Stakeholder reactions to the Digital Services Act

Position Papers & Publications

2022

August

CDT: A Series on the EU Digital Services Act: Tackling Illegal Content Online.

Reactions following the adoption of the Digital Services Act in Plenary on 5 July 2022

EBU: European Parliament adopts the digital services package, setting the bar high for online platforms.

Business Europe: Business supports EU’s green light for competitive and safer digital sector.

ECommerce Europe: European Parliament’s plenary adopts the Digital Services Act and Digital Markets Act.

Federation of European Publishers: The Digital Services Act is adopted, but does not fix the Internet

ETNO: Telecom Industry Applauds EU Institutions for New Platform Rulebooks.

ITI: ITI Statement on the DSA and DMA Final Plenary Vote in European Parliament.

ACT: Adopted DMA & DSA require strong enforcement & complementary legislation to deliver on digital promises.

Bitkom: Bitkom on the final vote on DSA and DMA.

LightingEurope: EU policymakers miss the opportunity to close the loophole on liability and to ensure that what is illegal offline is illegal online.

July

Center for Data Innovation: Proposals to Restrict Targeted Ads Make Even Less Sense With Recent Innovations in AdTech

Reactions following the approval of the provisional text in EP IMCO

Ecommerce Europe: EU Institutions nearing formal Digital Services Act approval: implementation concerns remain.

Center for Democracy and Technology (CDT): Digital Services Act Approved by Key EU Committee: Still a Long Road Ahead

May

BEUC: The European Commission must allocate sufficient resources to DMA and DSA enforcement.

Reactions following the political agreement of 23 April 2022

European Brands Association (AIM): The Digital Services Act should help crack down on illegal goods but is not future-proof.

Center for Democracy & Technology: The Digital Services Act: Political Agreement Reached, Long Road Ahead Awaits.

IAB Europe: IAB Europe Reacts to the Political Agreement on the DSA

AccessNow: EU’s political deal on the Digital Services Act step in the right direction, but some questions remain.

ITI: ITI Statement on DSA Final Agreement.

EDRi: EU negotiators approve good DSA, but more work is needed to build a better internet.

BEUC: Digital Services Act brings improvements for consumers online, but fails to go full mile.

CCIA: Digital Services Act: EU Negotiators Reach Political Agreement.

News Media Europe: New European internet rules: putting an end to the wild wild west?

April

ECIPE: After the DMA, the DSA and the New AI regulation: Mapping the Economic Consequences of and Responses to New Digital Regulations in Europe.

European Center for Non-for-Profit Law: Digital Services Act: Don't compromise on the protection of Fundamental Rights.

BEUC: Digital Services Act must go full mile to better protect consumers, not take half-measures

BEUC: The Digital Services Act (DSA) must include strong provisions on tracking ads, dark patterns and online marketplaces.

Civil society organizations joint statement (including EDRi, AccessNow, CDT, EFF and others): Civil society to EU: don’t threaten rights with last-minute “crisis response mechanism” in DSA.

March

Joint Letter by Civil Society Organisations (including Corporate Europe Observatory, LobbyControl, Access Info Europe, FragDenStaat, The Good Lobby, Statewatch and ARTICLE 19): Over 40 CSOs and trade unions demand transparency in DSA-DMA trilogues.

Open Letter by 72 civil society organisations (including EDRi, Access Now, Amnesty International, Centre for Democracy & Technology, European Youth Forum, LobbyControl and Wikimedia Deutschland): Civil society calls for a Digital Services Act that benefits people and is compatible with human rights.

Joint letter from European industry players (including Anitec-Assinform, CCIA, Confederation of Finnish Industries, Danish Entrepreneurship Association, DigitalFuture, Digital Poland, Estonian Employers' Confederation, FNTM, InfoBalt, RVSZ, Lewiatan, NUE, Sapie, Association for Internet Progress and ZPP): 16 Associations Call For a “fair, workable and effective” Digital Services Act.

SMEConnect: DSA: Explaining how KYBC may impact European SMEs.

Toy Industries of Europe (TIE): Europol’s operations against illicit toys point to the need of a stronger Digital Services Act.

People vs. Big Tech Coalition (including EDRi, Access Now, Avaaz, Global Witness, LobbyControl and other 30 NGOs): France must not betray European citizens on the DSA at the 11th hour.

