Digital Services Act Reporting Obligations Approaches

By February 16, 2025, services governed by the EU’s Digital Services Act (DSA) must submit their annual transparency reports. This requirement applies to hosting services, online platforms, very large online platforms (VLOP), and very large online search engines (VLOSE).

The reports must include detailed information that varies based on the service type. Intermediary services, which host or transmit content on behalf of users, are obligated to disclose figures related to orders from EU authorities, user reports concerning illegal content, and content moderation efforts. Additionally, they must provide data on user complaints processed through internal handling systems.

Online platforms under the DSA have additional reporting obligations. They must furnish information on out-of-court dispute settlements, including the number of disputes submitted and the median resolution time. Platforms are also required to report the frequency of user suspensions for providing illegal content. VLOPs and VLOSEs face even more stringent reporting measures, needing to include details on content moderation, such as the human resources allocated, the qualifications and training of moderators, and the effectiveness of automated moderation systems.

The format of these transparency reports is flexible for the initial deadline, but starting July 1, 2025, all intermediaries, online platforms, VLOPs, and VLOSEs must adhere to a new template provided by the European Commission. This change aims to standardize the reporting process across the EU, ensuring clarity and consistency in how information is presented.