Artifact GuideEU

EU Digital Services Act (DSA) Deadlines & Compliance Calendar

Key dates and cadences you can plug into your governance calendar.

Includes general applicability, the 2025 reporting-template transition, AMAR publication cadence, VLOP or VLOSE designation windows, and annual risk and audit cycles.

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Author

Sorena AI

Published

Feb 21, 2026

Updated

Feb 21, 2026

Sections

Structured answer sets in this page tree.

Primary sources

Cited legal and guidance references.

Publication metadata

Sorena AI

Published Feb 21, 2026

Updated Feb 21, 2026

Overview

DSA compliance is not just an initial rollout. It now runs on fixed cadences for transparency reporting, average monthly active recipients publication, and, for VLOPs and VLOSEs, systemic risk assessment and independent audits. Use this page to build a compliance calendar with owners, evidence checkpoints, and report-publication deadlines.

Section 1

Baseline dates: publication, entry into force, and general applicability

The DSA was adopted in October 2022 and published in the Official Journal later that month.

It enters into force on the twentieth day following publication, and it has a general date of applicability in February 2024.

Adoption: 19 October 2022 (Regulation (EU) 2022/2065).
Official Journal publication: 27 October 2022 (OJ L 277).
Entry into force: twentieth day following publication (commonly calculated as 16 November 2022 for the DSA).
General date of applicability: 17 February 2024.

Section 2

Regulator readiness milestones: Digital Services Coordinators (DSCs)

National supervision is coordinated through Digital Services Coordinators (DSCs). Your compliance program should anticipate regulator questions and evidence requests once supervision is operational.

DSC designation timing matters for enforcement expectations and cross-border cooperation.

DSC designation deadline: Member States designate DSCs by 17 February 2024.
Practical impact: build an evidence pack and a regulatory response playbook before "steady state" enforcement begins.
If you are not established in the EU but offer services in the EU: legal representative readiness (Article 13) should be in place early.

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Section 3

Always-on cadence: transparency reporting for intermediary services (Article 15)

Transparency reporting is an ongoing requirement: at least once a year, publish a machine-readable report on content moderation activities, including orders, notices, complaints, own-initiative actions, and automation usage and accuracy indicators.

Treat this as a recurring data product with QA and sign-off - not a one-off document.

Cadence: at least annually (unless excluded as micro/small enterprise and not a VLOP/VLOSE).
Build a "reporting close" calendar: data freeze -> QA -> approval -> publication -> archive evidence.
Keep supporting datasets and definitions (metrics dictionary, sampling, error indicators) for enforcement questions.

Section 4

Reporting templates and harmonized reporting periods under Implementing Regulation (EU) 2024/2835

The Commission adopted a reporting-template regulation in November 2024 to harmonize how Article 15, 24, and 42 transparency reports are structured and published.

This matters operationally because 2025 includes a transitional reporting cycle and from 1 January 2026 the reporting periods are aligned across providers.

Implementing Regulation (EU) 2024/2835 was adopted on 4 November 2024 and published in the Official Journal on 5 November 2024.
Providers must use the Annex I templates as of 1 July 2025.
First annual transparency report under the DSA baseline cycle had to be published by 16 February 2025.
The second reporting cycle starts no later than 17 February 2025 and runs until 31 December 2025.
From 1 January 2026, providers follow the harmonized reporting periods in the implementing regulation and must publish each report no later than 2 months after the reporting period ends.
Published reports, including corrected versions, must remain publicly available for at least 5 years.

Section 5

Platform cadence: publish AMAR every 6 months (Article 24(2))

Online platforms and online search engines must publish the number of average monthly active recipients (AMAR) in the Union, calculated as an average over the past six months, at least once every six months.

This cadence is also a VLOP/VLOSE risk indicator because designation thresholds are based on AMAR and a Commission decision (Article 33).

Cadence: by 17 February 2023 and at least every 6 months thereafter, publish AMAR for each platform/search engine.
Operationalize AMAR: define methodology, data sources, QA controls, and executive sign-off.
Threshold monitoring: if you approach 45 million AMAR in the EU, treat VLOP/VLOSE readiness as a program (not a scramble).

Section 6

VLOP/VLOSE designation windows (Article 33) and the "4 months after notification" rule

VLOP/VLOSE obligations apply (or cease) from four months after the provider is notified of the Commission designation (or termination) decision.

This creates a predictable "tier upgrade" timeline - but only if you have prebuilt capabilities.

Trigger: Commission decision designating a service as VLOP/VLOSE (based on AMAR and other information).
Effective window: obligations apply from four months after notification (and can be earlier than 17 February 2024 for designated services).
Preparation timeline: treat "4 months" as your final integration window, not your project start date.

Section 7

VLOP/VLOSE recurring cycles: systemic risk assessment + audits + publication (Articles 34, 37, 42)

For VLOPs/VLOSEs, compliance becomes cyclical: annual risk assessments, mitigation measures, independent audits, and frequent transparency reporting.

Plan a calendar that includes remediation time and the publication deadlines.

Systemic risk assessment: at designation application date and at least annually thereafter; also before deploying features likely to critically impact risks (Article 34).
Independent audit: performed at least once a year; if findings are not fully positive, plan remediation and an audit implementation report (Article 37).
Enhanced transparency reporting: at least every 6 months (Article 42) plus publication/transmission of risk assessment outputs, mitigation measures, audit report and audit implementation report within the required windows.

Section 8

Marketplace deadlines: trader data catch-up window (Article 30 transitional rule)

Marketplaces must collect trader traceability information before allowing use - but the DSA also sets a catch-up window for traders already onboard at the general applicability date.

This is a classic "data debt" program: plan it like a migration with enforcement gates.

Existing traders as of 17 February 2024: best efforts to obtain required trader information within 12 months (Article 30(2)).
If traders fail to provide required information within that window: suspend services until complete (Article 30(2)).
Plan enforcement-friendly communication: notices, deadlines, remediation help, and suspension policy evidence.

Primary sources

References and citations

Commission Implementing Regulation (EU) 2024/2835 - Transparency reporting templates

eur-lex.europa.eu

Referenced sections

Defines harmonized templates, transitional reporting cycles, publication deadlines, format rules, and retention and versioning for Articles 15, 24, and 42 reports.

European Commission - The enforcement framework under the Digital Services Act

digital-strategy.ec.europa.eu

Referenced sections

Commission overview of applicability and enforcement, including designation and early application to VLOPs/VLOSEs.

Regulation (EU) 2022/2065 (Digital Services Act) - Official Journal

eur-lex.europa.eu

Referenced sections

Primary legal text for DSA dates and cadences (entry into force clause, general applicability date, Article 24 AMAR cadence, Article 33 designation timing, Articles 34/37/42 cycles, and marketplace transitional rule in Article 30).

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