How to improve the Aotearoa New Zealand Code of Practice for Online Safety and Harms? 3. Transparency standards The Aotearoa New Zealand Code of Practice is diminished if, without any reasonable justification, its standards are lower than those adopted by the Code’s signatories in other countries. The IAG considers, by way of illustration, transparency standards because they are extraordinarily important human rights issues in relation to digital platforms and online safety and harm. The EU’s Strengthened Code of Practice on Disinformation Meta, Google, TikTok, and Twitch have adopted the EU’s Strengthened Code of Practice on Disinformation (2022), but Twitter/X has withdrawn from it. In relation to transparency standards, the New Zealand Code has two outcomes and four measures, whereas the EU’s Strengthened Code of Practice (2022) has three commitments and 14 measures. Some of the differences between the two codes are material. For example, commitment 35 of the EU’s Strengthened Code of Practice is not matched by the outcomes and measures in the Aotearoa New Zealand Code of Practice. Commitment 35 says: Signatories commit to ensure that the Transparency Centre contains all the relevant information related to the implementation of the Code’s Commitments and Measures and that this information is presented in an easy-to-understand manner, per service, and is easily searchable. Notably, the corresponding provisions of the Aotearoa New Zealand Code of Practice require neither a dedicated Transparency Centre nor that the information is “presented in an easy-to-understand manner, per service, and is easily searchable.” Human rights are averse to arbitrary differences between a signatory’s conduct in different jurisdictions. One way of improving the NZ Code is by ensuring its standards are not lower than those agreed by the Code’s signatories in other countries. The EU’s Digital Services Act The EU’s Strengthened Code of Practice should be considered with the EU’s Digital Services Act (2022). Transparency reporting under the EU’s Digital Services Act is mainly covered by articles 15, 24 and 42. These articles place different transparency reporting obligations on different levels of provider under the Act’s graduated (or calibrated) responsibilities. For example, article 15(1) sets out transparency reporting obligations for “providers of intermediary services”: Providers of intermediary services shall make publicly available, in a machine-readable format and in an easily accessible manner, at least once a year, clear, easily comprehensible reports 8