February

BEUC: "Dark Patterns" and the EU Consumer Law Acquis

Center for Data Innovation: The EU is on the Cusp of Banning Personalized Ads, While Campaigners Deliberately Ignore the Costs to European Businesses

Joint letter by 54 associations of the French Cultural and Creative sector: DSA: Europe in the hands of digital giants.

EBU: Digital Services Act - EBU Priorities for Trilogue Negotiations

Joint Industry Statement by European Media Associations on the DSA trilogue negotiations (including EPC, ACT, AER, EBU, EGTA, EMMA, ENPA and NME).

BEUC: Digital Services Act: BEUC Recommendations for the trilogue negotiations.

European Tech Alliance: EUTA Position for Digital Services Act (DSA) Trilogues.

January

Federation of European Data and Marketing: DSA: FEDMA recommendations ahead of the vote in plenary – Hosting services, dark patterns, gatekeeper platforms, industry standards.

Europe's media sector: (including AER, EMMA, EPA, EPC, EBU, News Media Europe and EGTA): The Digital Services Act must safeguard freedom of expression online.

EuroCommerce: DSA: need for a level playing field to drive online innovation in Europe.

Joint letter by associations of the media sector (including ACT, AEPO-ARTIS, AER, AAPA, ANIMATION in EUROPE, CEPI, CEPIC, ECSA, EIBF, EUROCINEMA, FEP, FIA, FIAD, FIAPF, FIM, FSE, GESAC, IAO, ICMP, IFPI, IFTA, IMPALA, IMPF, IVF, MPA, SAA, SROC, STM and UNIC): Plenary holds cards to building a safer internet.

Corporate Europe Observatory: Corporate lobbying undermined the EU’s push to ban surveillance ads.

DIGITALEUROPE: Ironing out new rules for online platforms: What to watch out for during the Digital Services Act trilogues.

EDRi: Framing the future of the internet

Reactions following the vote of the DSA report in Plenary on 19 - 20 January.

People vs BIGTECH: DSA Reactive: European Parliament stands up to big tech - Votes to restrict abusive business model.

EDRi: European Parliament approves rights-respecting DSA & proposes ban on use of sensitive personal data for online ads

CCIA: CCIA Statement on European Parliament Plenary Vote on the Digital Services Act

News Media Europe: The European Parliament fails to deliver a strong Digital Services Act

BEUC: EU Parliament improves some protections for consumers in digital services but fails to go full mile

FEDMA: FEDMA reacts to the European Parliament vote on the Digital Services Act: Preserving online advertising transparency and promoting better coherence with existing and forthcoming laws

Mozilla: European Parliament green-lights crucial new rulebook for Big Tech

ITI: ITI Issues Statement on DSA Plenary Vote in European Parliament

ACT: Trilogues last opportunity to fulfil DSA promise following disappointing European Parliament vote

Federation of European Publishers: European Parliament adopts its position on the Digital Services Act and misses an opportunity to deal a blow to illegal content online.

DOT Europe: DOT Europe welcomes progress on Digital Services Act.

Interactive Software Federation Europe (ISFE): Europe’s video games industry calls on policymakers to address shortcomings following today’s DSA vote in plenary

Federation of the European Sporting Goods Industry (FESI): FESI regrets the lack of ambition of the Parliament’s position on the DSA: a missed opportunity to protect brands and consumers from illegal products online

Allied for Startups: Digital Services Act vote: An opportunity for startups but a long road ahead.

Joint letter by associations from the media sector (Creativity Works! including ISFE, CEPI and ACT): DSA vote: Broader KYBC obligations but a missed opportunity to secure a safer online environment.

European Disability Forum: The European Parliament agreed on safer and accessible online platforms for persons with disabilities.

2021

December

AIM: In their current shape, some compromises on the Digital Services Act (DSA) would risk harming consumers and businesses, particularly offline SMEs.

ITI: ITI Sends Letter on DSA Ahead of Vote in IMCO Committee.

Reactions following the Adoption of the DSA report in EP IMCO Committee on 14 December

Access Now: Victories in the DSA vote: IMCO Committee puts people’s rights before corporate interest.

BEUC: Glass half full for consumers following Parliament vote on key digital services rules.

News Media Europe: European press urges European Parliament to protect editorial content integrity and online advertising revenues.

EDRi: Has the Parliament effectively wielded the Digital Services Act to challenge platform power? The verdict is, somewhat.

ECommerce Europe: EP IMCO adopts DSA Report: some good progress, but key concerns remain to be addressed.

