• Peer-reviewed studies of content moderators (CMs) show that repeated exposure to extreme content is associated with trauma-relevant symptoms and traumatic stress, with higher exposure linked to higher psychological distress (Gauthier et al., Submitted; Spence et al., 2023; Spence et al., 2024) 
• Protections are uneven across jurisdictions and are frequently weakest in outsourced supply chains where responsibility is fragmented, despite evidence that working conditions and support structures shape risk (Spence & DeMarco, 2025)
• Wellbeing services can help, but evidence suggests they are not a substitute for controls on exposure and job demands (Spence & DeMarco, 2025).

Policy can close these gaps by treating moderators as a trauma-exposed workforce and applying prevention-oriented occupational standards across the full moderation ecosystem. 

Key findings that justify regulatory action include: 

• Qualitative interviews with moderators exposed to Child sexual abuse material (CSAM) identified intrusive imagery, triggering, avoidance and negative cognitive/emotional effects consistent with repeated trauma exposure (Spence et al., 2023). 
• A cross-sectional survey of CMsfrom four lower and middle income countries found high rates of PTSD symptoms, depression symptoms, somatic symptoms, and alcohol misuse (Gauthier et al., Submitted).  
• A comparison study found U.S. based CMs had higher PTSD and depression symptoms than colleagues who were not exposed to traumatic content (Gauthier et al., Submitted). 
• A cross-sectional survey found a dose-response relationship between frequency of exposure to distressing content and psychological distress/secondary trauma as well as showing that supportive colleagues and feeling the role was valued buffered this relationship (Spence et al., 2024) 
• A replication and extension study found that problem-focused and approach-oriented coping strategies, including seeking support from similarly exposed colleagues, were associated with lower psychological distress and secondary trauma and higher wellbeing, while avoidant coping and confidentiality concerns were associated with poorer outcomes (Spence & DeMarco, 2025) 
• A practitioner briefing synthesising qualitative insights emphasised the protective role of peer support by speaking with colleagues exposed to similar content and organisational policies that support boundaries and recovery (Spence, Martellozzo, & DeMarco, 2022) 

Regulatory objectives

• Prevent avoidable trauma exposure and reduce psychological injury risk 
• Create common minimum standards for in-house and outsourced moderation, including vendor due diligence and joint responsibility 
• Increase transparency to enable oversight and early intervention 
• Require prevention-first controls on exposure and work design rather than relying on wellbeing services alone.  
• Protect worker voice, organising rights and whistleblowing in the public interest 

These recommendations are grounded in a growing interdisciplinary evidence base demonstrating the cumulative, dose response relationship between repeated exposure to traumagenic content and psychological distress among moderators, including symptoms consistent with secondary traumatic stress, burnout, and moral injury (DeMarco, Watson & Norman, 2026). They are further informed by qualitative accounts from moderators themselves, which consistently highlight gaps in prevention, support, accountability and safe working conditions across both in-house and outsourced moderation environments. 

There are several viable pathways for governments and regulators to operationalise protections for CMs:

• As labour, occupational safety and platform regulation regimes vary across jurisdictions, the precise legal route may differ. In some settings, the most immediate impact may come from psychosocial risk assessment duties or enforceable exposure controls. In others, it may require independent audit requirements, worker compensation clarity, vendor due diligence or platform level duty of care obligations may be the more practical entry points 
• Occupational safety and health (OSH) regimes can require psychosocial risk assessments, enforce controls and use inspections and penalties to ensure compliance 

• Platform regulation can complement this by embedding workforce safeguards into duty of care frameworks or formal risk management requirements making moderator wellbeing a core compliance expectation rather than a voluntary add-on 

• Public procurement rules require certified standards from any vendors providing moderation services to public bodies. 

• Given the globalised supply chain of moderation, cross-border cooperation is also essential, particularly through mutual recognition of audit standards and shared minimum expectations for outsourced workforces 

A pragmatic route is phased implementation. First classify or formally recognize high-risk moderation as hazardous work and introduce baseline reporting. Second, move to enforceable controls and independent audits. Finally,strengthen remedies and supply-chain accountability so responsibility cannot be outsourced. 

These recommendations are grounded in a growing interdisciplinary evidence base demonstrating the cumulative, dose response relationship between repeated exposure to traumagenic content and psychological distress among moderators, including symptoms consistent with secondary traumatic stress, burnout, and moral injury (DeMarco, Watson & Norman, 2026). They are further informed by qualitative accounts from moderators themselves, which consistently highlight gaps in prevention, support, accountability and safe working conditions across both in-house and outsourced moderation environments.