Your 8-Step Path to DSA Compliance
Complete implementation roadmap for achieving DSA compliance. From service classification to risk mitigation, this guide walks you through every requirement with practical timelines and expert guidance.
DSA Implementation Timeline
DSA has been fully operational since February 2024. Most platforms need 3-6 months for basic compliance, while VLOPs require 6-12 months for comprehensive implementation.
Weeks 1-2
Service Classification
Weeks 3-10
Content Moderation & Transparency
Weeks 11-20
Risk Assessment (VLOPs)
Week 21+
Auditing & Monitoring
Risk Management & Governance Framework for DSA
Since DSA is new legislation, there's no single "DSA standard" yet. However, proven governance and risk management frameworks provide the structured foundation for platform compliance and accountability.
ENISA Guidance - EU Platform Risk Methodology
ENISA is developing specific guidance on systemic risk methodologies for online platforms. This evolving framework provides EU-specific interpretation of DSA risk requirements, especially valuable for Very Large Online Platforms conducting mandatory risk assessments.
Platform Governance & Accountability
Build systematic governance for content moderation and user protection
ISO 31000 Risk Management (Core)
Systematic risk management principles for identifying and mitigating platform-specific societal risks.
- • Systemic risk identification and assessment methodology
- • Democratic processes and fundamental rights impact analysis
- • Algorithmic amplification risk evaluation
- • Stakeholder engagement and risk communication
ISO/IEC 27001 ISMS (Foundation)
Information Security Management System providing governance backbone for platform operations.
- • Management commitment and resource allocation
- • Risk-based approach to platform security
- • Continuous improvement cycle (Plan-Do-Check-Act)
COBIT 2019 Governance
Enterprise governance framework supporting DSA audit and reporting requirements.
- • Board-level accountability for platform risks
- • Stakeholder value optimization
- • Performance measurement and reporting
Best for: Large platforms requiring comprehensive governance, VLOPs/VLOSEs with direct EU Commission supervision, and platforms seeking formal risk management certification.
Transparency & External Assurance
Structured reporting and independent audit frameworks
ISAE 3000 Assurance (Primary)
International standard for assurance engagements providing independent verification of DSA controls effectiveness.
- • Independent auditor assessment of risk mitigation measures
- • Structured assurance reporting to regulators
- • Evidence-based control effectiveness evaluation
- • Professional auditor qualification requirements
SOC 2 Trust Services Criteria
Service organization controls for security, availability, and integrity of platform operations.
- • Security controls for content moderation systems
- • Availability assurance for user reporting mechanisms
- • Processing integrity for algorithmic systems
ISO/IEC 27701 User Transparency
Privacy management controls supporting DSA transparency obligations for user data processing.
- • Algorithm transparency and explainability
- • User data processing accountability
- • Data subject rights implementation
Best for: Platforms requiring external audit validation, organizations with existing SOC 2 programs, and VLOPs needing structured assurance reporting to EU authorities.
AI & Algorithm Governance
For platforms with AI-driven recommender systems:
- • ISO/IEC 23894: AI risk management framework
- • NIST AI RMF: Trustworthy AI development and deployment
- • ISO/IEC 38500: IT governance for algorithmic decision-making
Business Continuity (VLOPs)
For large platforms with critical infrastructure needs:
- • ISO 22301: Business continuity management
- • ISO/IEC 27035: Incident response for platform disruptions
- • Crisis management: Coordinated response to systemic events
Complete DSA Implementation Roadmap
Follow these 8 proven steps to achieve full DSA compliance. Each step builds on the previous one, ensuring you create a comprehensive digital governance program that protects users and meets regulatory requirements.
1. Determine Your Service Category
Identify which type of digital service you provide and what obligations apply
Key Actions
- Check if you're an intermediary service (hosting, caching, mere conduit)
- Determine if you qualify as an online platform
- Calculate monthly active users in the EU
- Check if you're a Very Large Online Platform (45M+ EU users)
Available Tools
Real Examples
2. Set Up Notice-and-Action System
Create mechanisms for users to report illegal content and for you to respond
Key Actions
- Implement easy-to-use reporting mechanisms
- Create clear content policies and community guidelines
- Set up processes to review and act on reports
- Establish appeals and counter-notification procedures
Available Tools
Real Examples
3. Implement Transparency Requirements
Provide clear information about your content moderation and recommendation systems
Key Actions
- Create transparency reports on content moderation
- Publish clear terms of service
- Explain how recommendation algorithms work
- Document content moderation decisions with statements of reasons
Available Tools
Real Examples
4. Implement ISO 31000 Risk Assessment (VLOPs only)
Conduct systematic risk management using proven framework for societal impact assessment
Key Actions
- Apply ISO 31000 risk management principles to identify systemic risks
- Assess risks to fundamental rights using structured methodology
- Evaluate democratic processes and public security impacts
- Review algorithmic amplification effects on society and minors
Available Tools
Real Examples
5. Implement Risk Mitigation Measures (VLOPs only)
Put in place measures to address identified systemic risks
Key Actions
- Modify recommendation systems to reduce harmful content amplification
- Implement stronger content moderation for high-risk content
- Add safeguards for democratic processes during elections
- Enhance protections for minors and vulnerable users
Available Tools
Real Examples
6. Implement ISAE 3000/SOC 2 Assurance (VLOPs only)
Obtain independent assurance using proven audit frameworks for controls assessment
Key Actions
- Engage ISAE 3000 qualified auditors for assurance reporting
- Implement SOC 2 Trust Services Criteria for security and availability
- Provide evidence of control effectiveness for risk mitigation measures
- Submit structured assurance reports to the European Commission
Available Tools
Real Examples
7. Provide Data Access to Researchers (VLOPs only)
Grant qualified researchers access to platform data for studying systemic risks
Key Actions
- Establish data access procedures for qualified researchers
- Implement privacy-preserving data sharing mechanisms
- Respond to research data requests within specified timeframes
- Maintain records of data access and research activities
Available Tools
Real Examples
8. Maintain Ongoing Compliance
Continuously monitor and improve your DSA compliance program
Key Actions
- Monitor content moderation effectiveness
- Update risk assessments regularly
- Submit required transparency reports
- Respond to regulatory requests and investigations
Available Tools
Real Examples
DSA Quick Reference
Key thresholds, requirements, and penalties at a glance
Platform Categories
- • Hosting: Basic intermediary obligations
- • Platform: Enhanced content moderation
- • VLOP: 45M+ EU users, full requirements
- • Search: Including VLOSE category
Core Requirements
- • Notice-and-action mechanisms
- • Transparency reporting (annual)
- • Algorithm transparency & user control
- • Risk assessment & mitigation (VLOPs)
- • External auditing (VLOPs)
Maximum Penalties
- • Standard: €18M or 6% revenue
- • Severe: EU market ban possible
- • Interim measures for ongoing violations
- • Structural remedies for systematic issues
Supporting Tools and Resources
Everything you need to implement and maintain DSA compliance
ISO 31000 Risk Mapper
Apply systematic risk management framework to DSA requirements
Platform Checker
Check if DSA applies to your digital service
Content Policy Templates
Community guidelines and terms of service templates
Transparency Report Builder
Generate annual transparency reports with standardized templates
Risk Assessment Tool
Assess systemic risks for VLOPs and VLOSEs
User Control Systems
Implement user choice and control mechanisms