Board Provides Country-Level Factors to Guide Community Notes Rollout
March 26, 2026
Today, the Board published a policy advisory opinion in response to Meta’s request for guidance on the specific factors the company should consider when deciding whether any country should be omitted from its planned expansion of community notes outside the United States.
Read the Executive Summary of the policy advisory opinion below. To read the full version, click here.
Executive Summary
The Oversight Board finds that community notes could enhance users’ freedom of expression and improve online discourse on Meta’s platforms if implemented with sufficient scale, speed and safeguards against manipulations. However, in certain circumstances – including in repressive human rights regimes, in particular electoral contexts and in ongoing crisis and conflict situations – expanding community notes to countries outside the United States could also pose significant human rights risks and contribute to tangible harms that Meta has a responsibility to avoid or remedy.
The Board is also concerned about coordinated disinformation networks potentially abusing community notes, and the risk that community notes could, in certain contexts, privilege dominant political, ethnic or linguistic groups, and marginalize minority groups.
The likelihood and severity of these potential human rights risks and their adequate mitigation depend greatly on the design and functionality of the community notes product in each context. The effectiveness and adequacy of Meta’s mitigation measures regarding some of these risks – for example, to ensure contributor anonymity and protect against those who try to game the system – will need to be verified through an ongoing process of data gathering and reporting on how community notes function in practice.
In addition, insofar as Meta envisions community notes as its primary way to address misinformation falling short of its threshold for removal (i.e., where there is not a likelihood of contributing to the risk of imminent physical harm or to interference with the functioning of political processes), the Board finds that the program’s design may limit its ability to accomplish that goal. Delays in note publication, the limited number of published notes and its dependence on the broader information environment’s reliability raise serious doubts about the extent to which community notes can meaningfully address misinformation linked to harm.
The Board recommends criteria that Meta should use to assess when these human rights risks may warrant withholding community notes from a particular market. The Board’s recommendations are necessarily conditional because Meta’s questions cannot be addressed conclusively without sufficient testing and detailed data about how the community notes algorithm functions in real-world situations and in relation to other misinformation tools. For that reason, the Board also recommends ongoing data gathering, assessment and reporting regarding the functionality of community notes, related to those criteria.
Background
On November 19, 2025, the Board announced that it had accepted a request from Meta for guidance on the specific factors the company should consider when deciding whether any country should be omitted from its planned expansion of community notes outside the U.S., as local context might impact the program’s operations. Additionally, Meta asked the Board how to weigh such factors in relation to one another, in a way that can be applied on a large scale.
In its request, Meta said the community notes program is in an “early stage of product development” and the company possesses “limited data from the U.S. beta rollout.” Meta described this rollout as a period of “testing and refinement” that may result in the form of community notes evolving. Because of these considerations, the company’s primary interest lies in establishing “fundamental guiding principles” for its implementation worldwide. Importantly, the Board has not evaluated the general effectiveness of community notes in the U.S.
The Board consulted a range of stakeholders, including technical experts on bridging algorithms, civil society organizations, journalists and fact-checkers, for observations and data on different community notes-style moderation systems (including X’s) across different contexts.
On January 7, 2025, Meta announced it was introducing a community notes program and ending its third-party fact-checking program in the U.S. The company indicated it would refine community notes before making it available for users outside the U.S.
Key Findings and Recommendations
Informed by a broad consideration of potential human rights impacts, the Board has developed the following country-level factors to guide Meta’s rollout of community notes:
Safeguards in repressive human rights contexts
Community notes depends on an active and engaged contributor base. Such programs have experienced greatest success amid a robust civil society. Ideally, contributors rely on independent media to support proposed notes and participate without fear of harassment or retribution.
The Board underscores that until Meta can demonstrate robust and effective contributor privacy protections, with evidence of red-teaming under adversarial conditions, a clear policy on handling requests from law enforcement agencies for community notes data and risk mitigation measures, countries with repressive human rights records and weak civil societies should be omitted from the initial rollout.
Exercise caution during elections
Community notes can support access to information and freedom of expression during elections in robust information environments with free media and uninhibited civil society. Without those conditions, the program risks publishing misleading notes, and Meta should proceed with caution. Where significant risks to the integrity of political institutions are present, and Meta determines through product testing, risk assessment and human rights due diligence that its safeguards are insufficient to mitigate them, community notes should not be introduced in advance of or during major elections.
