities and to act as ambassadors for online safety. Weshared with them some of our outreach material to aid their efforts, including the belowinfographics on reporting and Snap Safety Milestones: 542 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT The inaugural U.S. program will conclude this summer, and we are fashioning an “alumninetwork” to continue to update the teens on major safety initiatives and developments and toencourage their continued advocacy. We are now replicating these efforts in Europe. We recently finalized the selection process for thefirst European (including the UK) Council for Digital Well-Being (“E-CDWB”) and held our firstEuropean Teen Council for Digital Well-Being Summit in Amsterdam at the end of June 2025. TheE-CDWB is made up of 14 young people aged 13 to 16 and three members are from the UK. TheSummit hosts the teens and their parents/chaperones to hear from about their online life, thethings they enjoy, the value it brings to them, the worries they have and their ideas for the future. 543 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT We will be looking to incorporate their thoughts into future plans for Snapchat, and our riskassessments. Similar efforts are also underway in Australia. 6.7.3 Regular External Engagement In addition to the deep investment we are making in our SAB programme Snap also regularlyengages with external experts and civil society organisations. Snap periodically consults a cadreof some 50 safety experts from around the world on new product features and functionality,policies, and initiatives. Snap also conducts periodic internal trainings and learning-sessions,inviting external experts to help inform and educate Snap personnel working in a variety of safetydisciplines about the overall risk landscape and Snap’s potential exposure. This includescollaborations with the U.S.-based National Center for Missing and Exploited Children (NCMEC)on the topics of sextortion and improving CyberTip reports to NCMEC, as well as smaller,executive-attended sessions with WeProtect Global Alliance, IWF, Thorn, and others. Snap willcontinue to invest in these and other external partnerships and relationships to help bolsterinternal knowledge and awareness of the overall risk landscape. 6.7.4 Dedicated DSA Risk Assessment Workshop On July 10, 2024, Snap held our first dedicated DSA Risk Assessment and Mitigation workshopwith civil society organisations (CSOs) in Brussels and online. The session provided a detailedoverview of Snap’s 2024 DSA Risk and Mitigation Assessment Report and aimed to collectfeedback from relevant privacy and safety CSOs based in Brussels and across EU MemberStates. This initiative also served as a follow-up to the European Commission’s workshop onsystemic risk mitigation held on May 7, during which several stakeholders expressed interest inmore structured opportunities to provide input to platforms. The workshop brought together 19 experts representing 14 NGOs. Participating CSOs: ChildFocus, COFACE-Families Europe, E-Enfance (3018), ECPAT International, Eurochild, EuropeanParents' Association, European Schoolnet, FAFCE, Media Council for Children \& Youth (SIC)(Medierådet for Børn og Unge), Missing Children Europe, Offlimits, Point de Contact,Saferinternet.at, ThinkYoung. Participants appreciated the opportunity to engage deeply with Snap’s risk assessment processand shared constructive feedback that will inform future reports. This included in particular: ● Requests for additional clarity on the scope of risk categories - for example with respectto well-being risks affecting minors and adults. In response to this feedback, we haveincluded a more expansive harm description for each harm in Section 4. ● Request for more risk-specific mitigation highlights. In response to this feedback, wehave merged the ‘highlights’ paragraphs into the specific mitigations table under the‘Snap’s mitigations’ heading for each harm in Section 4. This streamlines the Report and 544 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT makes it easier for readers to locate the corresponding detail we have provided about ourspecific mitigations in Section 5. ● Request to explain how we reference frameworks such as the UN Charter on the Rights ofthe Child in our risk assessments. In response to this feedback, we have updated Section6.3 (Privacy and Safety by Design) to be clear that Snap has already embeddedwell-known, internationally recognised frameworks into its Privacy and Safety by Designassessment processes, including the UN Convention on the Rights of the Child and the5Cs risk categories set out by the OECD (Content, Conduct, Contact, Consumer, andCross-cutting)227. Consideration of these frameworks is specifically required by our holisticDigital \& Data Impact Assessment templates used to assess critical product updates. ● Request to ensure we have explained how we have assessed and mitigated the risksrelating to harmful AI-generated content, including content affecting body image. Wealready cover this in Section 5.9 (Content Authenticity). This will become clearer to civilsociety organisations when our 2024 Report, and this Report, are published. Participants praised Snap’s use of data to intelligently target safety interventions and supportmechanisms. We were recommended to build on this strong element of the company’s riskmitigation approach by further expanding in-app support resources and reminder features. This issomething that we will be reviewing during the following year. We found this workshop helpful, with the vast majority of participants focused on constructivedialogue and developing practical solutions to achieve common goals. Snap intends to continueand build on this engagement with participating CSOs to inform future DSA risk and mitigationassessments and provide transparency on how their input is reflected. 