Trust and safety’s double squeeze: DSA oversight intensifies as U.S. tightens visa restrictions

The European Commission’s recent €120 million fine against X marks a pivotal moment for the Trust & Safety (T&S) ecosystem. For the first time, regulators have imposed a high-stakes penalty under the Digital Services Act (DSA) for failures in transparency, user protection, and accountability. While enforcement actions were anticipated, the scale and assertiveness of this penalty signal a reshaped operating environment, one where compliance expectations are sharper, timelines are shorter, and tolerance for ambiguity is shrinking.

Additionally, with ongoing investigations into Meta, TikTok, and other very large platforms (VLOPs), regulators are making clear that transparency failures, inadequate user protection, and weak governance will carry material consequences.

In the wake of heightened regulatory scrutiny in Europe, the U.S. political environment has taken a sharply divergent stance, framing these actions as censorship. The U.S. is narrowing access to global talent, most visibly through new restrictions on H-1B and L-1 mobility.

Policies that scrutinize and even deny visas for individuals involved in content moderation and fact-checking have emerged at the same time when platforms are being told to demonstrate deeper cultural, linguistic, and contextual competence. This creates a unique structural collision, as regulators now expect more local nuance and greater auditability at the very moment when pipelines for multilingual and expert talent are tightening.

In effect, platforms need to do more with less. While there are heightened regulatory obligations on one side, there is diminishing access to specialist talent on the other. The convergence of these pressures is redefining how enterprises, platforms, and service providers must evolve their T&S operating models. As a result, the operating landscape is becoming significantly more complex, requiring both short-term adaptation and long-term strategic redesign.

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Implications for platforms

As regulatory pressure intensifies and the ban on visa comes into enforcement, platforms will face multi-dimensional operational challenges. These challenges will not only affect day-to-day moderation execution but also long-term governance maturity, risk exposure, cost of operations, and user experience as follows:

Moderation backlogs will grow

Reduced access to multilingual and culturally aware moderators increases decision queues, slows high-risk content review, and drives up escalations and appeals

Hiring delays and limited availability of niche-language specialists lead to unresolved cases to accumulate and prolong end-to-end moderation turnaround times

Cost of operations will increase

Visa restrictions force platforms to hire specialist and senior-level roles domestically in the U.S., where labor and operational costs are significantly higher. This would have a cascading effect on the training and ramp-up cost of enterprises

Functions previously staffed through lower-cost global talent now shift to high-cost markets, increasing per-case review costs and overall spending

Audit readiness and governance maturity will weaken

Limited availability of senior policy and governance experts undermines the consistency, explainability, and audit-readiness of moderation decisions and documentation

Gaps in expert oversight also lead to inconsistent policy application across markets, and fragile compliance governance during regulatory reviews

Edge-case decisions will become more sensitive

Context-heavy content such as political speech, coded extremism, satire, and real-time conflict narratives require nuanced cultural, legal, and historical interpretation that talent shortages directly erode

With fewer specialists, more borderline cases are escalated, inconsistently ruled, or even misclassified, heightening regulatory exposure and operational risk

Fines, reputational risk, and user friction will rise

Weak compliance execution increases the probability of missed removal deadlines and over-reliance on imperfect automation

Operational lapses translate into quantifiable outcomes such as higher regulatory penalties and degraded user trust

What does this mean for enterprises and service providers ?

These platform-level pressures cascade directly into how enterprises and outsourced T&S vendors must design their delivery models. The old playbook of relying heavily on a single geography, low-cost hubs, or ad-hoc specialist teams is no longer sufficient. A more resilient, diversified, and proactive operating approach is required.

Accelerate automation as a strategic buffer

With talent shortages automation becomes essential for risk mitigation, handling first-level triage, gray-area decision support, quality checks, and generating regulator-ready logs at scale

Automated workflows also reduce dependence on high-cost markets, such as the U.S., by shifting routine and repeatable tasks away from scarce senior talent

Adopt multi-shore, multi-vendor delivery models

Re-evaluate and rebalance shoring strategy to reduce dependence on any single region and ensure access to scarce language talent

Adopt a multi-vendor model with overlapping language coverage to avoid single-provider risk

Expand into strategic nearshore hubs

Nearshore locations with strong multilingual pipelines (Latin America (LATAM), Middle East and Africa (MEA) provide scalable, compliant access to languages and culturally proximate talent

Evaluate if gig-based and contractor models can supplement capacity for niche languages, burst demand, and specialized tasks

Increased scrutiny during vendor selection

Enterprises will assess providers on governance maturity including regulatory compliance support, audit-ready documentation, jurisdiction-specific policy expertise, and data residency capabilities

Vendors must demonstrate operational depth including language coverage, hybrid Artificial Intelligence (AI)-human workflows, and multi-geo delivery options

Build resilience into the full T&S operating model

Resilience now requires distributing policy and review teams across multiple geographies to offset U.S. talent constraints and ensure access to linguistic and context expertise despite visa restrictions

Organizations must plan for scenarios where visa restrictions tighten further, multilingual talent becomes scarce, and regulatory requirements expand further

Final thoughts

The convergence of escalating regulatory demands and shrinking access to global talent has created a fundamentally new operating reality for T&S. Going forward, enterprises and service providers must reassess how they will navigate this more complex environment, particularly as regulatory expectations tighten while talent pipelines contract. The path ahead requires rethinking how to source localized, diversified talent that can interpret cultural nuances, while also ensuring compliance with increasingly fragmented global legislations.

There is no single playbook for how these shifts will unfold. Much will depend on how regulations evolve, how political dynamics influence talent mobility, and how effectively automation can support parts of the moderation burden. It remains to be seen how these changes will affect enterprise operations and enterprises will need to monitor changes closely, anticipate where operational disruptions may emerge, and evaluate how their current delivery models might be exposed.

To discuss this further or other topics relating to Trust and Safety, please contact Rakshit Hooda ([email protected]) and Dhruv Khosla ([email protected]).

If you found this blog interesting, check out our The top 10 CXM predictions: how 2025 really played out  – Everest Group Research Portal, which delves deeper into another adjacent topic, CXM.