Key Takeaways
- Article 15 requires all in-scope providers to publish annual transparency reports on content moderation activities
- Article 24 mandates online platforms submit decisions and statements of reasons to the EU Commission's publicly accessible database
- Regulation 2024/2835 establishes mandatory templates and reporting formats effective from 1 July 2025
- Initial reporting cycle uses a flexible 2-month deadline with providers choosing their own reporting period end date between 31 December 2024 and 16 February 2025
- Core metrics include content removal orders, notice-and-action outcomes, complaint handling, and automated tool usage
- VLOPs/VLOSEs face stricter obligations than smaller platforms, reflecting their systemic impact
Introduction
Article 15 of the Digital Services Act (DSA) requires in-scope service providers to publish a transparency report detailing how they carry out content moderation, including how they implement and action Member State orders, carry out own-initiative moderation and process user reports. Complementing this, Article 17 requires all providers of hosting services to provide clear and specific information called statements of reasons to users whenever they remove or otherwise restrict access to their content, and Article 24(5) requires providers of online platforms to send all their statements of reasons to the Commission's DSA Transparency Database.
These transparency obligations represent the DSA's commitment to creating accountability in content moderation. However, implementing them effectively requires understanding multiple regulatory layers. This guide walks through the core requirements, implementing regulation templates, reporting deadlines, and practical compliance strategies for all platform sizes.
Understanding the Regulatory Framework
Core Requirements: Articles 15 and 24
Providers of intermediary services shall make publicly available, in a machine-readable format and in an easily accessible manner, at least once a year, clear, easily comprehensible reports on any content moderation that they engaged in during the relevant period. This baseline obligation under Article 15 applies universally across intermediary services.
All in-scope providers must comply with the requirements of Article 15, however the content of transparency reports will depend on how a service is categorised under the DSA. The DSA creates a tiered structure where obligations scale with platform size and systemic influence.
Online platforms are required to include the information listed in Article 24 into their Transparency Report, while VLOPs/VLOSEs have the strictest reporting obligation, and their Transparency Report needs to contain the information according to Article 42 of the DSA in addition to all of the above.
The Role of Implementing Regulation 2024/2835
On November 4, 2024, the European Commission adopted the implementing regulation on transparency reporting under the Digital Services Act, which is intended to harmonise the format and reporting time periods of the transparency reports required by the DSA. This regulation standardizes how platforms must structure and submit their reports.
The information in the transparency report shall be provided by completing the following templates set out in Annex I: the 'Quantitative Template', which is to be used to provide quantitative machine-readable information on content moderation, in accordance with the requirements under Articles 15, 24 and 42.
Those requirements will only apply from 1 July 2025 and so they do not apply to reports published under this first reporting cycle. As a result, service providers have some discretion in determining the format and structure of their first report.
Transparency Report Requirements: Core Metrics
Content Moderation Data Points
Key reporting elements include report identification (identity of the service and reporting period), member state orders (removal and information orders from EU states), notice and action mechanisms (reports of illegal content from users and trusted flaggers), complaint mechanism (appeal mechanism), and use of automated tools in content moderation.
Reporting obligations include orders from authorities (number of content removal orders, categorized by type of content and country) and notice and action outcomes (the number of notices processed, including actions taken and whether automated tools were involved).
Team Qualifications and Resources
Assessment of transparency reporting practices considers various forms including human resources involved in content moderation. Platforms must disclose information about the expertise and qualifications of teams responsible for content moderation decisions, demonstrating that personnel possess adequate knowledge of applicable laws and platform policies.
Additionally, providers are required to report on the median time taken to respond to a user report and the use of automated tools on their services. These metrics provide insight into both human and technological capacity.
Statements of Reasons: Article 24 Requirements
What Are Statements of Reasons?
Pursuant to Article 17 of the DSA, the statement of reasons must include certain mandatory information, including: what the decision entails and its territorial scope; the facts and circumstances relied on in taking the decision; information on any automated means used in making the decision; if the decision relates to allegedly illegal content, an explanation as to why the content is considered to be illegal; if the decision is based on infringement of the service Terms and Conditions, a reference to the contractual ground relied on and an explanation as to why the content infringes that ground; and the possibilities for redress regarding the decision.
These statements form the foundation of transparency because they explain to users exactly why their content was removed or restricted, grounding the decision in either applicable law or platform terms.
Database Submission Obligations
Providers of online platforms shall, without undue delay, submit to the Commission the decisions and the statements of reasons referred to in Article 17(1) for the inclusion in a publicly accessible machine-readable database managed by the Commission. The database is publicly accessible and machine-readable.
Once you are onboarded via your Digital Service Coordinator, you will gain access to a sandbox environment to test your submissions to the DSA Transparency Database, which you can perform either via an Application Programming Interface (API) or a webform, according to the volume of your data and technical needs. Once the testing phase is completed, you will be able to move to the production environment of the DSA Transparency Database.
Implementing Regulation 2024/2835: Templates and Deadlines
Template Structure
Providers of intermediary services, providers of hosting services, providers of online platforms, providers of very large online platforms and providers of very large online search engines shall publish one transparency report in accordance with the templates in Annex I per service that it offers.
The quantitative template is machine-readable and captures standardized data fields that allow for cross-platform comparison. This structured approach enables regulators, researchers, and the public to analyze content moderation patterns systematically rather than parsing free-form narratives.
Reporting Deadlines and Timeline
A report must be published within two months of the end of a reporting period, but service providers are free to choose an end date between 31 December 2024 and 16 February 2025. This means that reports can be published from 28 February 2025 up to 17 April 2025, depending on what end date the provider chooses.
In principle, the reporting period for the annual reporting is the calendar year from 1 January to 31 December; however, as the DSA came in to force in February, there are two initial reporting cycles before the reporting period gets into the intended rhythm. Transparency Reports shall be published latest two months after the end of the reporting period.
This flexible initial deadline acknowledges the logistical challenges platforms face in establishing data collection systems. Once the regime matures, providers will follow calendar-year cycles with consistent publication deadlines.
Tiered Obligations: Scaling Compliance by Platform Size
All Intermediary Services (Article 15 Baseline)
Every platform offering intermediary services in the EU must meet Article 15's baseline requirements. These include publishing annual reports and documenting how they process Member State orders, handle own-initiative moderation, and address user reports.
Online Platforms (Article 24 Enhanced Requirements)
Online platforms are required to include the information listed in Article 24 into their Transparency Report. This includes additional metrics specific to notice-and-action mechanisms, complaint handling systems, and the specific types of illegal content targeted.
VLOPs and VLOSEs (Article 42 Strictest Requirements)
Very Large Online Platforms (VLOPs) and Search Engines (VLOSEs): Platforms with more than 45 million EU users face stricter regulations and higher reporting standards. In addition to Articles 15 and 24 obligations, VLOPs/VLOSEs must meet Article 42 requirements, which include detailed systemic risk assessments and more granular data breakdowns.
Implementation Challenges and Data Mapping
Resource Intensity for Smaller Platforms
Many providers are engaging in data mapping exercises to ensure they can meet the DSA's requirements. This involves reviewing internal systems, identifying relevant data sources, and implementing new processes to track and record required metrics. For smaller platforms, these efforts can be resource-intensive, as they may lack the sophisticated compliance tools and infrastructure.
Smaller platforms without existing data warehousing systems may need to implement new technical infrastructure or business processes to track required metrics consistently.
Ensuring Data Accuracy and Consistency
Neither LinkedIn nor Snapchat explicitly distinguish between actions taken following a user report based on the law and those based on internal policies. This seems to be in tension with Article 15 of the DSA, which clearly states that providers must specify whether an action was based on the law or their own terms and conditions.
Platforms must establish clear data categorization systems that distinguish between legal compliance decisions and policy-based actions. This distinction is fundamental to demonstrating that moderation decisions follow appropriate legal or contractual grounds.
Best Practices for Compliance
Data Infrastructure Setup
Begin by auditing existing data sources and identifying gaps. Map which systems track content removals, user reports, automated actions, and appeals. Many platforms discover they must integrate previously siloed systems—content moderation platforms, legal tracking tools, and analytics dashboards—into unified reporting systems.
Transparency Database Onboarding
For online platforms, early engagement with your national Digital Service Coordinator accelerates onboarding to the EU Commission's Transparency Database. Begin sandbox testing well before your reporting deadline to identify and resolve API integration issues or data formatting problems.
Documenting Methodology
Publish clear explanations of how you calculated key metrics. Define what qualifies as a "user report," how median response times are computed, and which actions count as removals versus restrictions. This contextual information builds trust and helps regulators and researchers interpret your data accurately.
