Which tier are you in
The DSA stacks obligations by type of service. Intermediary services carry the basic duties. Hosting services, which store content for users, add notice and action and statements of reasons. Online platforms, which also publish that content to the public, add internal complaints and more. Very large online platforms carry the heaviest duties. Most apps with user content are online platforms.
Basic duties for every intermediary service
- A single point of contact for authorities and one for users
- A legal representative in the EU if you are established outside it
- Terms and conditions that describe your moderation rules and tools, including any automated decisions
- Transparency reporting on your moderation activity, with exemptions for micro and small enterprises
Notice and action
Hosting services must let anyone notify them of content they consider illegal, through an easy electronic mechanism. Notices must be processed in a timely, diligent and objective manner, and the notifier must be told the outcome. Where automated means are used, that must be disclosed.
Statements of reasons
When you remove content, restrict its visibility, suspend an account or demonetise a user because content is illegal or breaks your terms, you must give the affected user a clear statement of reasons: what was decided, on what basis, whether automation was involved, and how to seek redress. Online platforms also submit these statements to the EU transparency database.
Internal complaints and appeals
Online platforms must offer an internal complaint system, free of charge, for at least six months after a decision. Complaints must be handled under the supervision of qualified staff, not solely by automated means, and decisions reversed when the complaint shows they were wrong. Users must also be informed about out of court dispute settlement.
Other platform duties to know
- Priority for notices from trusted flaggers
- Measures against users who frequently post manifestly illegal content
- Notifying authorities of suspected criminal offences that threaten life or safety
- Protection of minors where the platform is accessible to them
The small enterprise exemption
Micro and small enterprises are exempt from several online platform obligations, unless they are designated as very large. The basic duties, notice and action and statements of reasons still apply. Check the exact scope with your counsel.
What this means for your moderation operation
Every obligation above produces data or a workflow that your moderation team touches every day: intake of notices, a reason for every decision, a second reviewer for appeals, and records you can report from. If those exist only in an inbox, compliance becomes guesswork. Our trust and safety services build them into the standard process, and the moderation software keeps the audit log.