Artifact GuideEU

EU Digital Services Act FAQ

Direct answers to recurring DSA questions about service scope, online platform duties, VLOP and VLOSE designation, content moderation notices, statements of reasons, trader traceability, recommenders, risk assessments, transparency reports, penalties, and complaints.

Use the cited EU sources to separate baseline intermediary duties from extra obligations for hosting services, online platforms, marketplaces, and designated very large services.

Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
FAQ modules
6

Structured answer sets in this page tree.

Primary sources
10

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 9, 2026
Overview

This EU Digital Services Act FAQ explains the main DSA duties a website visitor is likely to search for: which services are covered, when platform-specific rules apply, what VLOP and VLOSE status changes, how illegal-content notices and statements of reasons work, what marketplaces must collect from traders, what recommender disclosures must say, what designated very large services must assess and report, how penalties are capped, and how users can complain.

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Question 1

Which services are covered by the EU Digital Services Act?

The DSA applies to providers of intermediary services offered to recipients in the EU where there is a substantial connection to the Union. The core service categories are mere conduit, caching, and hosting services.

The duties then build by service type. Hosting services store information provided by users. Online platforms are a subset of hosting services that also disseminate that information to the public at a user's request, such as marketplaces, app stores, and social networks. Very large online platforms and very large online search engines have additional obligations only after Commission designation.

  • Do not treat every website or SaaS product as an online platform; first identify whether the service is an intermediary service and then whether it is hosting, an online platform, a marketplace, an online search engine, a VLOP, or a VLOSE.
  • Micro and small enterprise carve-outs can remove some online-platform duties, but designated VLOPs and VLOSEs remain subject to the very-large-service regime.
  • Mere technical accessibility from the EU is not enough by itself; the regulation points to establishment, significant recipient numbers, or targeting of activities toward one or more Member States.
Question 2

When does a service become a VLOP or VLOSE under the DSA?

An online platform or online search engine reaches the DSA very-large-service threshold when it has average monthly active recipients in the EU equal to or higher than 45 million. The Commission designates qualifying services as very large online platforms or very large online search engines.

Once designated, the service has four months to comply with the enhanced DSA duties. Providers of online platforms and online search engines must publish average monthly active recipient numbers for each service at least every six months.

  • Count active recipients per online platform or online search engine service, not at company group level alone.
  • Keep the published methodology, reporting period, and service boundary consistent enough for Commission or Digital Services Coordinator review.
  • A designation can be terminated if the service stays below the threshold for an uninterrupted year.
Question 3

What must hosting services and online platforms do for illegal-content notices and statements of reasons?

Hosting providers must provide easy-to-access electronic notice-and-action mechanisms for information that a person or entity considers illegal content. A sufficiently precise and substantiated notice can give the provider actual knowledge or awareness for the specific item of information concerned.

When a hosting provider removes, disables access to, demotes, demonetises, suspends, terminates, or otherwise restricts content, service access, payments, visibility, or accounts because of alleged illegality or terms-and-conditions incompatibility, it must give the affected recipient a clear and specific statement of reasons. Online platforms must also send those statements of reasons to the Commission's public, machine-readable DSA Transparency Database without personal data.

  • A notice should identify the alleged illegal content, explain why it is illegal, provide the exact electronic location where possible, and include the notifier's contact details except where special DSA exceptions apply.
  • A statement of reasons should explain the restriction, facts and circumstances, whether automation was used, the legal or terms basis, and available redress.
  • Trusted flagger notices submitted through Article 16 mechanisms receive priority handling by online platforms, but all notices must still be processed in a timely, diligent, non-arbitrary, and objective way.
Question 4

What DSA duties apply to marketplaces, recommender systems, and user complaints?

Online platforms that let consumers conclude distance contracts with traders have trader-traceability duties. Before allowing traders to offer products or services, they must collect specified trader information, make best efforts to assess whether it is complete, design the interface so traders can provide required product and compliance information, and take steps when they become aware of illegal products or services.

