DSA recommender transparency FAQ

Article 27 applies to providers of online platforms that use recommender systems. The DSA defines a recommender system as a fully or partly automated system that suggests information, prioritises it, or determines the relative order or prominence of information in the platform interface.

The platform must set out, in its terms and conditions and in plain, intelligible language, the main parameters used by the recommender system and any options recipients have to modify or influence those parameters.

Article 27 distinguishes between disclosure of options and in-product functionality. If several options are available for a recommender system that determines the relative order of information, the platform must let the recipient select and modify the preferred option at any time.

That control must be directly and easily accessible from the specific part of the online interface where information is being prioritised. A buried account setting is weak evidence if the ranking choice is presented somewhere else.

Article 38 adds a separate requirement for providers of very large online platforms and very large online search engines that use recommender systems. In addition to Article 27, they must provide at least one option for each recommender system that is not based on profiling under the GDPR definition referenced by the DSA.

The Commission describes VLOPs and VLOSEs as platforms or search engines with equal to or higher than 45 million monthly users in the EU once designated. For those designated services, the recommender inventory should show each recommender system and the matching non-profiling option.

Keep enough evidence to prove that the public disclosure, the live user interface, and the recommender implementation describe the same system. This is especially important for VLOPs and VLOSEs because DSA risk assessment, mitigation, audit, and data-access provisions can require explanations of algorithmic-system design, logic, functioning, and testing.

The evidence record should avoid invented scoring formulas. Use the real product documentation: criteria that matter most, reasons those criteria matter, UI choices available to recipients, and release records showing when the disclosure changed.