--- title: "DSA statement of reasons FAQ" canonical_url: "https://www.sorena.io/artifacts/eu/digital-services-act/faq/statement-of-reasons" source_url: "https://www.sorena.io/artifacts/eu/digital-services-act/faq/statement-of-reasons" author: "Sorena AI" description: "When DSA statements of reasons are required, what they must contain, when online platforms submit them to the DSA Transparency Database, and what appeal records to keep." published_at: "2026-05-09" updated_at: "2026-05-09" keywords: - "EU Digital Services Act" - "DSA statement of reasons" - "Article 17 DSA" - "DSA Transparency Database" - "content moderation appeals" - "DSA" - "statement of reasons" - "content moderation" - "online platforms" --- **[SORENA](https://www.sorena.io/)** - AI-Powered GRC Platform [Home](https://www.sorena.io/) | [Solutions](https://www.sorena.io/solutions) | [Artifacts](https://www.sorena.io/artifacts) | [About Us](https://www.sorena.io/about-us) | [Contact](https://www.sorena.io/contact) | [Portal](https://app.sorena.io) --- # DSA statement of reasons FAQ When DSA statements of reasons are required, what they must contain, when online platforms submit them to the DSA Transparency Database, and what appeal records to keep. *FAQ* *EU DSA* ## DSA statement of reasons when to send one A DSA statement of reasons is required when a hosting service restricts recipient-provided information, payments, service access, or an account because the information is illegal content or incompatible with its terms. For online platforms, the same moderation record also needs a Transparency Database submission path, personal-data removal check, and redress information that lets the affected user challenge the decision. Under Article 17 of the EU Digital Services Act, providers of hosting services must give affected recipients a clear and specific statement of reasons for listed moderation restrictions when those restrictions are based on alleged illegal content or incompatibility with the provider's terms and conditions. Online platforms have an additional Article 24(5) step: submit the Article 17 decisions and statements of reasons to the Commission's public, machine-readable DSA Transparency Database without undue delay and without personal data. ## When is a DSA statement of reasons required? A statement of reasons is triggered by the moderation decision, not by the label a team gives the workflow. Article 17 applies to providers of hosting services when they impose one of the listed restrictions because information provided by a recipient of the service is considered illegal content or incompatible with the provider's terms and conditions. The covered restrictions include removing, disabling access to, demoting, or otherwise restricting visibility of specific information; suspending, terminating, or otherwise restricting monetary payments; suspending or terminating all or part of the service; and suspending or terminating the recipient's account. Article 17 applies only where the provider knows the relevant electronic contact details, and it applies at the latest from the date the restriction is imposed. It does not apply to deceptive high-volume commercial content, and it does not apply to orders covered by Article 9. - Trigger: a hosting-service restriction based on illegal content or terms-and-conditions incompatibility. - Recipient: any affected recipient of the service whose relevant electronic contact details are known. - Timing: provide the statement at the latest when the restriction is imposed. - Exclusions to check: deceptive high-volume commercial content and Article 9 orders. Sources for this answer: - [Regulation (EU) 2022/2065 (Digital Services Act), Article 17](https://eur-lex.europa.eu/eli/reg/2022/2065/oj/eng?ref=sorena.io) - Defines when hosting-service providers must give affected recipients a statement of reasons and lists the restrictions covered by Article 17. ## What must the statement contain? Article 17 requires enough detail for the affected recipient to understand the decision and exercise available redress rights. The statement should identify the moderation measure, the territorial scope and duration where relevant, the facts and circumstances relied on, and whether the decision followed an Article 16 notice or voluntary own-initiative investigation. If automated means were used, the statement should say so where applicable, including whether the moderated content was detected or identified using automated means. If the ground is alleged illegality, cite the legal ground and explain why the information is illegal on that ground. If the ground is terms incompatibility, cite the contractual ground and explain why the information conflicts with it. Redress