Online platforms using recommender systems must explain the main parameters used by those systems and any options for recipients to modify or influence them. VLOPs and VLOSEs that use recommender systems must also provide at least one option that is not based on profiling.

Recipients can contest qualifying online-platform moderation decisions through internal complaint-handling systems. They can also use certified out-of-court dispute settlement bodies for content moderation disputes, and they retain access to courts.

  • Trader traceability records should cover the trader's identity and contact details, payment account details where applicable, trade register details where applicable, self-certification to offer only compliant products or services, and supporting checks required by Article 30.
  • If an illegal product or service was offered, Article 32 requires notice to affected consumers where contact details are available, and public interface information where they are not.
  • Complaint handling must be accessible, timely, non-discriminatory, non-arbitrary, and subject to human review where automated means were used.
Question 5

What extra risk, audit, transparency reporting, and penalty rules matter most under the DSA?

Designated VLOPs and VLOSEs must identify, analyse, and assess systemic risks linked to their service design, functioning, algorithmic systems, and use. The DSA names systemic-risk areas including illegal content, fundamental rights, civic discourse and electoral processes, public security, gender-based violence, public health, minors, and serious effects on physical and mental well-being.

Those very large services must put in place reasonable, proportionate, and effective mitigation measures, maintain an internal compliance function, undergo independent audits at least annually, provide data access where required, publish six-monthly transparency reports, and make public risk assessment, mitigation, audit, and audit implementation reports within the Article 42 framework.

For penalties, Member States must set effective, proportionate, and dissuasive penalties for providers within their competence. The DSA caps maximum fines for obligation failures at 6% of annual worldwide turnover, caps certain information or inspection failures at 1% of annual income or worldwide turnover, and caps periodic penalty payments at 5% of average daily worldwide turnover or income per day. The Commission has separate enforcement powers for designated VLOPs and VLOSEs.

Who enforces the EU Digital Services Act?

Digital Services Coordinators supervise and enforce DSA compliance for providers of intermediary services established in their territory, while the European Commission has exclusive competence for the enhanced due-diligence obligations imposed on designated VLOPs and VLOSEs.

What is the maximum DSA fine for failing to comply with an obligation?

For providers within Member State competence, the DSA requires Member States to ensure that the maximum fine for failure to comply with an obligation is 6% of the provider's annual worldwide turnover in the preceding financial year. Separate 1% and daily 5% caps apply to specified information, inspection, and periodic penalty-payment situations.

  • Baseline transparency reporting under Article 15 covers moderation, notices, complaints, automation, and other required metrics, subject to DSA scope limits and carve-outs.
  • Article 42 adds more frequent and more detailed reporting for VLOPs and VLOSEs, including moderation resources by EU language and public versions of risk and audit materials.
  • Recipients of intermediary services can lodge a DSA infringement complaint with the Digital Services Coordinator in the Member State where they are located or established.
Recommended next step for the EU Digital Services Act

Turn DSA FAQ answers into implementation evidence

Sorena can help translate DSA scope, notice handling, statement-of-reasons, marketplace, recommender, VLOP/VLOSE, reporting, complaint, and penalty questions into cited controls and review records.

Primary sources

References and citations

digital-strategy.ec.europa.eu
Referenced sections
  • Commission source explaining how users can contest online-platform content moderation decisions through certified out-of-court dispute settlement bodies.
"Users can contest moderation decisions by online platforms"
digital-strategy.ec.europa.eu
Referenced sections
  • Commission FAQ explaining what statements of reasons are, which providers submit them, and what is excluded from public database publication.
"clear and specific information, called statements of reasons"
digital-strategy.ec.europa.eu
Referenced sections
  • Commission overview explaining that DSA obligations differ across intermediary services, hosting services, online platforms, and very large services.
"The Digital Services Act"
eur-lex.europa.eu
Referenced sections
  • Articles 15, 34, 35, 37, 42, 52, 53, 74, and 76 support transparency reporting, VLOP/VLOSE systemic-risk duties, audit duties, complaint rights, and penalty caps.
"maximum amount of fines"
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