First Transparency Reports Under Digital Services Act Are Difficult to Compare

Europe’s Digital Services Act (DSA) requires that the largest tech firms submit regular transparency reports to stay compliant with the law. The deadline for Very Large Online Platforms (VLOPs) and Search Engines (VLOSEs) to publish their first reports was Nov. 6, with all fifteen service providers that meet the “very large” threshold making the cutoff. And though the community of DSA watchers made some initial observations, the transparency reports received little press or public attention.

In the days following the release of the reports, Tech Policy Press updated its DSA tracker to include links to the reports, ad repositories, notice and action mechanism portals, and points of contacts for DSA-related inquiries. (The firm Tremau is similarly tracking DSA developments.) Even a cursory glance at the various documents provided by the companies, however, raises several questions, particularly around the lack of transparency reporting standardization, varying degrees of disclosure, and seemingly different interpretations of DSA Articles that VLOPs and VLOSEs are obligated to comply with. An initial comparative analysis suggests that a more thorough investigation of the reports will yield worthwhile insights, and that the European Commission has the opportunity to issue more specific instructions to make these reports more useful to researchers, journalists, and the public.