DSA Updates scaled

The Digital Services Act continues evolving through renewed implementation guidance from the European Commission, bringing meaningful enhancements to how online platforms operate across the EU. As digital advertising professionals, staying informed about these developments helps you navigate the regulatory landscape effectively, particularly those affecting advertising transparency and compliance with Article 26

Recent months have brought accelerated regulatory guidance, comprehensive guidelines for specific sectors, and important procedural clarifications that support your DSA compliance strategies. Understanding these updates ensures your organisation can implement best practices whilst maintaining competitive advantage in Europe’s digital advertising ecosystem.

General DSA Updates

The Commission published comprehensive guidelines on protecting minors under the DSA, establishing clear standards for platforms accessible to children and young people. These guidelines provide practical recommendations for implementing proportionate measures addressing online risks.

Key recommendations include setting minors’ accounts to private by default, implementing robust age verification systems, and modifying platform settings that may lead to excessive use or encounters with harmful content. The guidelines address important areas: grooming prevention, harmful content filtering, managing addictive behaviours, cyberbullying prevention, and protection against harmful commercial practices.

The Commission also released a prototype age verification app,The Age Verification App Blueprint”, and opened a pilot phase for testing this software solution. The technical specifications and open-source blueprint are freely available for platforms to integrate into their compliance frameworks, supporting industry-wide implementation of best practices.

Source: European Commission – Commission publishes guidelines on the protection of minors

The European Commission published a comprehensive delegated act establishing clear rules for qualified researchers seeking access to internal data from VLOPs and VLOSEs. This development significantly enhances research capabilities whilst maintaining robust platform security standards.

The delegated act provides precise procedures for data sharing between platforms and vetted researchers, including standardised data formats and documentation requirements. Digital Services Coordinators, VLOPs, and VLOSEs now have clear guidance on information they must publish to facilitate researcher applications for relevant datasets.

The Commission also launched the DSA data access portal where researchers can find information and communicate directly with VLOPs, VLOSEs, and DSCs about their data access applications. This creates a centralised hub for academic research into systemic risks and mitigation measures across the EU, supporting evidence-based policy development.

Source: European Commission – Commission adopts delegated act on data access under the Digital Services Act

New Implementing Regulation requirements became effective, standardising transparency reporting formats, content, and periods for all providers of intermediary services providers. This addresses previous inconsistencies in reporting practices across platforms, making compliance clearer and more consistent.

The regulation also establishes uniform reporting templates and aligned periods for VLOPs and VLOSEs, regardless of designation dates. Providers must collect data according to new requirements, with first harmonised reports due in early 2026.

Requirements for submitting statements of reasons to the DSA Transparency Database were updated to align with data categories outlined in the Implementing Regulation. This change ensures consistency across transparency tools and simplifies compliance processes.

Source: European Commission – Commission harmonises transparency reporting rules under the Digital Services Act

The European Commission published a comprehensive election toolkit summarising best practices that national regulators developed over the past year to mitigate risks on VLOPs and VLOSEs during elections.

The toolkit provides practical guidance for Digital Services Coordinators collaborating with platforms to address challenges including hate speech, online harassment, and manipulation of public opinion. Particular attention focuses on emerging challenges involving artificial intelligence-generated content and impersonation tactics.

This resource builds upon Election Guidelines published in March 2024 and incorporates valuable experience from implementing the Code of Practice on Disinformation and DSA election integrity dialogues held since September 2023.

Source: European Commission – Commission presents new best-practice election toolkit on the Digital Services Act

The Commission and European Board for Digital Services endorsed integrating the voluntary Code of Practice on Disinformation into the DSA framework. This integration establishes the Code as a significant benchmark for determining DSA compliance.

Full adherence to the Code can now be considered appropriate risk mitigation for VLOPs and VLOSEs signatories. Compliance with Code commitments becomes part of annual independent audits required under the DSA, providing clear pathways for demonstrating regulatory compliance.

Major platforms including Google, Meta, Microsoft, and TikTok submitted necessary documents supporting the Code’s conversion into a DSA Voluntary Code of Conduct, strengthening collaborative approaches to combating disinformation.

Source: European Commission – Commission endorses the integration of the voluntary Code of Practice on Disinformation into the Digital Services Act

The European Commission adopted an Implementing Regulation outlining rules and templates for transparency reporting by providers of intermediary services under the DSA. This ensures all relevant providers give clear and comparable information on their content moderation practices.

Previously, inconsistency between reporting practices made it difficult to assess and compare moderation practices across intermediary services. Reports varied widely in format and interpretation of data categories.

The Regulation addresses these challenges by establishing uniform reporting templates and periods for all providers of intermediary services, including VLOPs and VLOSEs.

Source: European Commission – Commission harmonises transparency reporting rules under the Digital Services Act

The European Commission published guidelines on recommended measures for Very Large Online Platforms and Search Engines to mitigate systemic risks that may impact election integrity, with specific guidance for European Parliament elections.

Under the DSA, designated services with more than 45 million monthly active users in the EU have obligations to mitigate risks related to electoral processes whilst safeguarding fundamental rights including freedom of expression and information.

These guidelines provide practical recommendations for risk assessment and mitigation during electoral periods, supporting platforms in balancing democratic discourse protection with harm prevention.

Source: European Commission – Guidelines for providers of VLOPs and VLOSEs on the mitigation of systemic risks for electoral processes

Country Specific DSA Updates

Germany DSA Updates

31 January 2025: Federal Network Agency Enhances Election Preparedness

The Federal Network Agency, serving as Germany’s Digital Services Coordinator, conducted comprehensive preparedness activities with VLOPs ahead of national parliamentary elections scheduled for 23 February 2025.

These activities evaluated platforms’ readiness for election-related content moderation challenges and their capacity to manage increased information risks during the electoral period. This proactive approach demonstrates Germany’s commitment to supporting election integrity through collaborative DSA implementation.

The FNA coordinated with the European Commission to ensure consistent standards across designated platforms operating in Germany, fostering best practice sharing.

Source: European Commission – German Digital Services Coordinator tests platforms’ readiness under the Digital Services Act

Ireland DSA Updates

Ongoing: Irish DSC Reviews DSA Platform Compliance

Ireland’s Digital Services Coordinator initiated a formal review of online platforms’ compliance with DSA provisions on contact points for service recipients and notice and action mechanisms for reporting illegal content.

These initiatives focus on platforms established in Ireland. Given the country’s significance as a European headquarters location for major technology companies, the Irish DSC’s guidance affects numerous high-profile VLOPs with Irish establishments.

The collaborative approach helps platforms understand compliance requirements and implement suitable measures whilst maintaining operational efficiency.

Source: CnaM – Coimisiún na Meán opens review of online platforms’ compliance with EU Digital Services Act

Netherlands DSA Updates

July 2024: Dutch DSC Conducts Early Compliance Assessment

The Dutch national authority conducted an initial assessment of DSA compliance across fifty providers of intermediary service. This assessment identified areas where additional guidance and support could enhance compliance outcomes.

The findings revealed opportunities for improvement across multiple DSA provisions, particularly regarding content moderation and reporting mechanisms for illegal content. The Dutch DSC developed enhanced guidance materials to support companies in meeting their obligations effectively.

Source: ACM: Veel bedrijven voldoen nog niet aan Europese digitale wetgeving (in Dutch)