While the 25 Very Large Online PlatformsAn online platform refers to a digital service that enables interactions between two or more sets of users who are distinct but interdependent and use the service to communicate via the internet. The phrase “online platform” is a broad term used to refer to various internet services such as marketplaces, search engines, social media, etc. In the DSA, online platforms… (VLOPs) and Very Large Online Search Engines (VLOSEs) have already become well acquainted with the Digital Services Act transparency obligations (specifically articles 15, 24 and 42), all the other online services operating in the EU are due to publish their first DSA transparency reports in the coming weeks.
📌 Here’s what you need to know.
➡️ Is this obligation relevant to my online service?
The short answer: if your online service operates in the EU, yes ✅, you are required to publish a TR!
👀 However, the exact content of this report does vary depending on your service categorisation:
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- As an intermediary service (e.g., internet providers, domain registrars), you’ll need to publish annual reports as detailed under Article 15;
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- As a Hosting serviceA hosting service enables individuals, companies and other service providers to host websites, databases, applications.
Within the meaning of the DSA, a hosting service offers the storage of user-generated content. This includes for example filesharing, social media, video-sharing platforms as well as marketplaces. (e.g., cloud storage providers, website hosts), in addition to Article 15, you must disclose how you respond to notices submitted by users and trusted flaggersGenerally, this refers to individuals or entities that have proven expertise in flagging harmful or illegal content to online service providers. Within the meaning of the DSA, trusted flaggers are entities that have been awarded an official status by a Digital Service Coordinator. Online platforms will need to ensure notices from such organizations are treated with priority., including the volume of flagged content and the average time taken to act;
- As a Hosting serviceA hosting service enables individuals, companies and other service providers to host websites, databases, applications.
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- As an online platform (e.g., social networks, marketplaces, multiplayer online gaming, …), you will need to report on content removals and user appeals as well as comply with obligations under Article 24, including notices received by out-of-court dispute settlement bodies or trusted flaggers and how you handle repeated offenders.
Also, with the DSA being a proportionate regulation, micro and small enterprises (≤€10M annual turnover OR ≤50 employees) are exempt from this obligation (unless they’re designated as VLOPs/VLOSEs).
📘 If you have doubts as to which category your service belongs to, check out our DSA guide!
🔍 What does this transparency obligation entail?
While complying with articles 15 and 24 may seem relatively straightforward when looking at the text of the DSA, the specific requirements have been further refined by the EU Commission through a dedicated implementing regulation (the DSA Implementing Regulation for transparency, published on November 4th 2024).
Concretely, this implementing regulation defines a common standardized format (reporting template, available in a CSV or XLSX format) and reporting period applicable to all services operating in the EU, starting as of July 1st 2025.
💡 The new reporting format requires platforms to publish a wide range of data points covering their entire moderation process & detection sources. Some key highlights of the new format: |
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✅ 11 tabs encompassing all the reporting categories; |
✅ 17 infringement categories and 82 sub-categories defined; |
✅ Data points covering:
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✅ For automated moderation: data on the accuracy & recall rates of tools used; |
✅ Number of average monthly active recipients during the reporting period (this should be published on the website of your service too!); |
✅ Metrics for human resources dedicated to content moderation (e.g. number, linguistic expertise); |
✅ Qualitative indicators for all services. |
⏳ When is my transparency reportA transparency report is a document released by an organization that discloses information related to its policies, practices, and actions. Typically, transparency reports provide details on the handling of requests for user data and content removal, as well as government requests for user records, among other relevant metrics and insights. due?
As a non-VLOP, you are required to publish your TR “at least once a year”. It should be made available to the public at most two months after the end of the reporting period.
Concretely, for 2025, the reporting being from February 17th 2024 to any time between December 31st 2024 and February 17th 2025 (depending on the platform’s chosen reporting period closure date), services will have until – at the latest – April 17th 2025 to publish their TR.
👀 However, keep in mind that the April 17 deadline is a one-time exception, only applicable for the first reporting cycle.
Moving forward, the Implementing Regulation establishes a fixed annual schedule: From mid-July 2025, the annual transparency reports will need to cover a full calendar year (January 1st – December 31st) and due at the latest two months after, AKA, by February 28th, of the following year.
✏️ Complex? Here’s a summary breaking down of reporting periods and required format for the next 2 years:
🗓️ Reporting Period: 17 February 2024 – ends between 31 December 2024 and 17 February 2025 (depending on the platform’s chosen reporting period closure date);
⏰ Publication Deadline: Between 1 January 2025 and 17 April 2025;
📝 Format: Use of the template provided by the Implementing Regulation is encouraged but not mandatory.
🗓️ Reporting Period: 1 January 2025 – 31 December 2025;
⏰ Publication Deadline: By 28 February 2026;
📝 Format:
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- First semester: Use of the Implementing Regulation template is encouraged but not mandatory;
- Second semester: Mandatory use of the Implementing Regulation template.
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🗓️ Reporting Period: 1 January – 31 December 2026;
⏰ Publication Deadline: by 28 February 2027;
📝 Format: Mandatory use of the Implementing Regulation template for the full year.
🤯 Could I avoid the annual headache?
Of course… but it will require you to have the right systems in place! 🤖📊
The structure and type of data required to comply with the DSA transparency obligations are very specific – and often not at all tracked by services. Moreover, even if they were tracked, T&S teams often operate on decentralized and legacy moderation systems, leaving them to scramble across their organization to gather required data points, while having to retro-fit them into pre-defined EU violation categories. To make it worse, transparency reporting obligations will most certainly differ across regulations globally (already the case between the EU, UK and AUS).
It is to help platforms avoid this annual headache that we, at Tremau, built Nima: a centralized end-to-end Trust & SafetyThe field and practices that manage challenges related to content- and conduct-related risk, including but not limited to consideration of safety-by-design, product governance, risk assessment, detection, response, quality assurance, and transparency. See also: Safety by design platform, enabling our clients to generate DSA-compliant Transparency Report at the click of a button. To do so, Nima seamlessly collects and stores all the necessary information in the correct format, making compliance fast, efficient, and stress-free.
Beyond reporting, Nima is fully integrated with the EU Transparency Database 📊, automatically sending Statements of Reasons (SoR) for every moderation decision.
Finally, and perhaps most importantly, the wealth of data collected and processed through NIMA can significantly enhance the depth and accuracy of the Risk Assessments mandated by both the EU DSA and the UK OSA 🇬🇧.
For a deeper dive into transparency reporting under the DSA:
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- Check out our recent webinar, which was co-organized with TechCoalition. The session featured insights from Agne Kaarlep (Tremau), Despina Papageorge (Cloudflare), and Antonella Zarra (European Commission).
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- And Read the DSA Transparency Guide co-authored by Tremau and the Tech Coalition
