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The EU Digital Services Act (DSA), Regulation (EU) 2022/2065, is a tiered rulebook for intermediary services operating in the European Union. It covers online marketplaces, social networks, content-sharing services, app stores, travel and accommodation platforms, search engines and other online services, but the obligations vary by service category and size.
Since 17 February 2024, covered services have had to support reporting of illegal content, explain certain moderation decisions and publish transparency information. Designated Very Large Online Platforms (VLOPs) and Very Large Online Search Engines (VLOSEs) face additional systemic-risk, audit, advertising, recommender-system and data-access duties. Small and micro-enterprises are exempt from some of the heaviest requirements, not from the entire DSA.
The DSA at a glance
The DSA does not impose one identical checklist on every website or app. It layers duties according to what a service does and how large its EU user base is.
| Service or status | What the DSA generally requires |
|---|---|
| Intermediary service | Core obligations connected with illegal-content reporting, moderation transparency and regulatory reporting, subject to the service’s exact category and size. |
| Hosting service, including an online platform | Affected users must receive a clear, specific statement of reasons when content is removed or access is otherwise restricted. |
| Online platform | Additional user, advertising, marketplace-design and transparency duties. Most platforms must publish self-assessed EU monthly-user numbers and refresh them every six months, unless they qualify as small or micro-enterprises for that requirement. |
| Marketplace | Seller-contact verification and display, reasonable efforts to perform random checks or use traceability technology, and compliance with the platform-wide advertising and design rules. |
| Designated VLOP or VLOSE | All applicable baseline duties plus systemic-risk assessments and mitigation, an internal compliance function, independent annual audits, a non-profile-based recommender option, a public advertising repository and specified data-access duties. |
The European Commission describes the principle this way: “One single set of rules across the EU – All online services operating in the European Union are required to comply with the DSA.” That statement does not mean every provision applies in the same way to every provider; the Regulation’s category and size thresholds determine the actual workload.
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Who does the Digital Services Act apply to?
The practical starting point is the service, not the company’s marketing label. A business may operate a social network, a user-content site, an app store, a marketplace or a travel platform, and each function can trigger a different set of DSA duties. The regime also distinguishes ordinary providers from services designated as very large.
Intermediary and hosting services
The DSA covers intermediary services operating in the EU. Hosting services are a subset relevant to user-submitted material: when a provider removes content or restricts access, it must give the affected user a clear and specific explanation for that action. An online platform is a hosting service for the obligations that apply to platforms, so it carries this explanation duty as well as platform-specific requirements.
Online platforms
Online platforms include services such as social networks, content-sharing services, app stores and travel or accommodation platforms. Their obligations extend beyond handling reports. They must make advertising more transparent, avoid specified deceptive interface practices and, where applicable, meet marketplace duties. Most also have to publish their own estimate of monthly users in the EU and update it twice a year.
Very large services
The Commission uses more than 45 million monthly users in the EU as the threshold for designation as a VLOP or VLOSE. The threshold is both geographic and temporal: it concerns monthly users located in the EU, not a company’s worldwide total or a one-day traffic spike. Designation is a formal Commission decision; the additional obligations start four months after the provider is notified.
Small and micro-enterprises
Small and micro-enterprises are exempt from some of the more burdensome DSA rules. This is a limited exemption rather than a blanket exclusion from the Regulation. A small provider should map its exact service category and enterprise status against each provision instead of assuming that every requirement disappears.
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When did the requirements take effect?
- 17 February 2024: The DSA generally became applicable across the EU.
- Designation date plus four months: A notified VLOP or VLOSE receives a four-month compliance period for its additional obligations.
- 1 July 2025: The Commission’s standardising implementing regulation for DSA transparency reporting took effect.
- February 2026: The first harmonised transparency reports under that implementing framework were published.
These dates describe the framework’s application, not a permanent timetable for every future filing. Providers must monitor current Commission guidance, designation decisions and reporting formats.
Baseline duties for platforms and other covered services
Provide a channel for illegal-content reports
Platforms must provide a user-facing way to flag illegal content, goods or services. The reporting route should be findable in the service’s interface and usable for the types of illegal material the DSA covers. A reporting tool is not the same as a promise that every report will lead to removal; it is the mechanism through which a provider can receive and process a notice.