European Tech Alliance: EUTA Statement on the final DSA vote in the IMCO Committee.

Together Against Counterfeiting Alliance (TAC): Brands warn that the current Parliament's position on the DSA allows that "what is illegal offline remains legal online" and call on meaningful changes in Plenary to fight counterfeits online.

Algorithm Watch: DSA milestone: EU lawmakers have responded to our calls for meaningful transparency for big tech

Disinfo: Digital Services Act Update.

European Disability Forum (EDF): Members of the European Parliament vote to ensure accessible online platforms for persons with disabilities.

Electronic Frontier Foundation (EFF): Digital Services Act: EU Parliament's Key Committee Rejects a Filternet But Concerns Remain.

Computer & Communications Industry Association (CCIA): CCIA’s Response To European Parliament Vote on the Digital Services Act.

European Brands Association (AIM): IMCO favours platforms over EU consumers and legitimate businesses in report on Digital Services Act.

Article 19: EU: Another missed opportunity to ensure a pluralistic digital ecosystem.

Creativity Works: DSA: Disappointing IMCO vote, but a genuinely safe and trustworthy online environment is still possible, says Creativity Works!

Center for Democracy & Technology (CDT): European Parliament IMCO Committee Adopts DSA Report: Significant steps Forward, Leaps Still to Be Made.

ITI: ITI Issues Statement on DSA Vote in IMCO Committee.

European Publishers Council: EPC Statement on the DSA and why we need an obligation of non-interference by gatekeepers.

European Audiovisual Production: DSA: Disappointing IMCO vote, but a genuinely trustworthy online environment is still possible.

iab Europe: DSA IMCO vote: IAB Europe commends avoidance of a ban on “targeted” ads but warns of overlap and contradictions with existing data protection law

November

Access Now, Article 19, European Partnership for Democracy and Panoptykon Foundation: Joint statement on recommender systems.

EU DisinfoLab: Fact-checkers and experts call on MEPs to reject a media exemption in the DSA.

Center for Data Innovation: European Policymakers Should Not Ban Personalized Advertising.

Computer & Communications Industry Association (CCIA): 16 leading trade associations call on MEPs to ensure the DSA remains a workable, balanced and future proof.

European Brands Association: Joint industry letter - Intermediary services should “earn their liability exemptions”.

EDRi: European Parliament’s plans of a Digital Services Act threaten internet freedoms.

EDRi: Platform Regulation: Key takeways from Haugen’s hearing.

Wikimedia: The Digital Services Act could require big changes to digital platforms. Here are 4 things lawmakers need to know to protect people-powered spaces like Wikipedia.

EGBA: EGBA Joins Other Leading Trade Associations To Call For A Workable, Balanced, And Future-Proof EU Digital Services Act

AIM: AIM publishes statement on Council general approach for Digital Services Act.

News Media Europe: European Media call on co-legislators to protect editorial content integrity and free media in the Digital Services Act.

BEUC: Mixed bag for consumers in Member States’ position on major digital services legislation.

CCIA: CCIA Welcomes the Council’s General Approach on the Digital Services Act, Cautions More Work Needed on the Digital Markets Act.

October

European Broadcasting Union (EBU): Protecting media content online: a decisive moment

Electronic Frontier Foundation (EFF): Europe's Digital Services Act: On a Collision Course With Human Rights.

EDRi: Digital Services Act: The EDRi guide to 2,297 amendment proposals

Ecommerce Europe, Independent Retail Europe, Eurocommerce: Joint Industry Statement on Targeted Advertisement and the DSA.

Digital Services Act Human Rights Alliance: Digital Services Act: bad decisions can lead to global consequences

CERRE: What is the harm in size? Very Large Online Platforms in the Digital Services Act.

EUROCHAMBRES: European Chambres of Commerce call policy-makers to set fair and realistic rules for entrepreneurs (Statement on the DSA).

CISPE (Cloud Infrastructure Services Providers in Europe): European Lawmakers seeking exclusions for cloud infrastructure risk rendering the Digital Markets Act ineffectual.

Joint call by business, consumer and civil society organisations: Digital Services Act (DSA): Effective and unambiguous rules are needed to tackle illegal activities and rogue traders.

Mozilla: Addressing gender-based online harms in the DSA.

European Brands Association: AIM Statement on ITRE/JURI opinions for the Digital Services Act.

