Introduction
On June 4th, the Oversight Board (OSB) published its first case decision on disabled accounts, extending “its mandate beyond individual content decisions.” Although it agreed with Meta’s decision to permanently disable the account in case, following egregious violations of the company’s policies, the OSB made it abundantly clear that the focus of its decision is elsewhere.
Instead of merely addressing the facts of the case at present, the Board remarked on the need for transparency on account enforcement rules, due process, and appeals. Relying on more than 750 public comments submitted for this particular case, as well as on numerous individual complaints about disabled accounts that it had received since it first started hearing cases in 2020, the Board highlighted the shortcomings of Meta’s policies when it comes to account disablement.
The decision not only offers recommendations and good practices to Meta, but also urges other social media companies to comply with them too. We welcome the decision, which incorporates many of the recommendations SMEX provided in our public comment on the case.
Women at the Center of Online Violence Campaigns
The initial call for submissions did not include detailed information about the specific facts about the case, making it harder for us to judge whether Meta’s decision to permanently disable the account was in line with the company’s publicly stated rules. The OSB’s decision shed some more light on the specificities of the case, underscoring how inefficient Meta’s processes are.
Despite Meta’s automated content moderation and user reporting systems, a woman journalist who had been targeted by the eventually disabled account had to leverage her connections within the company to get the content reviewed, in a demonstration of Meta’s ongoing failure to address serious cases of harassment on the platform.
Citing a March 2026 report by the UN Special Rapporteur on Human Rights Defenders, the Board highlighted the heightened risk of online violence that women users face, emphasizing the possibility of it turning into a credible threat or even real-life harm. Another December 2025 UN report demonstrated the interplay between online and offline violence against women.
In the WANA region, women journalists and human rights defenders are constantly attacked both online and offline. Smear campaigns, doxxing, bullying, and sexual harassment are just a few forms of online violence that women users deal with. Just in Lebanon, about 80% of women face digital violence.
In April 2025, SMEX published a report analyzing the challenges feminist activists in Lebanon encounter, as well as potential forms of resistance. SMEX’s Digital Safety Helpdesk has received hundreds of cases of content targeting women users over the years, attesting to the severe danger women users are exposed to. In just the first half of 2026, SMEX already received 106 such cases. Platforms’ response times to reports of online violence have worsened, and constructive engagement on behalf of the companies has shrunk due to changed priorities and depleted resources.
Striking a balance between the rights and freedoms of both users in the case, the Board upheld Meta’s decision to permanently disable the violating account. The user had repeatedly violated Meta’s Violence and Incitement, Bullying and Harassment, Hateful Conduct, Adult Nudity and Sexual Activity Policies. The gravity of these violations was such that disabling the account was in line with the principle of proportionality in International Human Rights Law.
Meta’s Content Moderation Deficiencies Erode User Trust
The Board emphasized in its decision that although Meta “got it right” this time, the systemic issues related to the company’s transparency, due process, and redress mechanisms are quite persistent. Information about how account restrictions work is scattered across different policies. In our submission, we urged Meta to explain in each of its policies when a violation could result in an account being permanently disabled. Notifying the user about any action taken against them is also an important element of transparency. This notification should include a detailed explanation of the reasons behind the account restriction and comprehensive information on the appeal process.
The Board expressed concerns about due process failures in relation to both users targeted online, and users whose accounts have been restricted. Reporting mechanisms were also questioned: if a user needs to reach out to their personal contacts within the company–as in this case–to report violations of Meta’s policies, then these mechanisms seem to be failing royally. In our view, this constitutes a violation of the principle of non-discrimination, as recognized by the UN Guiding Principles on Business and Human Rights (UNGPs), endorsed by Meta.
It also draws a rather bleak picture of the company’s content moderation practices and raises concerns about its disregard of human rights. According to the Board, Meta’s failure to swiftly identify the potential threats against the woman journalist contributed to her being exposed to an “intolerable risk for a period,” increasing the likelihood of “credible threats” to materialize into offline harm.
Similarly, throughout the years, the Board has received a massive amount of individual complaints about wrongful account disablements. Many of these complaints shared common themes and revealed how deficiencies in Meta’s due processes affect users’ rights.
Citing its decision on restricting accounts of public figures during civil unrest, the Board stressed the need for “a significant but time-bound suspension.” In its present decision, the Board revealed that “Facebook accounts can also be suspended for increasing periods of time after additional violations, but this penalty is not applied to Instagram accounts.” This information isn’t available in Meta’s Transparency Center. Introducing “intermediate options” for account restrictions applied on Instagram too could potentially limit violations, while offering the violating user the chance to rectify their behavior. Meta should implement a more fair and proportionate penalty system.
