Punishing regulators to protect platforms: US retaliation against the DSA
In an unprecedented move, the United States announced sanctions against five European personalities involved in the regulation of the technology sector on 23 December 2025, banning them from entering the country.
The measure, announced by the State Department, is aimed at targeting figures linked to the Digital Services Act (DSA), the regulation by which theEuropean Union imposes stringent content and liability obligations on digital giants. The DSA had already come under attack by Elon Musk, following the fine imposed on X for its lack of transparency on dark patterns and opaque access to public data for researchers.
According to the US administration, the authorities in Brussels put undue pressure on American companies, undermining freedom of expression and using EU digital regulation for political purposes.
An act of retaliation against the DSA – Thierry Breton
The act takes the form of a real reprisal against the Union. It is emblematic that among the five names affected stands out that of Thierry Breton, former European Commissioner for the Internal Market and main architect of the DSA.
Breton used X to reiterate that the DSA was voted in by 90% of MEPs from all 27 member states, evoking the image of a return to a ‘McCarthyist-style witch hunt‘.
Is McCarthy’s witch hunt back? 🧹
– Thierry Breton (@ThierryBreton) December 23, 2025
As a reminder: 90% of the European Parliament – our democratically elected body – and all 27 Member States unanimously voted the DSA 🇪🇺
To our American friends: “Censorship isn’t where you think it is.”
Anna-Lena von Hodenberg and Josephine Ballon – HateAid
Together with Breton, four other key figures indigital activism were sanctioned, including Anna-Lena von Hodenberg and Josephine Ballon, founders ofHateAid, a German non-profit non-governmental organisation committed to combatingonline hatred, digital threats and defamation campaigns.
HateAid came into conflict with Musk after he took the helm of Twitter/X, taking an increasingly critical public stance. The organisation claims that the new ownership choices have significantly weakened the mechanisms for protecting victims of online hate and harassment. In various interventions and legal initiatives, HateAid has highlighted how content that is clearly illegal under European law – threats, incitement to hatred, anti-Semitism – has remained online despite warnings. The case of thelegal action brought in Germany against X for failure to remove anti-Semitic content is emblematic.

Clare Melford – Global Disinformation Index (GDI)
Similarly, Clare Melford, co-founder and CEO of the Global Disinformation Index (GDI), has ended up at the centre of great controversy for her work on analysing the advertising flows that feed the online disinformation ecosystem. Through systematic studies, GDI has shown how many sites that spread disinformation or extremist content survive not thanks to organic traffic, but to programmatic advertising automatically delivered by large global circuits. The basic idea is that disinformation is also an economic phenomenon and that targeting its funding is often more effective than content moderation alone.
Imran Ahmed – Centre for Countering Digital Hate (CCDH)
Finally, Imran Ahmed, founder of the Center for Countering Digital Hate (CCDH), embodies the most advanced level of the clash between platforms, political power and civil society. The CCDH has shown, with empirical analysis, how X ‘s algorithms tend to favour the spread of anti-Semitic and hate content, especially after its takeover by Elon Musk. In 2024, Musk attempted to legally hit the organisation with a civil lawsuit in the US, but the judge dismissed the case, stating that it was clear that X Corp, the company behind X, did not tolerate the criticism it received.
Ahmed, a permanent resident of the US, then sued theTrump administration before the Southern District of New York, claiming he was targeted for CCDH’s work in monitoring social platforms, in violation of the First Amendment. The case could become a symbol of civil resistance against a US policy that is increasingly hostile to those promoting digital regulations such as the European DSA or theUK’s Online Safety Act.
European reactions
The European Commission and the governments of several member states rejected the Trump administration’s accusations, calling the measure a hostile act and a form of political intimidation. Brussels asserts the full legitimacy of its regulatory framework, reiterating that the DSA is not about freedom of expression, but about the responsibility of platforms to manage illegal content, to fight disinformation, and to ensure transparency.
A firm reply from Ursula von der Leyen, President of the European Commission:
” Freedom of speech is the foundation of our strong and vibrant European democracy. We are proud of it and will protect it. TheEuropean Union will not be intimidated while defending its citizens and its democratic laws’.
Emmanuel Macron also branded the US bans as forms of ‘intimidation and coercion‘ against European digital sovereignty, asserting the democratic and sovereign nature of EU regulation. Concern was also expressed by the British government, which, although non-EU, declared its support for free speech and its commitment to keeping the internet free of harmful content.
The battle for regulation of digital environments now comes to a head.