information is part of the statement itself. For platform decisions, that means the recipient-facing notice should connect the user to the internal complaint-handling route where available, out-of-court dispute settlement where applicable, and judicial redress. - Decision type: removal, disabling access, demotion, visibility restriction, payment restriction, service restriction, or account restriction. - Scope and duration: territory and time period where relevant. - Basis: facts, circumstances, notice source or own-initiative review, and legal or contractual ground. - Automation: whether automated means were used where applicable. - Redress: clear, user-friendly complaint, out-of-court dispute settlement, and court options where applicable. Sources for this answer: - [Regulation (EU) 2022/2065 (Digital Services Act), Article 17](https://eur-lex.europa.eu/eli/reg/2022/2065/oj/eng?ref=sorena.io) - Lists the minimum content of a statement of reasons, including measure, facts, automation, legal or contractual basis, and redress information. ## What changes for online platforms and the Transparency Database? The DSA Transparency Database does not collect every hosting-service statement of reasons. The Commission FAQ explains that it collects statements of reasons from online platforms, which are a subset of hosting services that store user-provided information and disseminate it publicly, such as online marketplaces, app stores, or social networks. For online platforms, Article 24(5) requires submission of the Article 17 decisions and statements of reasons to the Commission without undue delay for inclusion in a publicly accessible, machine-readable database. The submitted information must not contain personal data. The Commission FAQ says redress options are not included in the public database because they are relevant only for the addressee of the statement of reasons. Operationally, keep the recipient-facing statement with redress information separately from the public database payload, and keep a personal-data removal check before submission. - Determine whether the service is an online platform, not only a hosting service. - Submit Article 17 decisions and statements of reasons to the Commission without undue delay where Article 24(5) applies. - Remove personal data from the database submission. - Do not rely on the public database record as the full recipient notice, because redress options are not published there. - Use the Commission onboarding, sandbox, API, webform, and batch API paths where applicable to the provider's submission volume. Sources for this answer: - [Regulation (EU) 2022/2065 (Digital Services Act), Article 24(5)](https://eur-lex.europa.eu/eli/reg/2022/2065/oj/eng?ref=sorena.io) - Requires online platforms to submit Article 17 decisions and statements of reasons to the Commission database without undue delay and without personal data. - [European Commission - DSA Transparency Database Q&A](https://digital-strategy.ec.europa.eu/en/faqs/dsa-transparency-database-questions-and-answers?ref=sorena.io) - Explains the database scope, submission methods, personal-data exclusion, redress-option exclusion, and retention behavior for statements of reasons. ## What appeal, complaint, and record links should the workflow preserve? For online platforms, Article 20 requires an effective internal complaint-handling system for at least six months after the recipient is informed about covered moderation decisions. Complaints must be handled in a timely, non-discriminatory, diligent, and non-arbitrary manner, and complaint decisions must be supervised by appropriately qualified staff rather than made solely by automated means. Users can also turn to certified out-of-court dispute settlement bodies for covered platform moderation disputes, without losing the ability to go to court. The Commission's dispute-settlement page states that users may select any certified body whose expertise covers the dispute and whose language coverage fits the case. Keep records that let reviewers connect the original moderation decision, the recipient-facing statement, the Transparency Database submission where required, and any complaint or dispute outcome. The Commission database FAQ also gives retention context for public database access: statements become available from the following day after successful insertion, search retains them for six months, daily dumps retain them for 18 months, and dashboard aggregate statistics cover the last five years. - Store the delivered recipient statement and delivery timestamp. - Store the moderation action, legal or contractual basis, facts and circumstances, automation flag, scope, duration, and redress text. - For online platforms, store the