6.8 Audit We completed the first external DSA audit of Snap’s compliance with its obligations underChapter 3 of the Digital Services Act for the audit period between July 1st 2023 and June 30th2024 pursuant to Article 37. 227 https://www.oecd-ilibrary.org/science-and-technology/children-in-the-digital-environment 9b8f222e-en 545 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 7\. Conclusion This Report has been prepared to meet Snap’s obligation under Article 42(4) of the DSA and setsout the results of: (i) the risk assessment conducted by Snap pursuant to Article 34(1); and (ii) thereview of the specific mitigation measures that Snap has put in place to assess whether theymeet the requirements of Article 35(1) DSA. The risk assessment conducted by Snap identified, analyzed and assessed in accordance withArticle 34(1) DSA any systemic risks in the European Union stemming from the design, functioningor use of Snapchat’s in-scope services. Snap has also reviewed the specific mitigation measuresthat it has put in place to ensure they are “reasonable, proportionate and effective” for thespecific systemic risks identified by its risk assessment as required by Article 35(1). The results ofthe risk assessment and mitigation review are set out in Section 4 of this Report. The specificmitigation measures put in place by Snap are further detailed in Section 5 and 6 of this Report asrequired by Article 42(4). The Report shows that we have reasonable, proportionate and effective mitigation measuresin place and we continue to monitor a few areas to confirm that if additional measures arerequired Snap will act accordingly, as follows: 1. Dissemination of illegal or violating content: Since our previous Reports, we haveobserved a further substantial reduction in the prevalence of content that is illegal orotherwise violating Snap’s Terms being disseminated on Snapchat’s online services ingeneral ). We have observed PVP rates for thiscontent to now be at a very low levelcompared to the prevalence of this content on websites and other onlinespaces. As we have previously noted, historical studies suggest that around 4% ofwebsites have adult sexual content which is much higher than the level of this content onSnapchat’s in-scope services. This year, all of our illegal or other violating contentcategories were observed from our testing to have a prevalence rate to fall within our 546 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT lowest relative prevalence category (which is a rate of 0.049% or below). Within this verylow level of dissemination in general: a. We continue to categorize two dissemination risk areas as falling within Level 1 riskprioritization for Snapchat’s in-scope services: (i) child sexual abuse material, and(ii) sale of drugs. We have again confirmed we have reasonable, proportionate andeffective mitigation measures for all two of these categories. As a result of theseongoing measures, these two categories are still assessed to fall within our lowestlikelihood category of the risks identified by Snap. b. We have continued to categorize five dissemination risk areas as falling withinLevel 2 risk prioritization for Snapchat’s in-scope services: (i) Sale of Weapons, (ii)Terrorist Content, (iii) Adult Sexual Content, (iv) Harassment and Bullying and (v)Self-Harm and Suicide, due to the risk of serious harm each may cause. We haveagain confirmed we have reasonable, proportionate and effective measures inplace for all five of these categories. As a result of these measures all five areassessed to fall within our lowest likelihood category of the risks identified bySnap. This is a change from our 2024 report, when bullying and harassment wasassessed to fall within our medium relative likelihood category. In the case toterrorism content, we have continued to observe a slight increase in prevalencesince our previous reports. It is normal to expect some natural fluctuation whenthe PVP percentages are so low, as they are for terrorism content, and theincrease is not considered statistically significant at this time. We have alsomade some improvements and expanded our prevalence testing to cover newareas that may have resulted in a slight increase in the volume of terrorismcases identified during our prevalence testing. The PVP percentages forterrorism remain extremely low relative to other harms and we continue toclosely monitor prevalence levels for this harm as one indicator of new orincreased terrorism threats on Snapchat. c. We have continued to categorize eight dissemination risk areas as falling withinLevel 3 risk prioritization for Snapchat’s in-scope services: (i) illegal Hate Speech,(ii) sale of prohibited products or services (excluding Drugs and Weapons); (iii)intellectual property infringements, (iv) other Adult Sexual Content,228 (v) Violent orDangerous Behaviour, (vi) Harmful False Misinformation, (vii) Fraud and Spam and(viii) content relating to Other Illegal Activities. We have again confirmed we havereasonable, proportionate and effective measures in place for all eight of thesecategories. As a result of these measures all eight of these risk areas are assessedto fall within our lowest likelihood category of the risks identified by Snap. This is a 228 With regard to the Adult Sexual Content category, sexual crimes are treated as Level 2, and other forms of AdultSexual Content are prioritized as Level 3. See Section 4.1.6 for more detail. 