--- title: "EU DSA Transparency Calendar: reporting, SoR database, AMAR updates" canonical_url: "https://www.sorena.io/artifacts/eu/digital-services-act/transparency-calendar" source_url: "https://www.sorena.io/artifacts/eu/digital-services-act/transparency-calendar" author: "Sorena AI" description: "Build a DSA transparency calendar for annual reports, statement-of-reasons database submissions, active-recipient updates, and VLOP/VLOSE audit touchpoints." published_at: "2026-05-09" updated_at: "2026-05-09" keywords: - "EU Digital Services Act" - "DSA transparency calendar" - "DSA transparency report" - "statement of reasons database" - "active recipients" - "VLOP audit" - "VLOSE reporting" - "DSA" - "transparency report" - "statement of reasons" - "VLOP" - "VLOSE" --- **[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) --- # EU DSA Transparency Calendar: reporting, SoR database, AMAR updates Build a DSA transparency calendar for annual reports, statement-of-reasons database submissions, active-recipient updates, and VLOP/VLOSE audit touchpoints. *Transparency Calendar* *EU DSA* ## EU DSA Transparency Calendar Track the recurring DSA transparency duties that turn moderation, user-count, database, and audit records into public reporting evidence. Use this page to build a control calendar for Article 15 reports, Article 24 active-recipient publications, Article 24(5) statement-of-reasons database submissions, and VLOP/VLOSE reporting and audit touchpoints. A DSA transparency calendar should not be a generic compliance reminder. It should identify which services are intermediary services, hosting services, online platforms, or designated VLOPs/VLOSEs, then attach each recurring publication or submission duty to an evidence owner, source system, review date, and public URL. ## Calendar lanes to maintain Start the calendar with four lanes: annual transparency reports, statement-of-reasons database operations, average monthly active recipient publications, and VLOP/VLOSE audit and enhanced-reporting work. Keep each lane service-specific because the DSA applies different duties to intermediary services, hosting services, online platforms, and designated very large services. For every calendar entry, store the legal trigger, covered reporting period, publication or submission channel, evidence source, approving owner, and the public link or database confirmation. Do not create a date unless it is tied to the DSA text, an implementing regulation, a designation event, or a published Commission source. - Annual transparency report lane: Article 15 report preparation, machine-readable publication, version control, and at least five-year public retention under the implementing reporting templates. - Statement-of-reasons lane: Article 17 user notice content, Article 24(5) online-platform submission to the Commission database, personal-data removal checks, and daily submission monitoring. - Active-recipient lane: Article 24(2) publication of average monthly active recipients in the Union, calculated over the past six months and updated at least once every six months. - VLOP/VLOSE lane: designation tracking, six-month transparency reporting cadence, Article 42 Member State active-recipient breakdowns, independent audit cycle, and audit-publication controls. Sources for this answer: - [Regulation (EU) 2022/2065 (Digital Services Act)](https://eur-lex.europa.eu/eli/reg/2022/2065/oj?ref=sorena.io) - Primary DSA source for Article 15 transparency reports, Article 24 active-recipient and statement-of-reasons database duties, and Article 42 VLOP/VLOSE reporting. - [Implementing Regulation (EU) 2024/2835 on DSA transparency reporting templates](https://eur-lex.europa.eu/eli/reg_impl/2024/2835/oj/eng?ref=sorena.io) - Sets harmonised transparency report templates, reporting periods, publication format expectations, update rules, and report retention. ## Annual transparency report controls For providers covered by Article 15, the calendar should collect content-moderation reporting data throughout the year rather than assemble it at publication time. The implementing regulation aligns ordinary annual reporting with a 1 January to 31 December reporting period from the first full harmonised annual cycle, while also describing transition periods before that cycle. The report workstream should cover orders from Member State authorities, notice-and-action volumes, own-initiative content moderation, internal complaints, automated moderation information, and the specific online-platform additions where Article 24(1) applies. The control owner should confirm that the published report uses the required template, is machine-readable, remains easy to access, and preserves prior published versions when updates correct errors or methodology changes. - Create a monthly data-close task for moderation decisions, notices, authority orders, complaint outcomes, median time measures, automated processing flags, and categorisation by illegal-content or terms-and-conditions ground. - Add a pre-publication review for template completeness, machine-readable format, public accessibility, source-system reconciliation, and sign-off by legal, trust and safety, data, and publishing owners. - If a published report is updated, label it as an updated version and keep the prior publication history rather than silently