EDRI: DSA should tackle the root cause of polarisation, not just its symptoms.

EDRi: Warning: the EU’s Digital Services Act could repeat TERREG’s mistakes.

The European Consumer Organisation: Reasons to add the Digital Markets Act to the Representative Actions Directive.

European Interactive Digital Advertising Alliance: EDAA & The DSA.

ITI: Global Tech Industry Reacts to the Competitiveness Council General Approach on the Digital Services Act and Digital Markets Act.

IAB Europe: IAB Europe Launches New Campaign On Targeted Advertising At Crunch Time For The Digital Services Act (DSA)

September

Panoptykon Foundation: Big Tech platforms are hurting us. 50 organisations urge the EU to #fixalgorithms.

European Brands Association: AIM co-signs joint industry letter on trusted flaggers in DSA.

Allied for Startups: Tweaking the Country of Origin principle in the DSA – A threat to the Digital Single Market.

Independent Retail Europe, SMEunited, and HOTREC: Digital Services Act – Joint statement of Independent Retail Europe, SMEunited, and HOTREC.

Access Now, Electronic Frontier Foundation and European Digital Rights: Civil society to EU: don’t derail the Digital Services Act.

EEA/EFTA: EEA EFTA States highlight how the Digital Services Act can contribute to a safer online environment.

August

EDRi: Can the EU Digital Services Act contest the power of Big Tech’s algorithms?

July

EDRi - European Digital Rights: Joint Civil Society Statement Urges IMCO Committee to Uphold Fundamental Rights in the DSA.

CCIA - Computer & Communication Industry Association: Industry Groups Urge Protection of Fundamental Principles and Rights in the Digital Services Act (also signed by ACT, Allied for Startups, DOT Europe, EuroISPA and Tech UK)

EACA - European Association of Communications Agencies: EACA comments on the proposed ban on targeted advertising.

June

Hate Aid: Digital Services Act: Barely Any Protection for Victims of Digital Violence

CCIA - Computer & Communication Industry Association: CCIA Reacts To European Parliament’s Digital Markets Act and Digital Services Act Reports.

DOT Europe: DOT Europe disappointed by IMCO draft report on DSA.

EDRi - European Digital Rights: DSA should promote open and fair digital environment, not undermine the rule of law.

BEUC - The European Consumer Organisation: Factsheet on the Digital Services Act.

EuroCommerce: Retailers ask for a safe, trustworthy digital environment for consumers.

Europe’s media sector (including AER, ACT, AER, EMMA, EBU, EGTA, News Media Europe, ENPA and EPC): European media call on policymakers to further strengthen the Digital Services Act proposal and to ensure that citizens can continue to engage online with the media they most trust and value.

May

Microsoft: Microsoft supports new rules for gatekeepers.

News Media Europe: News Media Europe adopts its Position Paper on the Digital Services Act proposal.

Mozilla: Mozilla publishes position paper on EU Digital Services Act.

EPC: European Publishers Council's views and recommendations on the Digital Services Act Proposal.

April

ECIS - European Committee for Interoperable Systems: ECIS Feedback on the Digital Services Act.

DOT Europe: Questions and Recommendations on the DSA.

SMEUnited: Position Paper on the Digital Services Act.

BEUC - The European Consumer Organisation: Position Paper on the Digital Services Act.

Together Against Counterfeiting (TAC) Alliance - Recommendations on the Digital Services Act.

Intergroup on the Welfare & Conservation of animals: Time is up: Digital Services Act crucial to curb illegal animal trade.

Council of European National Top-Level Doman Registries: CENTR publishes comments on the proposed Digital Services Act.

DOT Europe: Key principles to consider prior to drafting a Code of Conduct under the DSA.

ETNO & GSMA: Position on the DSA.

Association of Commercial Television in Europe: ACT Guidance and Indicators for the Code of Practice 2.0.

January - March

ETNO & GSMA: A Telecoms Industry View on the Digital Services Act.

Electronic Frontier Foundation: EFF’s Policy Principles for the Digital Services Act.

CCIA - Computer & Communication Industry Association: Position Paper on the EU Digital Services Act

EUTA - European Tech Alliance: Reaction to Commission’s Digital Services Act proposal.

Bitkom: Position paper on the proposal for a Digital Services Act

DIGITALEUROPE: Digital Services Act Position Paper

Amnesty International: Position on the Proposals for a Digital Services Act and a Digital Markets Act

DOT Europe: Preliminary remarks on the DSA: Consider the focus, scope and coherence of the proposal

Developers Alliance: Developers Alliance Recommends Core Principles For Digital Service Act Success.

