CDT Europe has expressed its support for the European Commission's initiative to provide independent researchers with access to platform data. This initiative is initially outlined in Article 40 of the Digital Services Act (DSA) and further specified in the Draft Delegated Act. CDT Europe noted that several very large online platforms (VLOPs) have made accessing their data more challenging over the past year, yet transparency remains essential for understanding how online services contribute to systemic risks and finding ways to mitigate them.

The draft delegated act addresses many important details, incorporating feedback from stakeholders, including CDT Europe. The organization aims to enhance these efforts by offering additional suggestions on areas needing further detail.

Key recommendations from CDT Europe include expanding independence requirements for applicant researchers to prevent government overreach and explicitly mentioning civil society organizations (CSOs), including those outside the EU, as potential applicant researchers. They also suggest detailing requirements for data inventory completeness, empowering researchers to initiate mediation processes, involving independent experts in assessing data inventories' quality and mediation processes, and extending timelines for Digital Services Coordinators (DSCs) responding to data access applications.

The full consultation is available online and in PDF format.