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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. 

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.