547 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT change from our 2024 report, when fraud and spam and adult sexual contentwere assessed to fall within our medium relative likelihood category. 2. Negative effects on EU Fundamental Rights: We continue to categorize: (a) three risks tofundamental rights as falling within the Level 1 priority category for Snapchat’s in-scopeservices: (i) Human Dignity, (ii) Data Protection and (iii) Children’s Rights; (b) one risk asfalling within the Level 2 priority category: Private Life; and (c) three risks as falling withinthe Level 3 priority category: (i) Right to Freedom of Expression, (ii) Right toNon-Discrimination and Freedom of Religion and (iii) Right to Consumer Protection. Wehave again confirmed we have reasonable, proportionate and effective measures in placefor all of these categories. We continue to assess Snapchat’s in-scope services againstthe Commission’s newly published guidance on Art 28 to ensure a high level ofprivacy, safety and security for minors to assess if further industry measures areneeded to address risks to child rights. 3. Negative effects on Public Security: We continue to categorize three risks to publicsecurity within the Level 3 priority category for Snapchat’s in-scope services: (i) NegativeEffects on Democratic and Electoral Processes; (ii) Negative Effects on Civic Discourseand (iii) Negative Effects on Public Security. We have again confirmed we havereasonable, proportionate and effective measures in place for all of these categories. 4. Negative effects on Public Health: We continue to categorize: (a) two risks to PublicHealth within the Level 1 priority category for Snapchat’s in-scope services: (i) NegativeEffects on Children; and (ii) serious negative consequences on Physical and MentalWell-Being; (b) one risk within the Level 2 priority category for Snapchat’s in-scopeservices: Negative Effects on Gender-Based Violence; and (c) one risk within the Level 3priority category for Snapchat’s in-scope services: Negative Effects on Public Health. Wehave again confirmed we have reasonable, proportionate and effective measures in placefor all of these categories. As above, we continue to assess Snapchat’s in-scopeservices against the Commission’s newly published guidance on Art 28 to ensure ahigh level of privacy, safety and security for minors to assess if further industrymeasures are needed to address risks to the protection of minors. It is Snap’s mission to reduce and maintain a lower prevalence of illegal and otherwise violatingcontent on Snapchat’s inscope services. We have beensuccessful in increasing the granularity of data that we rely on, which we have incorporated intothis Report. We will continue to progress this action to ensure that risks can be tracked with evengreater precision across in respect of each of Snapchat’s in-scope services. 548 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Regarding our Mitigations, since our previous Reports, we have worked to evaluate our mitigationmeasures against new guidance from the Commission (in particular the Commission’s Guidelineson Article 28, the Guidelines for providers of VLOPs and VLOSEs on the mitigation of systemicrisks for electoral processes and the updated EU Code of Conduct to counter illegal Hate Speechonline). We have also updated the information on our measures to reflect the increased use ofgenerative AI technology such as updates to our content moderation policies (note that many ofthese measures relate to out of scope services on Snapchat). Where required by the DSA, wehave made available our mitigations in all of the languages of the European Union and in all othercases in every language in which Snapchat is available. Since our previous Reports, we did not identify any deployed functionalities that were likely tohave a critical impact on our assessment of risks and mitigations pursuant to Articles 34 and 35 ofthe DSA. As described in the Ongoing Risk Management section above, our DSA GovernanceTeam continues to regularly evaluate the effectiveness of its measures as we look to maintain orfurther reduce prevalence, detect any new risks, assess any deployed functionalities for criticalimpacts and determine whether further mitigating measures might be required. In summary, we have carried out our third annual risk assessment of Snapchat’s in-scopeservices required by Article 34(1) of the DSA. We have observed further significant reductionsin the prevalence across our illegal and otherwise violating content categories. We continue toconclude that we have reasonable, proportionate and effective mitigation measures, tailoredto the specific systemic risks identified, as required by Article 35(1) of the DSA. However,there are two high risk categories that we continue to monitor to ensure their correspondingmitigations continue to be effective. 