DSA Implementation Report, 2026

Written By INACH Secretariat

Summary

The DSA has established a strong regulatory framework, but its long-term success will depend on consistent implementation, effective enforcement, greater platform accountability, and meaningful participation of civil society. To fully realise the DSA's objectives, enforcement must increasingly shift from addressing individual pieces of illegal content to tackling the systemic mechanisms that enable online harms to spread.

You can read the full report by clicking the button below, or scroll through the blog post for a summary of the key findings.

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Main Themes

Monitoring

INACH's 2025 Monitoring Exercise and a cross-border Holocaust Denial reporting exercise revealed improved procedural compliance, but ongoing inconsistencies in removals, transparency, and platform cooperation.

Trusted Flaggers

The report welcomes the Commission's draft Trusted Flagger Guidelines but highlights:

• lack of sustainable funding,

• inconsistent platform onboarding,

• insufficient protection against political attacks,

• limited operational advantages,

• and the need for stronger cooperation between Trusted Flaggers, regulators and platforms.

Digital Services Coordinators

Implementation varies considerably between Member States. Some DSCs actively engage with civil society, while others have limited interaction. The report calls for more structured dialogue and greater consistency across the EU.

Transparency & Systemic Risks

Although transparency reporting has improved, reports remain difficult to interpret and focus mainly on operational statistics rather than whether platforms effectively reduce systemic risks such as algorithmic amplification of hate speech. Civil society also lacks a formal mechanism to submit evidence of systemic risks.

 

Key Findings

  • • Trusted Flaggers have now been designated across much of the EU

    • Digital Services Coordinators (DSCs) are becoming operational

    • The European Commission has launched several investigations into VLOPs

    • Transparency reporting and Out-of-Court Dispute Settlement (ODS) mechanisms are beginning to function

    • Platforms generally respond faster to reports than before

  • Despite progress, significant shortcomings remain:

    • Platforms continue to rely heavily on geoblocking and visibility restrictions instead of removing illegal content

    • Reporting procedures remain inconsistent across platforms

    • Trusted Flagger reporting channels are still incomplete (for example, comments cannot be reported through Trusted Flagger channels on YouTube)

    • Moderation decisions often lack meaningful explanations

    • Technical barriers continue to undermine effective Notice-and-Action procedures

    • Greater attention is still given to individual content than to the systemic risks that enable online hate to spread

Key Recommendations

  • • Strengthen the systemic risk framework

    • Provide sustainable funding for Trusted Flaggers

    • Clarify DSA obligations and geoblocking practices

    • Establish a permanent European cooperation framework for DSA stakeholders

  • • Develop regular dialogue with civil society

    • Create national procedures for reporting systemic risks

    • Promote capacity building and exchange of best practices

  • • Use geoblocking only where strictly necessary and not as a substitute for content removal

    • Improve transparency of moderation decisions

    • Harmonise reporting systems

    • Strengthen cooperation with civil society and ODS bodies

    • Address systemic drivers of online harm rather than individual posts alone

INACH Secretariat
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