Fully in Effect Since Feb 17, 2024 - Compliance Required

Digital Services Act (DSA)

If you operate online platforms, marketplaces, social media, hosting services, or search engines serving EU users, DSA requires transparent content moderation, user protection measures, and systemic risk management for the largest platforms.

45M users
VLOP threshold
6% turnover
Maximum fine
1+ years
Fully operational

DSA in Plain English

The Digital Services Act is the EU's comprehensive law for online platforms and digital services. If you run any website, app, or service where users can post content, buy products, or interact with each other, DSA requires you to moderate illegal content, be transparent about your operations, and protect users' fundamental rights.

Think of DSA as establishing digital citizenship rules, similar to how physical spaces have laws and regulations. Just as a shopping mall must ensure safety, handle complaints, and follow building codes, digital platforms must ensure online safety, handle user reports, and follow digital governance standards. The bigger your platform, the more responsibilities you have—like how larger shopping centers need more security, emergency procedures, and public accommodations.

What makes DSA unique? Unlike previous internet regulations, DSA doesn't just focus on removing bad content—it requires platforms to actively protect democratic processes, prevent systemic risks to society, and give users meaningful control over their digital experience. This represents a fundamental shift from reactive content moderation to proactive digital responsibility and user empowerment.

Built on Risk Management Standards: Since DSA is new legislation, compliance is best achieved through proven governance frameworks. ISO 31000 for systemic risk management, ISO/IEC 27001 for governance and accountability, ISO/IEC 27701 for transparency obligations, and ISAE 3000/SOC 2 for external assurance reporting provide the structured foundation. ENISA guidance offers EU-specific methodology for platform risk assessment.

Applies to ALL digital services serving EU users, regardless of company location or size
Covers hosting, platforms, marketplaces, social media, search engines, and app stores
Requires transparent content moderation with clear appeal processes and user rights
Very Large Platforms (45M+ EU users) must assess and mitigate societal risks
Algorithm transparency mandatory—users must understand and control recommendations
Hefty penalties up to 6% of global revenue, with potential EU market bans
Real-time enforcement with direct European Commission supervision for largest platforms
Extends beyond illegal content to address systemic risks to democracy and society
ISO 31000 provides systematic approach to platform risk management and governance
ISAE 3000/SOC 2 frameworks support required external assurance and audit requirements

Why DSA Compliance Matters for Your Business

Beyond avoiding penalties, DSA compliance represents a strategic advantage. Companies that implement security by design reduce their risk of costly breaches, build customer trust, and gain competitive differentiation in an increasingly security-conscious market.

85%
reduction in security incidents with proactive compliance
3x
faster time-to-market with early security integration
67%
of customers prefer security-certified products

What DSA Actually Requires You to Do

The DSA establishes essential cybersecurity requirements that apply throughout your product's lifecycle. These aren't just theoretical guidelines—they're practical obligations with legal consequences.

Think of it this way: Just as you need safety standards for physical products (crash tests for cars, fire safety for electronics), the DSA creates mandatory security standards for digital products. Every requirement serves a specific purpose in protecting end users and the broader digital ecosystem.

Core Requirement 1

Content Moderation

Remove illegal content and provide clear policies

This means integrating security considerations from the very first design sketches. No more 'we'll add security later'—it must be part of your core product development process from day one.

Specific Requirements:

• Notice-and-action mechanisms
• Clear community guidelines
• Statements of reasons for decisions

💡 Practical Tip:

Start by conducting threat modeling sessions during your product planning phase. Many teams find Microsoft's STRIDE methodology helpful for systematic threat identification.

Core Requirement 2

Transparency Reporting

Publish regular reports on content moderation activities

You must establish a coordinated vulnerability disclosure process, maintain security throughout the product lifecycle, and respond quickly to security issues. This isn't just about fixing bugs—it's about professional incident response.

Specific Requirements:

• Annual transparency reports
• Content removal statistics
• Automated moderation accuracy

💡 Practical Tip:

Set up a security@yourcompany.com email address and establish SLAs for response times. Consider partnering with vulnerability disclosure platforms like HackerOne or Bugcrowd.

Core Requirement 3

Risk Management (VLOPs)

Assess and mitigate systemic risks to society

Clear, accessible documentation helps users understand security features and configure products safely. This reduces support calls and prevents security misconfigurations that could lead to breaches.