database submission status, submission channel, payload version, personal-data removal check, and any submission errors. - Store internal complaint intake, review owner, reasoned outcome, reversal if any, and notice of out-of-court dispute settlement options. - Store out-of-court dispute settlement body, dispute scope, language, outcome, implementation decision, and related fee handling where relevant. Sources for this answer: - [Regulation (EU) 2022/2065 (Digital Services Act), Articles 20 and 21](https://eur-lex.europa.eu/eli/reg/2022/2065/oj/eng?ref=sorena.io) - Sets the internal complaint-handling and out-of-court dispute settlement routes linked to platform moderation decisions. - [European Commission - Out-of-court dispute settlement bodies under the DSA](https://digital-strategy.ec.europa.eu/en/policies/dsa-out-court-dispute-settlement?ref=sorena.io) - Explains how users can contest platform content moderation decisions through internal complaints, certified out-of-court bodies, or courts. - [European Commission - DSA Transparency Database Q&A](https://digital-strategy.ec.europa.eu/en/faqs/dsa-transparency-database-questions-and-answers?ref=sorena.io) - Provides public database retention details for search results, daily dumps, and dashboard aggregate statistics. ## Primary sources - [Regulation (EU) 2022/2065 (Digital Services Act)](https://eur-lex.europa.eu/eli/reg/2022/2065/oj/eng?ref=sorena.io) - Primary legal source for Article 17 statements of reasons, Article 20 internal complaint handling, Article 21 out-of-court dispute settlement, and Article 24(5) database submission. - Quote: "clear and specific statement of reasons" - [European Commission - DSA Transparency Database Q&A](https://digital-strategy.ec.europa.eu/en/faqs/dsa-transparency-database-questions-and-answers?ref=sorena.io) - Commission guidance on what the DSA Transparency Database collects, online-platform submissions, personal-data exclusion, redress-option exclusion, technical submission routes, and retention behavior. - Quote: "providers of online platforms" - [European Commission - Out-of-court dispute settlement bodies under the DSA](https://digital-strategy.ec.europa.eu/en/policies/dsa-out-court-dispute-settlement?ref=sorena.io) - Commission guidance on certified out-of-court bodies, user selection of a body, platform engagement, and the relationship between platform appeals, ODS, and courts. - Quote: "out-of-court dispute settlement bodies" ## Topic Guides - [DSA Ads and Recommender Systems: transparency duties, user choice, and evidence](/artifacts/eu/digital-services-act/ads-and-recommender-systems.md): A grounded DSA guide to ad labels, targeting restrictions, recommender parameter disclosure, non-profiling options for VLOPs and VLOSEs, ad repositories, and compliance evidence. - [DSA Applicability Test: classify intermediary services, platforms, marketplaces, VLOPs and VLOSEs](/artifacts/eu/digital-services-act/applicability-test.md): A source-grounded EU Digital Services Act applicability test for classifying intermediary services, hosting services, online platforms, marketplaces, VLOPs and VLOSEs. - [DSA Article 28 minors protection guide for online platforms](/artifacts/eu/digital-services-act/minors-protection.md): EU Digital Services Act guide to Article 28 minors protection: platform scope, child-safety measures, targeted ads limits, recommender controls, and grounded evidence. - [DSA average monthly active recipients: what platforms must publish](/artifacts/eu/digital-services-act/faq/average-monthly-active-recipients.md): A grounded FAQ on average monthly active recipients under the EU Digital Services Act, including publication, EU recipient scope, the 45 million VLOP/VLOSE threshold, and evidence records. - [DSA Complaint and Dispute Workflows for Online Platforms](/artifacts/eu/digital-services-act/complaint-and-dispute-workflows.md): Build DSA complaint, appeal, statement-of-reasons, and out-of-court dispute workflows for online platform moderation decisions. - [DSA crisis response for VLOPs and VLOSEs](/artifacts/eu/digital-services-act/crisis-response.md): EU Digital Services Act crisis response guide for VLOPs and VLOSEs: Article 36 Commission decisions, Article 48 crisis protocols, mitigation, governance, requests for information, and records. - [DSA Dark Patterns: interface design checks for online platforms](/artifacts/eu/digital-services-act/dark-patterns.md): Article 25 DSA guidance for reviewing online platform interfaces for deceptive, manipulative, or choice-distorting design patterns. - [DSA Enforcement and Penalties in the EU](/artifacts/eu/digital-services-act/enforcement-penalties-and-investigations.md): How Digital Services Act enforcement works: