2023年11月16日
Metaverse November 2023 – 2 / 3 观点
The clock is ticking: In a little less than 3 months (on 17 February 2024), the comprehensive catalog of obligations under the Digital Services Act (DSA) will have to be observed by all affected service providers. In this article, we provide a suggested checklist for getting DSA-ready. It comprises basic items to get going and needs to be adapted to your organization’s individual needs. For any questions, reach out to our team.
1. Check whether the DSA applies to you
2. Check what type of intermediary you are
3. Check what types of obligations apply to you
New obligations | Intermediary services (cumulative obligations) |
Hosting services (cumulative obligations) |
Online platforms (cumulative obligations) |
Very large platforms (cumulative obligations) |
---|---|---|---|---|
Transparency reporting | X | X | X | X |
Requirements on terms of service due account of fundamental rights | X | X | X | X |
Cooperation with national authorities following orders | X | X | X | X |
Points of contact and, where necessary, legal representative | X | X | X | X |
Notice and action and obligation to provide information to users | X | X | X | |
Reporting criminal offences | X | X | X | |
Complaint and redress mechanism and out of court dispute settlement | X | X | ||
Trusted flaggers | X | X | ||
Measures against abusive notices and counter-notices | X | X | ||
Special obligations for marketplaces, e.g. vetting credentials of third party suppliers ('KYBC'), compliance by design, random checks | X | X | ||
Bans on targeted adverts to children and those based on special characteristics of users | X | X | ||
Transparency of recommender systems | X | X | ||
User-facing transparency of online advertising | X | X | ||
Risk management obligations and crisis response | X | |||
External & independent auditing, internal compliance function and public accountability | X | |||
User choice not to have recommendations based on profiling | X | |||
Data sharing with authorities and researchers | X | |||
Codes of conduct | X | |||
Crisis response cooperation | X |
Quelle: European Commission
4. Planning your DSA implementation project
Many of the DSA’s obligations cannot be realized overnight and need time to be set up and get going within your organization.