Specific Requirements:

• Annual risk assessments
• Mitigation measures
• Independent auditing

💡 Practical Tip:

Create user-friendly security guides alongside your regular documentation. Include clear setup instructions, common security mistakes to avoid, and troubleshooting guidance.

Core Requirement 4

User Protection

Protect users, especially minors, from harmful content

Products must be assessed for their potential impact if compromised. Critical infrastructure products face stricter requirements than consumer apps, reflecting their different risk profiles.

Specific Requirements:

• Age verification systems
• Parental controls
• Mental health safeguards

💡 Practical Tip:

Use risk assessment frameworks like NIST Cybersecurity Framework to systematically evaluate your product's risk level. Document your reasoning for audit purposes.

Core Requirement 5

Data Access (VLOPs)

Provide data access to researchers and authorities

You're responsible for the security of all components in your product, including third-party libraries and dependencies. This creates accountability throughout the entire supply chain.

Specific Requirements:

• Researcher data sharing
• Regulatory cooperation
• Privacy-preserving methods

💡 Practical Tip:

Implement Software Bill of Materials (SBOM) tracking from the start. Tools like Syft, CycloneDX, or SPDX can help automate component inventory management.

Core Requirement 6

Algorithm Accountability

Explain how recommendation systems work

CE marking for cybersecurity works like CE marking for other product safety aspects. It's your declaration that the product meets EU security requirements and is safe to place on the market.

Specific Requirements:

• Algorithm transparency
• User control options
• Bias assessment and mitigation

💡 Practical Tip:

Work with a notified body early in your process to understand specific conformity assessment requirements for your product category and risk level.

The Bottom Line

DSA requirements aren't just compliance checkboxes—they represent cybersecurity best practices that protect your customers, your business, and the broader digital ecosystem. Companies that implement these requirements early often find they reduce long-term security costs while building stronger, more trustworthy products.

Common DSA Questions

What types of services does DSA cover?

DSA has a tiered approach covering different types of digital services:

  • Intermediary services: Hosting, caching, internet access providers
  • Online platforms: Social media, marketplaces, app stores, travel booking
  • Very Large Online Platforms (VLOPs): Platforms with 45M+ monthly EU users
  • Search engines: Including Very Large Online Search Engines (VLOSEs)

What counts as illegal content under DSA?

DSA doesn't define illegal content - it refers to existing EU and national laws:

  • Content that violates EU criminal law (terrorism, child exploitation)
  • Content that violates national laws (hate speech, defamation)
  • Intellectual property violations (copyright infringement)
  • Consumer protection violations (fraudulent products, false advertising)

What are the main differences between platform tiers?

DSA obligations increase based on platform size and impact:

  • All platforms: Notice-and-action, transparency, illegal content removal
  • Online platforms: Additional user protection measures, appeals processes
  • VLOPs/VLOSEs: Risk assessments, mitigation measures, external audits, researcher access

How does DSA affect recommendation algorithms?

DSA requires transparency and user control over algorithmic systems:

  • Platforms must explain how recommendations work in plain language
  • Users must have options to modify or disable personalized recommendations
  • VLOPs must assess risks from their algorithmic amplification
  • Algorithm design changes may be required to mitigate identified risks

What about freedom of expression concerns?

DSA aims to balance content moderation with fundamental rights protection:

  • Platforms must consider fundamental rights in all moderation decisions
  • Users have right to appeal content moderation decisions
  • Independent dispute resolution mechanisms required
  • Over-removal of legal content should be avoided

How does DSA enforcement work?

DSA enforcement varies based on platform size:

  • National authorities supervise smaller platforms and services
  • European Commission directly supervises VLOPs and VLOSEs
  • Fines up to 6% of global annual turnover for violations
  • Repeated violations can lead to EU market bans

Which standards should I use for DSA compliance?

Since DSA is new, established governance and risk frameworks provide the best foundation:

  • ISO 31000: Systematic risk management for identifying and mitigating societal risks
  • ISO/IEC 27001: Governance and accountability frameworks for platform operations
  • ISO/IEC 27701: Transparency and user data protection for privacy obligations
  • ISAE 3000/SOC 2: External assurance frameworks for audit and reporting requirements
  • ENISA Guidelines: EU-specific risk methodologies and implementation guidance

🤝 Still Feeling Overwhelmed?

EU cybersecurity laws can be complex. Our free tools and guides work great for most people, but if you're dealing with something particularly challenging or have tight deadlines, we're here to help.