replacing the record. - Keep transparency reports publicly available for at least five years after publication, matching the implementing regulation's retention control. Sources for this answer: - [Implementing Regulation (EU) 2024/2835 on DSA transparency reporting templates](https://eur-lex.europa.eu/eli/reg_impl/2024/2835/oj/eng?ref=sorena.io) - Grounds the annual reporting cycle, template use, report-update handling, machine-readable publication, and five-year report retention controls. - [Regulation (EU) 2022/2065 (Digital Services Act)](https://eur-lex.europa.eu/eli/reg/2022/2065/oj?ref=sorena.io) - Article 15 and Article 24 define the report content categories that calendar evidence should collect. ## Statement-of-reasons database controls The DSA transparency database lane is operational, not annual. Hosting services must provide clear and specific statements of reasons to users when they remove or otherwise restrict content; online platforms must send those statements to the Commission's public, machine-readable DSA Transparency Database under Article 24(5). The calendar should therefore track onboarding, sandbox testing, production submission readiness, daily error review, and redaction checks. The Commission FAQ states that statements become available from the following day after successful insertion, search data is retained for six months, daily dumps are retained for 18 months, and aggregated dashboard statistics remain available for five years. - Before go-live: register the platform process, complete Digital Services Coordinator onboarding, test API or webform submission in the sandbox, and approve personal-data removal from database submissions. - Daily or per-batch: reconcile moderation actions that require a statement of reasons against successful database submissions and investigate rejected, delayed, duplicate, or malformed records. - Monthly: sample the public database and daily dumps by platform and timeframe to confirm submissions are visible and match internal moderation logs without exposing personal data. - Evidence to retain: user-facing statement template, Article 17 field mapping, database submission logs, redaction checks, API or webform error records, and remediation notes for database consistency changes. Sources for this answer: - [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 Article 17 statements of reasons, Article 24(5) database submission, onboarding flow, daily dump access, and database retention periods. - [Regulation (EU) 2022/2065 (Digital Services Act)](https://eur-lex.europa.eu/eli/reg/2022/2065/oj?ref=sorena.io) - Binding source for the legal duty to provide statements of reasons and submit online-platform statements to the Commission database. ## Active-recipient publication and VLOP/VLOSE triggers The active-recipient lane should run even for services that are not designated very large services. Article 24(2) requires providers of online platforms and online search engines to publish information on the average monthly active recipients of the service in the Union, calculated as an average over the past six months, and to update it at least once every six months. The Commission explains that platforms and search engines with more than 45 million monthly users in the EU may be classified as VLOPs or VLOSEs. Once designated, the service has four months to comply with the DSA obligations for designated services, and the Commission may revoke designation if the service no longer reaches the threshold during one full year. - Every six months: refresh the public active-recipient figure, archive the calculation workbook, source-system extraction, bot or duplicate-account treatment, and publication screenshot or URL. - After each active-recipient update: test whether the 45 million monthly EU user threshold may be met and whether legal should prepare for possible Commission designation questions. - If designated: add a four-month implementation workstream covering VLOP/VLOSE-specific obligations, including systemic-risk governance, data access, non-profiling recommender options, ad repository duties, and enhanced reporting. - For VLOP/VLOSE transparency reports: include average monthly active recipients for each Member State when Article 42 applies, not only a Union-level number. Sources for this answer: - [European Commission - VLOPs and VLOSEs under the DSA](https://digital-strategy.ec.europa.eu/en/policies/dsa-vlops?ref=sorena.io) - Commission source for the 45 million monthly EU user threshold, six-month user-number updates, four-month post-designation compliance period, and designation revocation logic. - [European Commission - DSA guidance on publishing user numbers](https://digital-strategy.ec.europa.eu/en/library/dsa-guidance-requirement-publish-user-numbers?ref=sorena.io) - Commission guidance source for Article 24(2) average monthly active recipient publication and counting context. - [Regulation (EU) 2022/2065 (Digital Services Act)](https://eur-lex.europa.eu/eli/reg/2022/2065/oj?ref=sorena.io) - Article 24(2), Article 33, and Article 42 ground the publication, designation, and VLOP/VLOSE reporting controls. ## VLOP/VLOSE audit and evidence calendar Designated VLOPs and VLOSEs need a separate audit calendar because Article 37 independent audits and Article 42 publication duties create evidence deadlines that are not the