Digital

Services

Act

transparency

reports:

focus

on

simplicity

and

usefulness

Executive summary

Transparency is important for boosting users’ trust in the internet, improving understanding of content moderation practices and ensuring accountability. Reports should be clear and ensure meaningful transparency. However, they should not be unnecessarily detailed at a time when President von der Leyen has promised to reduce companies’ reporting burdens by 25 per cent.

Under the Digital Services Act (DSA), providers of intermediary services are required to publish, at least once a year, easily comprehensible and detailed reports on any content moderation they engaged in during the previous period. The Commission has published a draft implementing act with two reporting templates and proposed harmonised reporting periods. This provides helpful guidance to companies. However, providers should have greater flexibility to publish reports which best reflect their business operations and moderation efforts. As it stands, the draft implementing regulation goes beyond the material scope of the DSA’s transparency reporting obligations, requires too much granularity, lacks flexibility in the templates, and provides too short a timeline for preparation of reports:

• The template should remain closely aligned with the DSA and not expand the requirements beyond what the law mandates;
• The focus should be on proportionality and the usefulness of the information for the intended audience, ensuring the possibility of providing context to readers; and
• Reporting guidelines should seek to simplify and harmonise reporting obligations, not generate additional engineering work that could be better deployed to improve content moderation practices.