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When a hosting service removes content or otherwise restricts access, the affected user must receive a clear and specific statement of reasons. The explanation needs to identify why the action was taken rather than relying on an opaque message such as “violates our rules.” The obligation covers actions based on the provider’s applicable moderation rules, including restrictions short of complete deletion.
For online platforms, these statements of reasons are also sent to the Commission’s public, machine-readable DSA Transparency Database. That database allows outside observers to analyse the explanations platforms issue at scale.
Publish moderation-transparency reports
Intermediary service providers must publish moderation transparency reports at least once a year. Designated VLOPs and VLOSEs have a shorter maximum interval: at least every six months. Reports concern the provider’s moderation activity and users, so a platform needs records that can support consistent counts, categories and explanations over time.
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Publish EU user numbers where required
Most online platforms, except small and micro-enterprises covered by the exemption, must publish their self-assessed number of average monthly users in the EU and update that figure every six months. The number is a regulatory disclosure, not a marketing audience estimate. Providers should document the method used to calculate it so that successive updates are comparable and defensible.
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Advertising, interface design and marketplace responsibilities
Make every covered advertisement understandable
DSA advertising rules require an ad to be labelled and to identify who placed it and why the user is seeing it. The explanation should be available in the user-facing experience, not hidden solely in a general privacy policy. The rules also prohibit targeting based on sensitive personal data such as religion, race or sexual orientation.
Prohibit deceptive design tactics
Deceptive interface practices, commonly called dark patterns, are prohibited. A design that steers a person into a choice through misleading presentation, obstructs an equally visible alternative or disguises the commercial nature of an action can create DSA risk. Product, design, growth and legal teams should review sign-up, consent, cancellation, ranking and checkout flows together rather than treating the issue as a copywriting detail.
Verify marketplace sellers
Marketplaces must verify seller contact details and display those details to users. They must also make reasonable efforts to conduct random checks or use traceability technologies. These measures are intended to make it harder for illegal goods or services to be offered anonymously and easier for users and authorities to identify the responsible trader.
What extra duties apply to VLOPs and VLOSEs?
Designation adds a systemic-risk regime on top of the ordinary platform rules. The Commission’s threshold is more than 45 million monthly EU users, and the provider has four months after notification to meet these additional obligations.
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Assess systemic risks
A designated service must identify and assess systemic risks arising from its operation. The Commission’s examples include:
- the dissemination of illegal content;
- impacts on fundamental rights;
- risks to public security;
- risks to electoral processes;
- gender-based violence;
- public-health risks;
- risks affecting minors; and
- effects on mental and physical wellbeing.
The assessment is broader than counting individual policy violations. It examines how the service’s systems, reach and design could create or amplify harms across the EU.
Mitigate the identified risks
After the assessment, the service must take mitigation measures. The DSA does not reduce this to a single prescribed technical control; the provider must select and operate measures that address the risks it identified. Those measures should be documented well enough for the internal compliance function, auditors and regulators to evaluate them.
Maintain an internal compliance function
VLOPs and VLOSEs must maintain an internal compliance function. Its role is to coordinate DSA responsibilities, track controls and evidence, and provide a point of accountability separate from ad hoc moderation or product decisions.
Undergo an independent audit every year
Designated services must undergo an independent audit at least annually and respond to the audit’s recommendations. The obligation is continuous: completing one audit does not end the duty, and management needs a process for assigning, funding and closing corrective actions.
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Offer a recommender option that is not based on profiling
At least one recommender-system option must not be based on profiling. A service should make that option discoverable and explain the meaningful difference between the profile-based and non-profile-based choices. Merely renaming an existing profile-driven feed does not satisfy the purpose of offering a genuine alternative.
Maintain a public advertising repository
Designated services must maintain a public repository of advertisements. The repository gives researchers, regulators and the public a way to inspect advertising activity beyond the individual impressions shown to users.
