The DSA Civil Society Coordination Group, along with the Recommender Systems Taskforce and People vs Big Tech, has released an initial analysis of Risk Assessment Reports from major platforms under Article 42 of the Digital Services Act (DSA). This analysis highlights both effective practices and significant gaps, providing recommendations to improve future reports and ensure compliance with the DSA.
The DSA aims to create a safer online environment through yearly risk assessments mandated by Articles 34 and 35. These require Very Large Online Platforms (VLOPs) and Very Large Online Search Engines (VLOSEs) to identify, assess, and mitigate systemic risks posed by their services.
The first set of RA Reports revealed diverse approaches to risk identification but also varied formats for presenting information. The analysis focused on key issues like online protection of minors, media pluralism, and online gender-based violence. The goal is to establish a baseline for future reports by highlighting effective transparency practices.
A recurring issue in these reports is the insufficient focus on design-related risks. While some platforms acknowledged their systems' roles in amplifying harmful content, such references were often indirect. Design choices driven by engagement metrics can contribute significantly to systemic risks like mental health issues or political polarization. Future RA Reports should prioritize assessing these design-related risks.
Transparency is crucial for building trust with users and regulators. Many reports lacked verifiable data to support claims about mitigation measures' effectiveness. Platforms need to disclose quantitative and qualitative data to demonstrate compliance effectively.
Engagement with civil society, researchers, and impacted communities is vital for identifying systemic risks. However, none of the analyzed RA Reports detailed how external expertise was incorporated into their assessments. Meaningful stakeholder engagement will strengthen report credibility.
The initial round of RA Reports marks progress toward accountability but reveals significant gaps remain. Recommendations include focusing on design-related risks tied to recommender systems, enhancing transparency through verifiable data, and engaging stakeholders meaningfully.
By addressing these gaps, VLOPs and VLOSEs can align with the DSA's objectives for a safer digital environment while rebuilding trust with users and regulators. Civil society remains committed to supporting this process through ongoing analysis and collaboration.
"The DSA CSO Coordination Group," convened by CDT Europe, "is an informal coalition of civil society organisations," advocating for human rights protection under the EU Digital Services Act.
