DSA notice and action workflow

Article 16 applies to providers of hosting services, including online platforms. The intake channel should allow any individual or entity to submit notices electronically about specific items of information that they consider illegal content.

Do not treat a general abuse complaint, broad account grievance, or policy suggestion as a complete DSA notice unless it identifies the relevant content and gives enough information to assess the alleged illegality. Keep the original notice payload, timestamps, language, channel, and any automated routing flags.

Online platforms covered by Article 22 need a separate trusted flagger lane. Check Article 19 first: its micro or small enterprise exclusion can remove these platform-section duties, including during the 12-month post-loss period, except for designated VLOPs. Trusted flaggers are designated by national Digital Services Coordinators and their notices, when submitted within the designated area of expertise through the Article 16 mechanism, must receive priority and be processed and decided on without undue delay.

Priority does not mean automatic removal. The Commission's trusted flagger page states that providers remain responsible for deciding on notices and removing content where justified. The workflow should therefore identify the trusted flagger, verify scope, speed the review, and still capture the platform's own legal or terms-based decision.

For every notice, the reviewer should decide in a timely, diligent, non-arbitrary, and objective manner. The record should show whether the decision relied on law, terms and conditions, both, or no action, and whether automated means were used in processing or decision-making.

The notifier communication and affected-user communication are different handoffs. Article 16 requires the hosting provider to notify the person or entity that submitted the notice of the decision and available redress. Article 17 separately requires a clear and specific statement of reasons to affected recipients when covered restrictions are imposed and the relevant electronic contact details are known.

The notice workflow should not close merely because a moderation action was taken. Online platforms need downstream complaint handling for decisions on notices and covered moderation restrictions, and statement-of-reasons data may need submission to the Commission's DSA Transparency Database.

A durable record ties the original notice to the decision, communications, complaint status, out-of-court dispute status, and reporting metrics. That is the record a platform needs when a user appeals, a certified dispute settlement body asks for context, a transparency report is prepared, or a regulator examines trusted flagger handling.