Omit countries with a history of coordinated disinformation networks
Community notes operates under the assumption that a sufficiently diverse and independent set of contributors will evaluate content in good faith and that consensus signals can reliably approximate accuracy. Where malicious actors have repeatedly demonstrated the ability to coordinate large numbers of accounts to promote deceptive information, this assumption may not hold. Instead, community notes risks becoming a vector for manipulation rather than a safeguard against it. This risk will become more acute as artificial intelligence facilitates the scaled creation and operation of these networks.
Until such time as data on the functionality of community notes can verify the adequacy of Meta’s mitigation measures against such coordinated activity, the Board recommends that Meta initially omit countries with a historical pattern of intentional, large-scale disinformation networks. Meta should also consider here whether actors have demonstrated the intent to manipulate information ecosystems and possess the technical sophistication to do so on a large scale.
Do not introduce in crisis or protracted conflict conditions
The potential vulnerability of community notes to coordinated manipulation by armed groups, state actors or their supporters seeking to legitimize propaganda through gaming of the note rating system poses heightened risks in ongoing crisis or conflict situations. Conditions causing groups’ inability to contribute, e.g., unstable internet access and insecurity preventing participation, can exacerbate information asymmetries. In such circumstances, timeliness is critical. Delays in note publication suggest community notes may be an inadequate primary safeguard in crises and conflicts, particularly as thresholds for incitement to violence may be lower. Notes targeting specific groups can more easily result in offline harm.
Due to uncertainty over community notes’ performance in conflicts and its potential to heighten risk of harm, the Board believes that it should not be introduced in countries experiencing crises or protracted conflict.
Delay introducing community notes where there is language complexity that Meta cannot technically and operationally accommodate
Community notes requires sufficient representation of a context’s language groups. Where Meta is unable to achieve this, it should delay introducing community notes. Otherwise, language disparities in notes proposed and published could be created or exacerbated, undermining the program as a plural and diverse information source.
Additionally, there are potential linguistic and cultural variations in the use and interpretation of community notes, some unexpected, which may affect which notes are published. For example, what it means to rate something as “helpful” might differ in different places and when the word is translated. In countries where Meta anticipates features of community notes cannot yet accommodate linguistic complexity, it should consider delaying its introduction.
Exercise extreme caution where social division and disagreement that drives political violence cannot be outlined simply
The design of X’s community notes algorithm implicitly assumes disagreement and division in a particular context can be modelled simply, giving a single measurement of polarization. Meta has not provided any information that suggests its program will be different. However, where division and disagreement cannot be easily modelled along a single axis, this can reinforce an unduly simplistic understanding of conflict, overlooking how multiple factors intersect (across politics, ethnicity, religion, language and caste, for example). In practice, this risks marginalizing minority perspectives, as misleading or harmful notes reaching consensus among majority groups may be published. Where the algorithm does not accurately identify and attempt to “bridge” (rewarding content receiving positive feedback from audiences that typically disagree) a division that drives conflict and violence, this risk of harm is especially acute. Therefore, the Board recommends that Meta exercise extreme caution when considering countries characterized by these dynamics.
Where there is a heightened risk of misalignment between the design assumptions of community notes about a society and what actually drives social and political division there, such countries need not be categorically omitted from community notes’ rollout. Rather, the rollout should be sequenced to allow performance testing in different contexts, and should begin cautiously in political, linguistic, and information environments that are similar to places where Meta already possesses such data, piloting and risk mitigation measures.
Omit countries that face persistent obstacles to internet access
The Board recommends omitting countries that face persistent or systemic obstacles to internet access, as community notes relies on broad, consistent and equitable contributor participation to function as intended. A narrow pool of contributors, due to infrastructure gaps, high costs, regional disparities and, especially, government-imposed shutdowns, undermines the core premise of community notes’ representativeness.
Weighting
The Board recommends that factors whereby community notes could create or heighten the risk of harm should be weighted heavier than factors from the program’s inadequacy as a harm mitigation measure. These include thresholds whereby Meta should not introduce community notes until it demonstrates it can do so while mitigating these harms.
Meta should provide the Board with the criteria or risk matrix it develops to guide expansion every six months during initial expansion, with evidence of how these are applied in country-level decisions about program expansion.
Data and reporting
The potential human rights risks of and adequacy of mitigation strategies for community notes depend on the design and functionality of the product in context. Meta told the Board it plans to test the program prior to launch in a market. The Board recommends this testing should focus on surfacing and mitigating risks related to contributor anonymity, coordinated disinformation campaigns and gaming of the system, language representation and contributor participation. The Board calls for substantial transparency, reporting and researcher access to data on Meta’s community notes performance.
For Further Information
In preparing this policy advisory opinion, the Board carried out extensive stakeholder engagement. To read public comments for this case, click here.
