Shortcomings of the first DSA Audits — and how to do better

June 11, 2025/in Analysis

By Daniel Holznagel

At the end of 2024, the first audit reports under the Digital Services Act were published. Most were produced by Big Four accounting firms — and were, in many ways, not very ambitious. This post collects impressions from digesting most (not all) of these reports, focusing on five structural shortcomings that severely limit their usefulness: from illegitimate audit gaps to auditors’ apparent reluctance to interpret the law or meaningfully assess systemic risks (especially around recommender systems). The post also highlights a few useful disclosures — including platform-defined compliance benchmarks — and outlines where auditors, regulators, and civil society should push for improvements in future rounds.

DSA Audits: How do platforms compare on influencer marketing disclosures?

June 2, 2025/in Analysis

By Taylor Annabell, Utrecht University

Under the DSA, social media platforms must provide clear tools for influencers to disclose paid content. But how well do they meet this obligation, and how rigorously is compliance assessed? This post compares eight DSA audit reports on influencer marketing disclosures under Article 26(2) and finds striking inconsistencies in how audits were conducted, what was measured, and how “compliance” was defined. The findings raise broader concerns about audit transparency, platform-defined standards, and the need for clearer guidance on what adequate disclosure—and meaningful oversight—should look like.

Workshop Report: Researchers on Data Access and Preparing for DSA Article 40(4)

May 23, 2025/in Analysis

By John Albert and Paddy Leerssen, DSA Observatory

Drawing on a March 2025 workshop hosted by the DSA Observatory, this post shares practical and strategic insights from researchers preparing to make use of Article 40(4), from scoping proposals and navigating compliance to building collective support structures.

Expert insights: Fundamental rights in DSA dispute resolution procedures

January 20, 2025/in Analysis

By John Albert, DSA Observatory

Despite claims that it is “institutionalizing censorship,” the DSA is designed to protect fundamental rights, including freedom of expression. One key example is its provision allowing EU users to challenge platforms’ content moderation decisions through out-of-court dispute settlement (ODS) proceedings—a topic explored in depth at a recent workshop hosted by the DSA Observatory and the Article 21 Academic Advisory Board.

DSA risk assessment reports: A guide to the first rollout and what’s next

December 9, 2024/in Analysis

By John Albert, DSA Observatory

Recently published risk assessment reports may offer new insights into how the largest online platforms think about and manage risks. But the first rollout has already raised questions about publication timelines, redactions, and formats. This post aims to clarify some of these ambiguities, and points toward upcoming regulatory guidance on risk assessments and opportunities for stakeholder engagement.