Share data and support qualified research
VLOPs and VLOSEs must share certain data with authorities and allow vetted researchers access for qualifying research into systemic risks. These are controlled-access duties, not a requirement to publish every internal dataset openly. Providers need governance for requests, privacy protection, security and timely responses.
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How transparency reporting changed in 2025 and 2026
The Commission’s standardising implementing regulation took effect on 1 July 2025. It established a more consistent reporting framework, and the first harmonised DSA transparency reports were published in February 2026. Platforms should therefore distinguish older reports prepared under earlier formats from the harmonised reports now appearing under the implementing regulation.
The scale of moderation reported by the Commission illustrates why consistent data matters: platforms made more than 9 billion content-moderation decisions in the first half of 2025, and 99% were proactively initiated under the platforms’ own terms and conditions. Those figures are the Commission’s characterization for that six-month period; they are not a universal rate that can be applied to every service or future reporting period.
Who enforces the DSA?
Enforcement combines national authorities’ investigative and sanctioning powers with Commission supervision. National authorities participate in enforcement for services within their remit, while the Commission directly supervises the additional obligations imposed on designated VLOPs and VLOSEs. A platform therefore needs an escalation path that can handle both domestic authority contacts and Commission requests.
Because designations, reporting formats, guidance and enforcement decisions can change, a provider making a provision-by-provision legal decision should check the operative text of Regulation (EU) 2022/2065 and the latest Commission materials rather than relying on a summary page.
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- Map the service. List each EU-facing function—hosting, social networking, content sharing, marketplace, app distribution, travel or accommodation—and identify which function is an online platform.
- Confirm enterprise status. Record whether the provider is a small or micro-enterprise and document which exemptions are being relied on. Treat each exemption as provision-specific.
- Measure EU monthly users. Establish a repeatable method for the self-assessed figure, retain the calculation record and schedule the six-month update where required.
- Build the illegal-content reporting path. Make the reporting mechanism visible, route submissions to accountable teams and retain enough information to support moderation and transparency reports.
- Standardise statements of reasons. Create reason codes and plain-language explanations that are specific to the restriction. For an online platform, ensure the statement is transmitted to the public, machine-readable DSA Transparency Database.
- Inventory advertising and interface flows. Check that every ad identifies its sponsor and why it was shown, remove sensitive-data targeting, and test sign-up, consent, cancellation and checkout journeys for deceptive design.
- Secure marketplace traceability. Verify and display seller contact details, then document the random-check or traceability-technology process.
- Test the VLOP/VLOSE threshold. If EU monthly users exceed 45 million, prepare for possible designation and the four-month post-notification compliance window.
- For designated services, run the systemic-risk cycle. Assess the listed risk areas, select mitigation measures, operate the internal compliance function, arrange the annual independent audit, maintain the public ad repository, provide a non-profile-based recommender option and govern authority and vetted-researcher data requests.
- Keep evidence current. Align policies, technical logs, board oversight, audit findings and published reports so the service can demonstrate what it did, when it did it and why.
Common mistakes to avoid
- Assuming that the DSA applies only to social media. Marketplaces, app stores, content-sharing services, travel platforms and search engines can also fall within its scope.
- Treating “small business” as a complete exemption. The relief is limited to specified burdens and does not erase every DSA duty.
- Using a generic moderation message. Covered restrictions require clear and specific reasons.
- Publishing worldwide audience numbers instead of the required self-assessed EU monthly-user figure.
- Calling an ad transparent because it is labelled while omitting who placed it or why it was shown.
- Completing an initial VLOP risk assessment but failing to maintain mitigation, audit follow-up, researcher access and reporting processes.
- Assuming that a national regulator is the only enforcement contact. The Commission supervises the additional VLOP/VLOSE obligations.
The key takeaway
The DSA is best understood as a graduated compliance framework. Every covered service must first identify its legal category and enterprise size, then implement the baseline reporting, explanation and transparency duties that apply to it. Marketplaces and advertising-supported platforms add seller, ad and design controls. Crossing the Commission’s threshold of more than 45 million monthly EU users adds a separate systemic-risk, audit, recommender, advertising-repository and data-access layer after designation. That classification work is the foundation for everything else.
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