EU Digital Services Act deadlines and compliance calendar

The DSA entered force after publication in the Official Journal and applies generally from 17 February 2024. Several provisions applied earlier from 16 November 2022, including the user-number publication and designation machinery used for VLOP and VLOSE supervision.

For most providers, 17 February 2024 is the baseline date for DSA operating readiness. For online platforms and online search engines that may approach VLOP or VLOSE scale, the earlier Article 24 and Article 33 provisions matter because they drive user-number publication and designation evidence.

The DSA threshold for very large online platforms and very large online search engines is 45 million average monthly active recipients in the Union. The Commission designates a service after considering reported user numbers, requests, or other available information.

Once designated, a VLOP or VLOSE has four months to comply with the DSA obligations that apply to very large services. The first set of 19 VLOPs and VLOSEs was designated on 25 April 2023 and had to comply by the end of August 2023.

Article 15 transparency reports are not a one-time publication. The 2024 transparency-reporting implementing regulation creates harmonised templates, reporting periods, transition rules, publication timing, and retention expectations.

For ordinary intermediary, hosting, and online-platform providers, the first DSA annual transparency report after full application had to be published no later than 16 February 2025. The transition period ends on 31 December 2025, and from 1 January 2026 the annual reporting period is 1 January to 31 December. Reports are due no later than two months after the reporting period ends.

Very large online platforms and very large online search engines have a shorter reporting rhythm than ordinary providers. Article 42 requires them to publish the Article 15 reports within two months from their DSA application date under the designation rule and thereafter at least every six months.

The implementing regulation also gives VLOPs and VLOSEs a specific template transition: they collect information under the Annex instructions from 1 July 2025, and their first reporting cycle under those templates covers 1 July to 31 December 2025.

Statement-of-reasons work is event driven rather than annual. Article 17 requires hosting services to give affected users a clear and specific statement of reasons for covered restrictions, and Article 24(5) requires online platforms to submit relevant decisions and statements of reasons to the Commission database without undue delay.

The practical calendar control is a daily or near-real-time queue, not a year-end report. The provider should reconcile moderation decisions, user notices, personal-data removal, and database submission status so that missing submissions are visible quickly.

A useful DSA calendar should distinguish fixed legal dates, repeating publication cycles, designation-triggered due dates, and event-driven evidence queues. Mixing those clocks is how teams miss obligations or overstate dates that apply only to VLOPs and VLOSEs.

Keep the calendar as a controlled record with one line per service and clock. Do not copy a VLOP/VLOSE date to an ordinary intermediary service unless the service has actually been designated or the source supports the same duty.