Who speaks and who is heard? Civil society participation and participatory justice in DSA systemic risk management

February 17, 2026/in Analysis

By Mateus Correia de Carvalho (PhD researcher, EUI) and Rachel Griffin (postdoctoral researcher, Duisburg-Essen University)

This post presents the report ‘Who speaks and who is heard?’ on civil society participation and participatory justice in DSA systemic risk management. In it, we examine the early practice of DSA participation to understand how it is unfolding in practice. Drawing on a qualitative empirical study with civil society actors of diverse backgrounds, perspectives, and activities, we traced the mechanisms used by those actors, their perceptions about the usefulness of different spaces of participation, the strategic considerations determining when, where, whether, and how to participate, as well as the obstacles and inequalities hampering meaningful participation. Regarding these inequalities, we propose to understand them as a matter of participatory justice, making some recommendations to improve the overall inclusiveness of DSA participation in systemic risk management. 

The Missing Metrics in DSA Content Moderation Transparency

January 8, 2026/in Analysis

By Max Davy, Oxford Internet Institute

The Digital Services Act makes platform transparency reporting mandatory and standardised, but the metrics it requires still fall short of what is needed for real accountability. Counts of removals and appeals alone cannot tell us whether content moderation systems are accurate, proportionate, or effective, making the absence of evaluation metrics such as precision and recall increasingly difficult to justify under the DSA’s risk-based logic. While these metrics are unlikely to surface in baseline transparency reports under Articles 15 and 24, the post argues they may yet emerge through heightened scrutiny of the largest online platforms and search engines (VLOPSEs), as regulatory expectations take shape through enforcement, systemic risk reporting, audits, and related obligations.

Waiting for the DSA’s Big Enforcement Moment

November 26, 2025/in Analysis

By Magdalena Jóźwiak, DSA Observatory (University of Amsterdam)   This blog post explores the issue of DSA enforcement by the European Commission, focusing on the law’s systemic risk management provisions. It first briefly sketches the Commission’s role in regulatory oversight of the systemic risk framework and then sums up enforcement efforts to date, considering also […]

Investigation: Platforms still use manipulative design despite DSA rules

August 7, 2025/in Analysis

By Chitra Mohanlal, Tech Researcher at Bits of Freedom

Our recent investigation into a selection of Very Large Online Platforms reveals multiple potential breaches of the DSA relating to manipulative design (Article 25), recommender system transparency (Article 27), and the obligation to offer alternative recommender systems (Article 38). The report explains and illustrates several types of manipulative design practices on platforms including Facebook, Snapchat, TikTok, Shein, Zalando and Booking.com. These findings can be used to support enforcement actions under the DSA.

The Commission’s approach to age assurance: Do the DSA Guidelines on protecting minors online strike the right balance?

July 31, 2025/in Analysis

By Sophie Stalla-Bourdillon, (Brussels Privacy Hub, LSTS, VUB)

The European Commission’s guidelines on protecting minors online take important steps toward building a comprehensive list of relevant service design and organizational measures that are relevant under Article 28(1) DSA. But in doing so, they also risk oversimplifying a complex regulatory trade-off that underlies the deployment of age assurance methods. This blog post argues that the guidelines overstate the proportionality of age verification and age estimation methods, sideline key data protection concerns, and miss the opportunity to articulate the implications of a rights-based, privacy-preserving design for all users.