IPIE SUBMISSION TO THE EUROPEAN COMMISSION ON THE IMPLEMENTATION OF REGULATIONS FOR TRANSPARENCY REPORTING OBLIGATIONS UNDER THE DIGITAL SERVICES ACT

The International Panel on the Information Environment (IPIE) recommends amending the European Commission's draft qualitative template for DSA transparency reports to better capture risk mitigation data. The IPIE argues that content moderation is fundamentally a risk mitigation measure and that transparency reports should explicitly include information on content labelling, corrective information, and the specific parameters of automated moderation tools. This would bridge the gap between general transparency obligations (Articles 15 and 42) and the systemic risk assessment requirements (Articles 34 and 35) for very large online platforms and search engines, facilitating faster access to data for scientific researchers.

• The IPIE argues that the draft mandatory qualitative template in Annex II fails to adequately capture information regarding risks and risk assessments, despite content moderation being used as a risk mitigation measure.
• The IPIE recommends that the transparency reporting obligations under Articles 15 and 42 be explicitly linked to the risk assessment and mitigation requirements set out in Articles 34 and 35 of the DSA.
• The IPIE identifies four specific areas for amendment in the qualitative template: summaries of content moderation on the provider's own initiative, information on detection methods, the use of automated means for moderation, and the qualitative description and purposes of those automated means.
• The IPIE suggests that the 'Summary of the content moderation' field should specifically include data on content labelling, corrective information, and account moderation.
• The IPIE proposes that the 'Specification of the precise purposes to apply automated means' field should identify the specific problems the tools are intended to address rather than just the intended outcome.
• The IPIE asserts that relying solely on the publication of risk assessments is insufficient for researchers because the 15-month waiting period creates an "unreasonable barrier to researcher access to data."
• The IPIE identifies a scientific consensus supporting four effective strategies for improving the information environment: content labelling, corrective information, content or account moderation, and information and media literacy.

APA

Glenster, A. K., Howard, P., & Ward, J. (2024). IPIE SUBMISSION TO THE EUROPEAN COMMISSION ON THE IMPLEMENTATION OF REGULATIONS FOR TRANSPARENCY REPORTING OBLIGATIONS UNDER THE DIGITAL SERVICES ACT. International Panel on the Information Environment. https://www.ipie.info/research/tp-2024-1

Chicago

Glenster, Ann Kristin, Philip Howard, and James Ward. IPIE SUBMISSION TO THE EUROPEAN COMMISSION ON THE IMPLEMENTATION OF REGULATIONS FOR TRANSPARENCY REPORTING OBLIGATIONS UNDER THE DIGITAL SERVICES ACT. International Panel on the Information Environment, 2024. https://www.ipie.info/research/tp-2024-1.

Wikipedia

{{cite press release |last1=Glenster |first1=Ann Kristin |last2=Howard |first2=Philip |last3=Ward |first3=James |title=IPIE SUBMISSION TO THE EUROPEAN COMMISSION ON THE IMPLEMENTATION OF REGULATIONS FOR TRANSPARENCY REPORTING OBLIGATIONS UNDER THE DIGITAL SERVICES ACT |publisher=International Panel on the Information Environment |date=2024 |url=https://www.ipie.info/research/tp-2024-1 |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{glenster2024ipie, author = {Glenster, Ann Kristin and Howard, Philip and Ward, James}, title = {{IPIE SUBMISSION TO THE EUROPEAN COMMISSION ON THE IMPLEMENTATION OF REGULATIONS FOR TRANSPARENCY REPORTING OBLIGATIONS UNDER THE DIGITAL SERVICES ACT}}, publisher = {International Panel on the Information Environment}, year = {2024}, url = {https://www.ipie.info/research/tp-2024-1}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }