CDT Europe Responds to European Commission Public Consultation on Templates for Transparency Reports Under EU Digital Services Act 

On December 8, the European Commission opened a public consultation for a draft Implementing Regulation under the EU Digital Services Act (DSA), for the transparency reports on the content moderation engaged in by all providers of intermediary services and online platforms operating in Europe. The draft regulation sets out the mandatory templates that must be used for these transparency reports with the aim of creating common transparency reporting standards and which must be published on a cyclical basis.

CDT Europe’s submission focuses on providing recommendations to strengthen the usefulness of the transparency reports through the collection of more precise and tangible data points that will create a precedent for more meaningful transparency from service providers. These include:

• Clarifying certain elements of the structure, categorisation and data points requested in the reporting templates to prevent the reports from failing to capture vital information in the public interest (e.g. more insight into which member state authorities are issuing orders against illegal content or request information on users). 
• Establishing a stronger alignment between the quantitative and qualitative data requested in the reporting templates, as both elements are essential to developing a more in depth understanding of how user-generated content is being moderated.
• Ensuring definitional coherency by providing additional guidance on some of the terms used and providing scope for service providers to supplement the data provided with information on how they internally understand and apply certain terms such as ‘content moderation’. 

Read the full submission.