Digital Services Act
DSA Enforcement: Compliance Requirements Transforming Online Platform Operations
The Digital Services Act (DSA) has fundamentally altered the compliance landscape for online platforms operating in the European Union, creating comprehensive obligations that extend far beyond traditional content moderation. Government affairs officials and compliance managers now face a regulatory framework that treats digital platforms as critical infrastructure requiring systematic risk assessment and mitigation procedures.
The tiered approach creates differentiated obligations based on platform size and reach. While all platforms must implement basic content reporting mechanisms, Very Large Online Platforms (VLOPs) and Very Large Online Search Engines (VLOSEs) face additional requirements including risk assessments, external auditing, and compliance function establishment. This creates strategic considerations for platform operators approaching the 45 million average monthly user threshold that triggers enhanced obligations.
Content moderation requirements represent the most operationally intensive aspect of DSA compliance. Platforms must establish accessible reporting mechanisms that function even for non-logged-in users, maintain detailed records of content decisions, and provide transparent communication throughout the notice-and-action process. The regulation requires both automated and human review capabilities, with specific timelines for responding to illegal content reports that can strain existing moderation resources.
Risk assessment obligations force platforms to systematically evaluate their potential societal impacts. VLOPs must conduct annual risk assessments covering illegal content, fundamental rights impacts, and deliberate manipulation of their services. These assessments must inform concrete risk mitigation measures, creating ongoing compliance obligations that require continuous monitoring and adjustment of platform policies and technical systems.
The transparency reporting requirements create unprecedented disclosure obligations. Platforms must publish detailed data about content moderation actions, including the number of reports received, content removed, and accounts suspended. For VLOPs, additional requirements include advertising repositories, algorithmic transparency, and detailed human resources reporting for content moderation teams.
External auditing requirements for VLOPs represent a new form of regulatory oversight. Annual independent audits must confirm compliance with DSA obligations, with negative audit opinions triggering mandatory remedial action plans. The audit implementation reports must be submitted within one month, creating tight timelines for addressing identified non-compliance issues.
Data sharing obligations with national Digital Services Coordinators provide regulators with unprecedented access to platform operations. Platforms must provide requested data within 15 days, though they can seek amendments if unable to comply. This creates ongoing compliance monitoring that extends beyond traditional regulatory reporting to real-time operational oversight.
The global implications are significant for platforms with international operations. The DSA’s extraterritorial reach means non-EU platforms serving EU users must comply with full obligations, potentially requiring separate compliance infrastructure for European operations or global policy changes to meet EU standards.
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