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This report is primarily based on data collected through fieldwork interviews. These interviews involved 62 practitioners and experts from three broad respondent groups defined by professional categories.
- Staff of competent authorities tasked with applying or supporting the application of the different provisions of the regulation (e.g. law enforcement authorities and media regulators). Experts responsible for different aspects of the regulation (issuing removal orders, conducting scrutiny of cross-border removal orders, etc.) were interviewed. The focus was primarily, but not exclusively, on authorities that already have practical experience in applying the regulation.
- Staff of HSPs involved with the regulation, or more broadly, in dealing with illegal content. The HSPs were selected to cover companies of different sizes, types and business models, and include those that already have practical experience with applying the regulation (e.g. receiving removal orders) and those that do not.
- Experts from civil-society organisations and academic experts familiar with the regulation and related areas. These experts were selected to cover a wide range of expertise relevant to the regulation, including in the areas of privacy, freedom of expression, human rights and counterterrorism, capacity-building work with HSPs, and online content moderation.
All interviews took place in person and online between July 2024 and January 2025 and were conducted directly by FRA staff. Each interview was conducted with one or more interviewees from the same organisation and lasted on average 90 minutes.
Interviewees replied orally to questions from a predefined questionnaire, sharing their experience and views as regards fundamental rights challenges, concerns and good practices related to the application of the regulation against the backdrop of the broader picture of addressing the dissemination of terrorist content online. The interviewers could ask follow-up questions or request clarifications and encouraged respondents to speak freely and draw on their personal experiences. Interviews were audio-recorded, if the respondent consented, and were documented using an interview-reporting template in full compliance with FRA’s data protection standards.
All interviews took place under the guarantee of anonymity of individual interviewees and the organisations they represent. This was necessary given both the confidentiality of counterterrorism work and the sensitivity of the topic for HSPs.
Therefore, this report does not list individual interviewees or the authorities, HSPs or civil-society organisations they are affiliated to. When reporting on the views shared or information provided by a particular interviewee, the report refers to them only by the professional group they represent. This allows for comparing the experience across the three professional groups where relevant. Given the clearly defined competences for applying the regulation at the national level, specific Member States where interviews took place are not listed in order not to jeopardise this anonymity. Where references are made in this report to particular Member States, HSPs or other organisations, these are based on open-source material or information collected through desk research, which covered all 27 Member States (see further below), not on interviews.
The fieldwork was supplemented by limited desk research conducted by FRA’s multidisciplinary research network, Franet, between January and February 2025. The desk research collected basic information about the implementation of the regulation’s requirements into national legal and institutional frameworks in all 27 Member States.
In addition, Europol (i.e. the EU Internet Referral Unit of the European Counter Terrorism Centre) provided FRA with information on the functioning and use of PERCI, which is managed by Europol and supports Member States in applying the regulation.