By Daniel Holznagel At the end of 2024, the first audit reports under the Digital Services Act were published. Most were produced by Big Four accounting firms. Most were not very ambitious. This post collects impressions from digesting most (not all) of these reports — focusing on five structural shortcomings that severely limit their usefulness: from illegitimate audit gaps to auditors' apparent reluctance to interpret the law or meaningfully assess systemic risks (especially around recomm...| DSA Observatory
By Paddy Leerssen, Anna van Duin, Iris Toepoel, and Joris van Hoboken Discussion of DSA enforcement tend to focus on regulatory action by the European Commission and national Digital Services Coordinators, but private actors are also taking the DSA to court. This report looks at the underexplored but important role of private enforcement—where individuals, NGOs, or consumer groups bring legal action themselves. It examines key DSA provisions with potential for such claims and outlines the l...| DSA Observatory
By Taylor Annabell, Utrecht University Under the DSA, social media platforms must provide clear tools for influencers to disclose paid content. But how well do they meet this obligation, and how rigorously is compliance assessed? This post compares eight DSA audit reports on influencer marketing disclosures under Article 26(2) and finds striking inconsistencies in how audits were conducted, what was measured, and how “compliance” was defined. The findings raise broader concerns about audi...| DSA Observatory - a hub of expertise on the DSA package.