Are you ready for your first DSA Transparency Report?

While the 25 Very Large 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 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.

The short answer: If your online service operates in the EU, yes ✅, you are required to publish a Transparency Report (TR)!

👀 However, the exact content of this report depends on your service categorization:

• Intermediary services (e.g., internet providers, domain registrars) must publish annual reports as detailed under Article 15.
• Hosting services (e.g., cloud storage providers, website hosts) must comply with Article 15 and disclose how they respond to notices from users and trusted flaggers, including flagged content volume and average response time.
• Online platforms (e.g., social networks, marketplaces, multiplayer online games) must report on content removals, user appeals, and comply with Article 24, including notices from out-of-court dispute settlement bodies and actions against repeat offenders.

Since the DSA follows a proportionate approach, micro and small enterprises (≤€10M annual turnover OR ≤50 employees) are exempt—unless designated as VLOPs/VLOSEs.

📘 Unsure which category your service falls under? Check out our DSA guide!

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 4^th 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 1^st 2025.

As a non-VLOP, you are required to publish your Transparency Report (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 period runs from February 17^th, 2024, to any time between December 31^st, 2024, and February 17^th, 2025 (depending on the platform’s chosen reporting period closure date). Services will have until – at the latest – April 17^th, 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 1^st – December 31^st) and will be due at the latest two months after—by February 28^th of the following year.

✏️ Complex? Here’s a summary breaking down reporting periods and the required format for the next two years:

For the first-ever DSA transparency report required from online platforms, both the reporting period and the publication deadline are flexible.

• 🗓️ 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.

For the transparency report referring to 2025 and due in 2026, services will have to start factoring the implementing regulation, entering into force in July 2025.

• 🗓️ Reporting Period: 1 January 2025 – 31 December 2025;
• ⏰ Publication Deadline: By 28 February 2026;
• 📝 Format: First semester (January – June) –  Use of the Implementing Regulation template is encouraged but not mandatory; Second semester (June – December) –Mandatory use of the Implementing Regulation template.

For the transparency report referring to 2026 and due in 2027, services are expected to standardise their practices and fully align with the templates provided in the Implementing Regulation.

• 🗓️ 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.

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 & Safety 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 🇬🇧.