IAB Europe: Position Paper on the Digital Services Act.

Initial Reactions on the Digital Services Act and Digital Markets Act (15 - 17 December 2020)

Ecommerce Europe: Ecommerce Europe’s preliminary reaction to the Digital Services Act Proposal.

DIGITALEUROPE: “Clarity on platforms’ roles and responsibilities as well as enforcing existing competition tools are key”.

European Consumer Organisation (BEUC): EU plans on digital economy are step in right direction but more ambition is needed.

DOT Europe: DOT Europe DSA Reaction.

The App Association (ACT): The App Association Reacts to European Commission's Digital Markets Act and Digital Services Act.

European Brands Association (AIM): DSA and DMA – a starting point to deliver a clean and fair platform ecosystem.

Computer & Communications Industry Association (CCIA): CCIA Responses To EU Digital Markets Act and Digital Services Act Proposals.

European Digital SME Alliance: Digital Services/Markets Act: Commission proposes rules on gatekeepers for a more competitive market environment.

European Publishers Council (EPC): EPC gives cautious welcome to Commission’s ambitious plans to take digital gatekeepers.

Together Against Counterfeiting Alliance (TAC): Together Against Counterfeiting Alliance calls on the European Parliament and Member States to increase the level of ambition of the European Commission's Digital Services Act proposal.

European Digital Rights (EDRi): ‘A for effort’: European Commission DSA/DMA proposal falls short of the systemic change needed to rein in Big Tech power.

EuroCommerce: With omnichannel the new reality, rules need to foster competitive EU ecosystems.

LightingEurope: The Digital Services Act acknowledges gap in the online product supply chain.

Hospitality Europe (HORTEC): Newly proposed EU platform rules can support digitalization of European hospitality SMEs

Federation of the European Sporting Goods Industry (FESI): FESI welcomes the new Digital Services Act but calls for stronger obligations against the presence of illegal products.

Association of European Radios (AER): Commercial radio reacts to the publication of the Digital Markets Act (DMA) and Digital Services Act (DSA) proposals.

Information Technology Industry Council (ITI): ITI Reacts, Offers Initial Analysis to EU Proposals on New Rules for Internet Companies.

Allied for Startups: Allied for Startups welcomes opportunity to update and clarify regulatory framework for startups in the Digital Services Act (DSA), applauds inclusion of key principles.

Allied for Startups: Allied for Startups encourages European institutions to design a Digital Markets Act that incentivises starting up and scaling.

Center for Democracy & Technology: Digital Services Act: Despite Good Intentions, Fundamental Inconsistencies Put Rights at Risk.

Center for Data Innovation: With Two Legislative Proposals to Regulate the Online Environment, the EU Is Shooting Itself in Both Feet.

Access Now: DSA: European Commission delivers on the first step toward systemic rules for online platforms.

Developers Alliance: Developers Alliance Wary Of Unproven Measures In Digital Services Act And Digital Markets Act.

Creativity Works: The DSA should upgrade the responsibility of online platforms, not weaken it, says Creativity Works!.

Bitkom: Bitkom on EU initiatives for digital markets.

IBM: IBM Statement on the Digital Services Act and Digital Markets Act.

Mozilla: Mozilla reacts to publication of draft Digital Services Act and Digital Markets Act.

European Casino Association, The European Lotteries and World Tote Association: Illegal gambling is a threat to the safety of EU citizens.

SMEUnited: A step in the right direction to make digital markets more open for SMEs.

Conseil Supérieur de l'Audiovisuel: DSA : le CSA apportera toute sa contribution dans le cadre des négociations qui s’engagent.

Imaging Consumables Coalition of Europe (ICCE): ICCE welcomes new EU Digital Services Act establishing revised online commerce framework.

CEC European Managers: CEC European Managers welcomes the proposal by the European Commission.

News Media Europe: News publishers: “DSA and DMA are a missed opportunity to rebalance online ecosystem”.

ACT - Association of Commercial Television in Europe: DMA/DSA: Broadcasters support Commission proposals to end Platforms’ unfair digital practices and strongly encourage a liability regime that delivers effective accountability online.

ACT - Association of Commercial Television in Europe: The DSA should upgrade the responsibility of online platforms, not weaken it, says Creativity Works!