The OSB’s Recommendations to Meta
The Board provided five categories of recommendations to Meta:
- Improve Due Process for the Targets of Violent Threats
- Improve Due Process for Users Whose Accounts are Disabled
- Clarify Policies on Account Suspensions and Disablement
- Create a Framework to Guide Permanent Disablement Decisions
- Ensure Proportionate Penalties
Some of these recommendations are directly in line with the suggestions we made in our submission, in which we provided certain examples of how they could be fulfilled. To improve due process for both targets of violent threats and users whose accounts are disabled, Meta should include clarifying information about disabling accounts in its Transparency Center. The company should also notify users about any decision taken against their account, and better enforce content moderation policies and practices, by investing in both more human moderators and more accurate automated systems.
It is also crucial that the company revamps its engagement with civil society. Insights from the ground are essential to assess whether certain content may result in offline harm, and consulting with local CSOs would allow for invaluable insights.
Due process for disabling accounts demands that the principles of legality, legitimate aim, necessity, and proportionality are respected when it comes to restricting an account. Our submission provided a detailed analysis on how these requirements can be met. Meta itself has publicly committed to upholding the UNGPs and has endorsed the Santa Clara Principles on Fairness and Accountability in Content Moderation. The latter require that “human rights and due process should be taken into account and integrated by companies throughout the process of content moderation.”
Clarifying policies on account suspensions and disablement is another core point of the OSB’s decision. Meta’s “restricting accounts” section of its Transparency Center lacks clarity, solely referring to restrictions applied on Facebook, and completely omitting any explanation of how account restrictions work on Instagram. As noted in the OSB’s decision, to obtain a comprehensive understanding of Meta’s approach to account disablement, one has to delve into multiple policies. This puts a considerable burden on the user. Besides, the lack of clarity can result in inconsistent practices.
It is our view that Meta should concentrate all information related to account disablement in one policy, which users could access easily. This policy should include details about the different penalties, as well as the platform’s explicit responsibility to notify the user about any action taken against their account. It should also incorporate a comprehensive reasoning for such a decision, and information about the appeal process.
What is currently lacking, but would enhance Meta’s due processes, is a Framework to Guide Permanent Disablement Decisions. The Board recognized the importance of a case-by-case review. It also noted that undefined factors such as “user behavior and recent activity” can produce diverging decisions. We maintain that, to establish such a framework, the company should take into account the OSB’s previous decisions detailing what a clear and accessible appeals process would look like. This process would necessarily introduce a prohibition for the same human reviewers to assess appeals against their own decisions, as the Board recommended in its October 2025 Reporting on Somaliland Current Affairs decision.
Apart from the OSB’s previous recommendations, we urge Meta to consider both soft and hard law when drafting the Framework. The Santa Clara Principles provide extensive guidance on what an efficient appeal process should entail, while the EU’s Digital Services Act Article 17 introduces an obligation for platforms to provide a statement of reasons for every decision taken against an account, with a special mention of “clear and user-friendly information on the possibilities for redress.”
The Board also recommends that Meta ensure proportionate penalties. Between restricting the possibility to broadcast live and suspending an account on Instagram, there should be a set of measures, proportionate to each violation. In a similar manner, we strongly urge Meta to replace its current approach and make appeals available for any violation.
A Model Decision for all Online Platforms
Aside from extending the Board’s mandate to account suspensions, this OSB decision is also unique in another way. The Board seizes this opportunity to encourage other social media platforms to consider a set of Account Governance Good Practices, including coordination for addressing violent threats across platforms. Online gender based violence, for instance, is unfortunately a common issue on different platforms, with illegal content published on one platform quickly spreading across the others.
Last but not least, Meta, and all other companies should respect their transparency obligations as stipulated in Principle 21 of the UNGPs, DSA Articles and soft law provisions, such as the Santa Clara Principles and the GNI Principles.
Conclusion
This landmark OSB decision touches upon a wide range of Meta’s systemic failures and could provide a useful roadmap for both Meta and other social media companies on how to properly address issues such as online gender violence, user rights to redress, transparency shortcomings and coordination among different platforms to ensure better account governance practices. OSB decisions may lack binding force, but Meta should honor its human rights responsibilities by incorporating the Board’s recommendations into its policies and practices.
