Meta Oversight Board weighs cautious rollout of Community Notes beyond the United States

The Oversight Board has released a policy advisory opinion addressing Meta’s request for guidance on which factors to weigh when deciding whether to omit any country from expanding Community Notes outside the U.S. The document emphasizes that, while Community Notes could broaden users’ freedom of expression and enrich online discussion at scale and pace, expanding into some contexts—especially in repressive states, during elections, or amid ongoing crises—could pose meaningful human rights risks and real harms Meta must avoid or address.

Executive Summary

• Community Notes can enhance expression and discourse on Meta’s platforms if deployed with sufficient scale, speed, and precautions against manipulation. However, in certain settings—repressive regimes, electoral contexts, and ongoing crises or conflicts—expansion outside the U.S. could generate significant human rights risks and tangible harms.
• The Board is concerned about coordinated disinformation networks that could abuse Community Notes and about the potential for the feature to privilege dominant political, ethnic, or linguistic groups, marginalizing minority communities.
• The likelihood and severity of these risks depend heavily on how the product is designed and operates in each context. The effectiveness of Meta’s fixes—such as protecting contributor anonymity and guarding against gaming the system—needs ongoing verification through data gathering and reporting on real-world performance.
• If Community Notes is used as the primary means to address misinformation that falls short of removal thresholds, its design may not achieve that goal. Delays in publishing notes, limited numbers of notes, and dependence on the reliability of the broader information environment raise serious questions about its capacity to meaningfully counter harm.
• The Board proposes criteria for deciding when human rights risks justify withholding Community Notes in a given market. Recommendations are conditional, pending extensive testing and data on how the algorithm operates in practice, alongside other misinformation tools. The Board also calls for ongoing data collection, assessment, and reporting tied to these criteria.

Background

• On November 19, 2025, the Board accepted Meta’s request for guidance on country-specific factors to consider when deciding whether to omit a market from the planned expansion of Community Notes beyond the U.S., acknowledging that local context can influence operations. Meta asked how to weigh these factors at large scale.
• Meta described Community Notes as an early-stage product with limited data from the U.S. beta rollout, framing the expansion as a period of testing and refinement that could lead to evolution of the program. The Board has not assessed the overall 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—to gather observations on Community Notes-style moderation systems across different contexts.
• Meta announced the Community Notes program on January 7, 2025, and disclosed the end of its third-party fact-checking program in the U.S., stating that notes would be refined before expanding outside the United States.

Key Findings and Recommendations Safeguards in repressive human rights contexts

• Community Notes depend on an active, engaged contributor base and are most robust where civil society and independent media can operate without fear. Until Meta can demonstrate strong contributor privacy protections, robust red-teaming against adversarial testing, a clear stance on law-enforcement data requests, and effective risk mitigation, countries with repressive records and weak civil society should be omitted from the initial rollout.

Exercise caution during elections

• In information environments with strong media freedom and vibrant civil society, Community Notes can support information access and freedom of expression. Where these conditions are absent, the program risks publishing misleading notes. If risks to electoral integrity persist and safeguards are deemed insufficient after testing and due diligence, Community Notes should not be introduced before or during major elections.

Omit countries with a history of coordinated disinformation networks

• Community Notes assumes a diverse, independent contributor base that can reach a reliable consensus. When actors repeatedly demonstrate the ability to coordinate large numbers of accounts to spread deceptive information, this assumption weakens and the notes risk becoming a tool of manipulation. AI-enabled scaling of such networks heightens the concern. Pending data demonstrating adequate mitigations, Meta should initially omit countries with a historical pattern of large-scale disinformation networks and consider actors’ intent and sophistication.

Do not introduce in crisis or protracted conflict conditions

• In crises or ongoing conflicts, the heightened risk of manipulation by armed or state actors who seek to legitimize propaganda poses additional hazards. Disruptions in participation and internet access can create information imbalances, and delays in publishing notes can undermine timeliness. Given these uncertainties, the Board recommends not launching Community Notes in countries experiencing crises or protracted conflicts.

Delay introducing where language complexity cannot be technically and operationally accommodated

• Effective representation of all language groups is essential. If Meta cannot ensure adequate language coverage and accurate interpretation, notes may be misaligned with local context. In such cases, delaying rollout helps prevent linguistic or cultural misalignments and preserves the plural and diverse nature of information sources.

Extreme caution where social division and disagreement drive political violence

• The algorithm’s ability to model disagreement along a single axis is a simplification that may not reflect real-world complexity. In places where multiple overlapping factors—political, ethnic, religious, linguistic, caste—drive conflict, notes that reflect majority views could marginalize minorities. If the design cannot capture these nuances, Meta should proceed with great caution, sequencing rollout and prioritizing performance testing in contexts similar to where Meta already has data and experience.

Omit countries with persistent obstacles to internet access

• Widespread, reliable contributor participation is central to Community Notes. Countries with systemic internet access issues—whether due to infrastructure gaps, cost, regional disparities, or government shutdowns—risk producing non-representative participation. The Board favors omitting such markets until access can be reliably ensured and harms mitigated.

Data and reporting

• The potential human rights risks and the effectiveness of mitigations depend on product design in context. Meta should test the program before launch in a market with a focus on protecting contributor anonymity, resisting coordinated disinformation campaigns, addressing gaming of the system, and ensuring adequate language representation and contributor participation.
• The Board calls for substantial transparency, ongoing reporting, and researcher access to data on Community Notes performance. Meta should share criteria and risk matrices used to guide expansion at six-month intervals during the initial rollout, including evidence of how those criteria are applied in country-level decisions.

For Further Information

• The Board conducted extensive stakeholder engagement in preparing this advisory. Public comments on this case are available for review.

If you’d like, I can tailor this rewrite to a particular audience (policy brief, blog post, or summary for executives) or adjust the tone to be more formal or more accessible.