same as ordinary annual report preparation. The audit cycle should complement the prior audit period, allow the auditor to conclude at least once per year, and support prompt transmission of audit reports to the Commission and Digital Services Coordinator. Article 42 requires VLOPs and VLOSEs to make audit-related reports publicly available at the latest three months after receiving each audit report, while allowing limited removals from the public version for specified confidentiality, security, public-security, or recipient-harm reasons. That means the calendar needs both a confidential-regulator package and a public-redaction package. - Before auditor selection: collect independence, conflict-of-interest, expertise, subcontractor, and non-audit-service checks for the auditing organisation. - During the audit: preserve evidence for each audited obligation, including risk assessments, mitigation measures, transparency reporting controls, content moderation systems, recommender controls, ad repository controls, and data-access processes. - After report receipt: trigger regulator transmission without undue delay, prepare public versions, record any redactions and reasons, and publish within the Article 42 audit-publication window. - Evidence calendar fields: audited service, audit period, auditor, obligations covered, evidence repository, management response, implementation report owner, regulator submission date, public publication date, and redaction rationale. Sources for this answer: - [Delegated Regulation (EU) 2024/436 on DSA independent audits](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32024R0436&ref=sorena.io) - Grounds annual audit sequencing, auditor independence checks, audit evidence expectations, audit report templates, and submission timing for VLOP/VLOSE audits. - [Regulation (EU) 2022/2065 (Digital Services Act)](https://eur-lex.europa.eu/eli/reg/2022/2065/oj?ref=sorena.io) - Article 37 and Article 42 set the independent audit and audit-publication duties for very large online platforms and search engines. - [European Commission - VLOPs and VLOSEs under the DSA](https://digital-strategy.ec.europa.eu/en/policies/dsa-vlops?ref=sorena.io) - Commission overview summarising annual independent audits and other enhanced duties for designated VLOPs and VLOSEs. *Recommended next step* *Placement: before sources* ## Map each DSA transparency lane to owners, evidence, and publication controls Sorena can help translate the DSA reporting, statement-of-reasons, active-recipient, and VLOP/VLOSE audit touchpoints on this page into a maintained evidence calendar. - [Open Research Copilot for the DSA](/solutions/research-copilot.md): Ask source-linked questions about DSA transparency reporting, statement-of-reasons submissions, active-recipient updates, and VLOP/VLOSE audit evidence. - [Talk through implementation](/contact.md): Review your DSA transparency calendar, owner model, data sources, and publication controls with Sorena. ## Primary sources - [Regulation (EU) 2022/2065 (Digital Services Act)](https://eur-lex.europa.eu/eli/reg/2022/2065/oj?ref=sorena.io) - Primary DSA text for transparency reports, statement-of-reasons duties, active-recipient publication, VLOP/VLOSE reporting, independent audits, and audit publication. - Quote: "Digital Services Act" - [Implementing Regulation (EU) 2024/2835 on DSA transparency reporting templates](https://eur-lex.europa.eu/eli/reg_impl/2024/2835/oj/eng?ref=sorena.io) - Harmonised templates, reporting periods, machine-readable publication, update handling, and five-year report retention for DSA transparency reports. - Quote: "transparency reporting templates" - [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 FAQ for statements of reasons, Article 24(5) database submission, public database features, onboarding, daily dumps, and retention periods. - Quote: "statements of reasons" - [European Commission - DSA guidance on publishing user numbers](https://digital-strategy.ec.europa.eu/en/library/dsa-guidance-requirement-publish-user-numbers?ref=sorena.io) - Commission guidance on publishing average monthly active recipients under Article 24(2), including counting context for VLOP/VLOSE designation. - Quote: "number of average monthly active recipients" - [European Commission - VLOPs and VLOSEs under the DSA](https://digital-strategy.ec.europa.eu/en/policies/dsa-vlops?ref=sorena.io) - Commission overview for the 45 million monthly EU user threshold, post-designation compliance period, enhanced obligations, annual audits, and designation revocation. - Quote: "over 45 million users" - [Delegated Regulation (EU) 2024/436 on DSA independent audits](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32024R0436&ref=sorena.io) - Audit-performance rules for designated VLOPs and VLOSEs, including annual audit sequencing, auditor checks, evidence expectations, and audit report templates. - Quote: "independent audits" ## Related 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 FAQ](/artifacts/eu/digital-services-act/faq/statement-of-reasons.md): 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. - [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 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. --- [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). 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