Alignment with Related Obligations
Transparency reporting connects with other DSA requirements. Consider how recommender system transparency under Article 27 and researcher data access under Article 40 might use similar data infrastructure. Building systems that serve multiple compliance needs is more efficient than creating isolated reporting solutions.
Internal Controls and Quality Assurance
Verification Processes
Establish quality assurance workflows to verify that reported metrics accurately reflect actual moderation activity. Sample data points, reconcile totals against source systems, and document any corrections or adjustments before publication.
Documentation and Record-Keeping
Maintain comprehensive records of how metrics were calculated, which data sources were used, and any methodology changes between reporting periods. This documentation supports regulatory inquiries and demonstrates good-faith compliance efforts.
Training and Accountability
Ensure teams responsible for data collection understand DSA definitions and requirements. Ambiguity about whether a particular action qualifies as a removal or restriction can propagate through reporting. Clear internal guidance prevents inconsistent data categorization.
FAQ: Common Questions on DSA Transparency Reporting
Q: Do I need to publish my first transparency report in the new format under Regulation 2024/2835?
No. Those requirements will only apply from 1 July 2025 and so they do not apply to reports published under this first reporting cycle. As a result, service providers have some discretion in determining the format and structure of their first report. However, you may voluntarily use the templates as guidance even before they become mandatory.
Q: When exactly must I publish my first transparency report?
A report must be published within two months of the end of a reporting period, but service providers are free to choose an end date between 31 December 2024 and 16 February 2025. This means that reports can be published from 28 February 2025 up to 17 April 2025, depending on what end date the provider chooses. Choose your reporting period end date strategically to allow adequate time for data collection and verification.
Q: What if I'm a small platform with limited resources? Do I still need to comply?
Companies with fewer than 50 employees and under €10 million in annual revenue are partially exempt. However, most platforms offering significant services must at minimum meet Article 15's baseline requirements. Evaluate your specific categorization under the DSA to determine your exact obligations.
Q: How do statements of reasons differ from transparency reports?
Transparency reports are aggregate, periodic disclosures about overall content moderation patterns. Statements of reasons are individual explanations provided to each user whose content is removed or restricted. Article 24 requires platforms to submit individual statements to the Commission's database for public analysis.
Q: Can I submit statements of reasons via an API or webform?
Once you are onboarded via your Digital Service Coordinator, you will gain access to a sandbox environment to test your submissions to the DSA Transparency Database, which you can perform either via an Application Programming Interface (API) or a webform, according to the volume of your data and technical needs. Choose based on your technical capacity and submission volume.
Q: What happens if my transparency report contains inaccuracies?
Inaccuracies discovered before publication should be corrected before filing. If errors are identified post-publication, consider publishing a corrected version and notifying the Commission. Consistent inaccuracies discovered during enforcement investigations can trigger significant penalties. DSA enforcement case studies show that regulators scrutinize data integrity closely.
Looking Ahead: From Initial Compliance to Mature Reporting
The DSA's transparency regime is evolving. The first reporting cycle tests platform systems and data quality. From July 2025 onward, mandatory templates will standardize reporting across the industry, enabling regulators and researchers to compare practices systematically.
Larger platforms should prepare for intensified scrutiny. Independent audits under DSA requirements increasingly focus on validation of reported metrics. VLOPs and VLOSEs face heightened expectations around both accuracy and the depth of explanations accompanying their data.
Consider transparency reporting not as a compliance checkbox but as foundational infrastructure for accountability. Well-designed systems that accurately track and report content moderation activities will serve you across multiple DSA obligations and strengthen your platform's reputation for responsible content governance.
Conclusion
Platforms are required to publish annual reports that provide detailed insights into their content moderation practices, enabling regulators, users, and other stakeholders to evaluate their efforts. These reports must not only highlight how platforms manage harmful content but also offer a deeper look into the mechanisms and resources used to ensure compliance. By mandating detailed disclosures, the DSA aims to foster accountability and build trust, ensuring that moderation efforts are both effective and fair.
Articles 15 and 24 represent the DSA's commitment to transparency in digital content governance. Implementing these requirements demands careful attention to data collection, metric definitions, and reporting timelines. Whether you're a smaller platform meeting baseline Article 15 standards or a VLOP subject to the full spectrum of DSA obligations, early preparation, robust data infrastructure, and clear documentation position you for successful compliance.
For comprehensive guidance on the broader DSA framework, see our overview of the Digital Services Act definition and core objectives. Visit the latest articles for ongoing updates as the regulatory landscape develops.