Commission and Digital Services Coordinator roles, VLOP and VLOSE investigations, fines, periodic penalty payments, and evidence readiness. - [DSA illegal content notices: what must be included?](/artifacts/eu/digital-services-act/faq/illegal-content-notice.md): A grounded FAQ on EU Digital Services Act illegal-content notices: Article 16 notice elements, acknowledgement, decision notices, trusted flagger priority, statements of reasons, and records. - [DSA Marketplace Trader Traceability FAQ](/artifacts/eu/digital-services-act/faq/marketplace-trader-traceability.md): Answer to what EU Digital Services Act Article 30 requires online marketplaces to collect, verify, display, retain, and evidence for trader traceability. - [DSA Marketplace Trader Traceability Guide](/artifacts/eu/digital-services-act/marketplace-trader-traceability.md): EU Digital Services Act guide for online marketplaces collecting, checking, displaying, storing, and evidencing trader traceability information. - [DSA notice and action plus statements of reasons guide](/artifacts/eu/digital-services-act/notice-and-action-plus-statements-of-reasons.md): A grounded Digital Services Act guide for notice intake, moderation decisions, statements of reasons, DSA Transparency Database submission, complaints, appeals, trusted flaggers, and records. - [DSA Notice and Action Workflow for Hosting Services and Online Platforms](/artifacts/eu/digital-services-act/notice-and-action-workflow.md): A grounded DSA notice-and-action workflow covering notice intake, completeness checks, trusted flaggers, decisions, user communications, statements of reasons, appeals, and records. - [DSA recommender transparency FAQ: Article 27 and VLOP options](/artifacts/eu/digital-services-act/faq/recommender-transparency.md): What EU Digital Services Act recommender transparency requires: main parameters, user options, VLOP/VLOSE non-profiling choices, and evidence to keep. - [DSA researcher data access for VLOPs and VLOSEs](/artifacts/eu/digital-services-act/researcher-data-access.md): Article 40 DSA guide to vetted researcher data access for VLOPs and VLOSEs: DSC requests, eligibility checks, amendment grounds, confidentiality, security, and evidence records. - [DSA service tier classifier for platforms, marketplaces, VLOPs and VLOSEs](/artifacts/eu/digital-services-act/service-tier-classifier-workflow.md): Classify a digital service under the EU Digital Services Act as intermediary, hosting, online platform, marketplace, VLOP or VLOSE, with EU recipient-count evidence and obligation outputs. - [DSA statement of reasons log workflow for online platforms](/artifacts/eu/digital-services-act/statement-of-reasons-log-workflow.md): Build a DSA statement of reasons log for moderation decisions, Transparency Database submission, complaint links, retention, and QA controls. - [DSA transparency report template fields and cadence](/artifacts/eu/digital-services-act/dsa-transparency-report-template.md): A source-grounded template outline for Digital Services Act transparency reports, covering applicable service tiers, reporting periods, CSV/XLSX format, retention, statement-of-reasons links, and required evidence tables. - [DSA Transparency Reporting Obligations by Provider Tier](/artifacts/eu/digital-services-act/transparency-reporting.md): A grounded guide to EU Digital Services Act transparency reports, active-recipient publication, statements-of-reasons submissions, VLOP/VLOSE reports, templates, cadence, and evidence. - [DSA VLOP and VLOSE Risk Assessments and Mitigation Guide](/artifacts/eu/digital-services-act/risk-assessments-and-mitigation.md): Grounded guide to Digital Services Act systemic risk assessments, mitigation measures, audits, transparency reports, data access, and governance evidence for VLOPs and VLOSEs. - [DSA VLOP Audit Pack Workflow: Risk, Mitigation, Audit, and Transparency Records](/artifacts/eu/digital-services-act/vlop-audit-pack-workflow.md): Build a DSA VLOP or VLOSE audit pack covering Article 34 risk assessments, Article 35 mitigations, independent-audit evidence, transparency reports, data access, and compliance governance. - [DSA VLOP Risk Assessment FAQ: Article 34, Mitigation, Audits](/artifacts/eu/digital-services-act/faq/vlop-risk-assessment.md): What VLOPs and VLOSEs must assess under the EU Digital Services Act, when to reassess, how Article 35 mitigation and annual audit evidence fit together, and what records to keep. - [DSA vs DMA Platform Rules](/artifacts/eu/digital-services-act/dsa-vs-dma.md): Compare the EU Digital Services Act and Digital Markets Act by scope, designation thresholds, obligations, enforcement, evidence, and practical team ownership. - [DSA vs GDPR: online-platform governance