- Office of Electronic Communications

First report of the Digital Services Council on systemic risks under the DSA adopted

On November 18, 2025, the European Digital Services Council, in cooperation with the European Commission, published its first report under Article 35(2) of the Digital Services Act (DSA). The document identifies the most important and frequently occurring systemic risks associated with the operation of very large online platforms (VLOPs) and very large search engines (VLOSEs) and presents a set of effective measures to mitigate them.

Such risks include, among others, the dissemination of illegal content (e.g., child sexual abuse material) and dangerous or counterfeit products (e.g., cosmetics, toys, electronic devices, explosives, or chemicals). Risks related to the protection of minors and threats to the mental well-being of users, such as increased susceptibility to the addictive nature of social media use, were also mentioned. The report also presents risk mitigation measures implemented by the largest providers, including intellectual property protection programs on marketplaces to protect consumers from dangerous counterfeits, as well as the use of automated tools to detect situations where, for example, emojis are used as code to conceal illegal activities.

It was emphasized that, pursuant to Articles 34 and 35 of the DSA, the largest platforms, i.e., those reaching at least 45 million users in the European Union, are obliged to regularly and thoroughly assess the risks arising from the operation of their services, including the operation of algorithms, and to implement proportionate and effective countermeasures while respecting fundamental rights. This process should be based on the best available scientific knowledge and dialogue with groups particularly vulnerable to the negative impacts of risks.

As the first edition of the annual report referred to in Article 35(2) of the DSA, this publication provides a starting point for developing a long-term perspective on identifying the most significant and recurring systemic risks. As progress is made in implementing other provisions of the DSA, including the data access mechanisms under Article 40 of the DSA and the research based on such access, the knowledge base on systemic risks and mitigation methods will steadily expand, enabling increasingly robust, data-driven application of Articles 34 and 35 of the DSA.

Link to the Commission's communication and the full report.