549 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 8\. Final Words This is the third year in which VLOPs have had to produce a report on their assessment of risksand the specific mitigation measures they have put in place. Snap has continued to take acomprehensive approach to the obligations in Articles 34, 35 and 42. As in our 2024 Report,although there is still no settled legal definition of ‘systemic risk’, we have again adopted theposition that all the risks identified in the DSA are systemic to online platforms (which is why theyhave been identified in the DSA). We are still then looking to ensure we have appropriateplatform wide measures in place in general, taking additional steps for specific risks, certainservices and high priority risks as necessary. As noted in our 2024 Report, our position reflects Snap’s own internal approach to riskmanagement and our core values to be kind, smart and creative. We have always taken theassessment of privacy and safety risks and mitigations seriously and this is demonstrated again inthis Report which concludes that Snapchat represents an even lower risk profile than identified inour 2024 Report. This is due to its unique design and function, but also in particular to the effortsof our cross-functional teams who have worked hard to provide high levels of privacy, safety andsecurity for all our users and further substantial falls in the risks specifically referred to in the DSA.We are particularly proud of the further 46% decrease in the overall prevalence rate for our illegaland harmful content categories. We are pleased to have confirmed that we meet all of the recommendations for risk assessmentand mitigation reports provided by the Commission in its workshop on 7 May (as set out in the Foreword). We have also introduced some enhancements to further improve our approach. Welook forward to again receiving feedback from the Commission on this third Report, as well as thepublication of our second Risk Assessment and Mitigation Report and our Audit Report. 550 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Annex ContentsAnnex................................................................................................................................................... 552 Community Guidelines............................................................................................................................... 553 Overview.................................................................................................................................................553 Community Guidelines: Explainer Series.............................................................................................. 555 Sexual Content......................................................................................................................................555 Threats, Violence \& Harm.................................................................................................................. 557 Hateful Content, Terrorism and Violent Extremism..................................................................... 559 Harassment and Bullying.................................................................................................................... 561 Illegal or Regulated Activities............................................................................................................563 Harmful False or Deceptive Practices............................................................................................ 565 Severe Harm..........................................................................................................................................568 Snapchat Moderation, Enforcement, and Appeals......................................................................568 551 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Community Guidelines Overview 552 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 553 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Community Guidelines: Explainer Series Sexual Content Community Guidelines Explainer SeriesUpdated: February 2025 554 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Threats, Violence \& Harm Community Guidelines Explainer SeriesUpdated: February 2025 556 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Hateful Content, Terrorism and Violent Extremism Community Guidelines Explainer SeriesUpdated: February 2025 558 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 559 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Harassment and Bullying Community Guidelines Explainer SeriesUpdated: February 2025 560 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 561 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Illegal or Regulated Activities Community Guidelines Explainer SeriesUpdated: May 2025 562 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 563 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Harmful False or Deceptive Practices Community Guidelines Explainer SeriesUpdated: February 2025 564 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT ● 565 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT Severe Harm Community Guidelines Explainer SeriesUpdated: December 2023 Snapchat Moderation, Enforcement, and Appeals Community Guidelines Explainer SeriesUpdated: March 2025 567 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 568 CONFIDENTIAL - SNAP 2025 DSA RISK AND MITIGATION ASSESSMENT 569