Transparency Reporting and the Digital Services Act

One month to go. If you provide an online platform or intermediary service in the EU, new Digital Services Act transparency reporting rules now apply. Michael Madden, Data & Technology partner, outlines what has changed, key deadlines and why many providers are still grappling with the new reporting templates ahead of the 28 February deadline.

If you provide an online platform or other intermediary service in the EU, the EU's Digital Services Act (DSA) has made transparency reporting much more demanding.

Under Article 15 of the DSA, in-scope services must publish reports explaining how they moderate content as well as relevant statistics regarding such moderation. Most services must do this annually, but very large online platforms and search engines must report every six months.

As we reported in a previous article, that obligation changed on 1 July 2025 after which providers were required to use new, detailed reporting templates adopted by the European Commission, which require far more granular information than before.

The Commission has also aligned all reporting periods to the calendar year. This means, for annual reporters, the full year to 31 December and, for very large services, one report for January to June and another for July to December. These new-format reports must be published within two months of the end of the period to which they relate, so the first deadline using the new templates for all service providers is 28 February.

There are also some key practical points to consider. For example, providers are required to publish a transparency report for each service that they offer and need to consider how to incorporate information for the period prior to the new detailed rules applying. While providers are entitled to publish updated versions of reports for the purpose of correcting inaccuracies, errors, or methodological changes, the Commission templates must be completed unless you can clearly justify why certain sections are not relevant. Providers are also encouraged to include an explanatory document setting out their methodology and a plain-English summary.

With the level of detail now required and the associated complexity, many organisations are still grappling with how to comply, and we expect uneven results across the market.

For further information and expert advice concerning the DSA, please get in touch with a member of our Data & Technology team.

This content is provided for information purposes only and does not constitute legal or other advice.