and personal-data obligations](/artifacts/eu/digital-services-act/dsa-vs-gdpr.md): Compare the EU Digital Services Act and EU GDPR by scope, ads, recommenders, minors, transparency, complaints, enforcement, and evidence. - [DSA vs P2B Regulation: EU platform obligations compared](/artifacts/eu/digital-services-act/dsa-vs-p2b.md): Compare the EU Digital Services Act with the Platform-to-Business Regulation for platform scope, business-user terms, content moderation, ranking transparency, complaints, enforcement, and evidence. - [DSA vs Terrorist Content Online Regulation: notice-and-action vs removal orders](/artifacts/eu/digital-services-act/dsa-vs-terrorist-content-online-regulation.md): Compare DSA content-governance duties with the EU Terrorist Content Online Regulation removal-order workflow for scope, timing, evidence, authorities, and team ownership. - [EU Digital Services Act checklist for platforms and hosting services](/artifacts/eu/digital-services-act/checklist.md): A grounded DSA checklist for classifying service tiers, notice-and-action, statements of reasons, complaints, transparency reports, ads, recommenders, trader traceability, VLOP/VLOSE duties, and evidence records. - [EU Digital Services Act Compliance Guide](/artifacts/eu/digital-services-act/compliance.md): DSA compliance guide for intermediary services, hosting providers, online platforms, marketplaces, and VLOP/VLOSE teams: obligations, controls, and evidence to keep. - [EU Digital Services Act FAQ: DSA scope, platform duties, VLOPs, reports, and penalties](/artifacts/eu/digital-services-act/faq.md): Concise EU Digital Services Act FAQ covering intermediary-service scope, active-recipient thresholds, illegal-content notices, statements of reasons, trader traceability, recommender transparency, systemic-risk duties, reporting, penalties, and complaints. - [EU Digital Services Act penalties and fines: caps and enforcement roles](/artifacts/eu/digital-services-act/penalties-and-fines.md): DSA penalty caps and enforcement roles: Member State fines, Commission fines for VLOPs and VLOSEs, 1% procedural fines, and 5% periodic penalty payments. - [EU Digital Services Act requirements by service tier](/artifacts/eu/digital-services-act/requirements.md): Overview of DSA obligations for intermediary services, hosting providers, online platforms, marketplaces, VLOPs and VLOSEs, including notices, complaints, ads, transparency reports, audits, data access and enforcement. - [EU Digital Services Act service types and scope](/artifacts/eu/digital-services-act/service-types-and-scope.md): Classify DSA service scope across mere conduit, caching, hosting, online platforms, marketplaces, online search engines, and VLOP/VLOSE threshold duties. - [EU DSA deadlines and compliance calendar: application dates, reporting cycles, and VLOP clocks](/artifacts/eu/digital-services-act/deadlines-and-compliance-calendar.md): Calendar view of grounded EU Digital Services Act dates: full application, user-number publication, VLOP/VLOSE designation clocks, statements of reasons, and transparency reporting cycles. - [EU DSA Transparency Calendar: reporting, SoR database, AMAR updates](/artifacts/eu/digital-services-act/transparency-calendar.md): Build a DSA transparency calendar for annual reports, statement-of-reasons database submissions, active-recipient updates, and VLOP/VLOSE audit touchpoints. - [EU DSA vs UK Online Safety Act: scope, duties, regulator, and evidence](/artifacts/eu/digital-services-act/dsa-vs-uk-online-safety-act.md): Compare the EU Digital Services Act and UK Online Safety Act for platform scope, risk assessments, child protection, transparency, regulators, enforcement, and owners. *Recommended next step* *Placement: before sources* ## Build one record for user notice, database submission, and appeal handling Sorena can help map Article 17 statement fields, Article 24(5) Transparency Database submission checks, and appeal records into a repeatable content-moderation workflow. - [Open Research Copilot for DSA questions](/solutions/research-copilot.md): Ask source-linked questions about statements of reasons, database submissions, appeal routes, and moderation records using the cited DSA sources. - [Review your DSA statement workflow](/contact.md): Check whether your moderation notice, Transparency Database payload, and complaint records line up with the cited DSA requirements. --- [Privacy Policy](https://www.sorena.io/privacy) | [Terms of Use](https://www.sorena.io/terms-of-use) | [DMCA](https://www.sorena.io/dmca) | [About Us](https://www.sorena.io/about-us) (c) 2026 Sorena AB (559573-7338). All rights reserved. Source: https://www.sorena.io/artifacts/eu/digital-services-act/faq/statement-of-reasons