Meta should delay the rollout of its Community Notes feature in countries outside the United States, its own advisory board said on Thursday, March 26, citing concerns over language complexity, barriers to internet access, and the presence of large-scale disinformation networks that can manipulate the system.
The Meta Oversight Board, a semi-independent body that reviews the company’s content takedown actions and suggests policy improvements, also warned that expanding Community Notes to countries with repressive governments or facing ongoing conflict poses serious human rights risks and could lead to real-world harm.
In addition, Meta should not introduce Community Notes in countries approaching major elections, especially where there are risks to the integrity of political institutions, the Board said. Its recommendations are intended to serve as non-binding criteria for when Meta should withhold or delay launching Community Notes in a particular country.
The Oversight Board’s suggestions come a year after Meta announced that it will eliminate fact-checks posted by third-party fact-checkers in the US, replacing them with a Community Notes system similar to that of Elon Musk-owned X. Simply put, Community Notes is a fact-checking system where a group of ideologically diverse users must agree that a post needs additional context before a note is attached.
At the time, Meta said it planned to expand Community Notes to other countries as well, raising existential concerns among its fact-checking partners in India that count on revenue from Meta as a key source of survival.
Oversight Board member Sudhir Krishnaswamy, who is also the vice chancellor at the National Law School of India University (NLSIU) in Bengaluru, said that Meta should avoid a one-size-fits-all approach to a global rollout of Community Notes.
“In India, linguistic diversity and multidimensional social and political polarisation calls for a Community Notes model that ensures adequate user participation across diverse languages and verifiable mitigation strategies to address complex non-binary social and political divisions,” Krishnaswamy told The Indian Express.
India is one of the largest markets for Meta’s platforms such as Instagram and WhatsApp, which registered more than 500 million monthly active users last year. “Going by the listed criteria, it would appear that India would qualify as among the countries where Community Notes should not be introduced,” Karen Rebelo, a former fact-checker and independent journalist, said.
“It is safe enough to say that people in developing countries such as India face the brunt of mis/disinformation on these platforms and we are affected disproportionately. The type of political misinformation in India is similar to what is seen in the US and Brazil, but the repercussions and recourse that the average user has against deepfake scams, for instance, is completely different,” she added.
Although the criteria has been proposed by the Oversight Board at Meta’s own request, the Facebook and Instagram parent is not obligated to implement them unlike the Board’s content moderation rulings which are binding. However, Meta is required to publicly respond to each of the Board’s recommendations within 60 days, as per its website. To be sure, the Oversight Board is funded by Meta but claims to operate independently.
These recommendations could also serve as a framework for other platforms considering crowdsourced approaches like Community Notes. “As Meta, X, YouTube, TikTok and other platforms increasingly adopt crowdsourced approaches to address potentially misleading content, they have a responsibility to undertake comprehensive human rights due diligence with robust strategies to prevent potential harms in different contexts,” said Paolo Carozza, the Oversight Board’s co-chair.
Proposed framework
The Oversight Board set out distinct criteria for when Meta’s Community Notes rollout should be completely avoided, delayed, and carried out with caution.
Meta should, for instance, exclude those countries from Community Notes that “face persistent and widespread obstacles to internet access” as well as experience “government-imposed shutdowns”. Regions marred by conflict would also be out as armed groups or state actors may seek to legitimise propaganda by gaming the system.
For countries that have repressive human rights records and a history of large-scale disinformation networks, the Board said Meta should delay rollout till the company puts in place safeguards to protect contributors’ privacy and takes proactive measures against coordinated disinformation campaigns. In markets with complex social divisions, Meta can introduce Community Notes but with close monitoring and analysis of how the programme is working in socially diverse contexts.
Effectiveness of Community Notes
The Oversight Board said it consulted a range of stakeholders, including fact-checkers, journalists, and civil society organisations for observations and data on the effectiveness of different Community Notes-style moderation systems (including X’s) across different contexts.
Based on its analysis, the Board acknowledged that crowdsourcing fact-checks on social media posts “could enhance users’ freedom of expression and improve online discourse if implemented with sufficient scale, speed and safeguards against manipulations.”
However, it found that Community Notes cannot be the primary method for handling misinformation that does not qualify for post removal or account suspension under Meta’s rules. “Delays in note publication, limited published notes in number 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 said.
The body also flagged the lack of data and sufficient testing to know how Community Notes functions in real-world settings 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,” it added.
Implications for fact-checkers
In its policy brief, the Oversight Board highlighted widespread opposition against replacing third-party fact-checking with Community Notes. Stakeholders engaged by the Board argued, instead, for a hybrid approach where Community Notes complements professional assessments made by fact-checkers along with media literacy efforts.
However, the Board appears to have stopped short of incorporating these points in its final recommendations. “Generally, if you’ve seen the decisions they [the Board] take, they tend not to rock the boat so I’m not surprised that they haven’t included those concerns,” Rebelo told The Indian Express.
After the US, India is said to have the largest network of fact-checking partners under Meta’s Third-Party Fact-Checking (3PFC) programme, which was initiated back in 2016, following concerns about the spread of misinformation on its platforms. While Meta ended all its fact-checking partnerships in the US in 2025, it has not clearly said whether it will do the same in other countries.
The application is required for several features on Meta’s Ray-Ban and Oakley smart glasses and has reportedly been downloaded more than 50 million times. (Image: Reuters) 
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