SUMMARY:

• On 17th November, the European Commission published its awaited report (attached) on the assessment of the Digital Services Act’s (DSA) interaction with other EU laws and the designation process for Very Large Online Platforms (VLOPs) and Very Large Online Search Engines (VLOSEs).
• The report confirms that the designation criteria of VLOPs and VLOSEs, including the threshold of 45 million average monthly active recipients, remain fit-for-purpose and aligned with today’s dynamic digital environment.

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MORE INFORMATION:

The report provides an extensive evaluation of how the DSA interacts with 54 different EU legal acts, covering areas such as:

• data protection and privacy
• audiovisual, media and intellectual property
• consumer protection
• product safety
• democracy, security, and justice

The analysis demonstrates that the DSA generally complements sector-specific legislation, providing a strong and harmonised baseline for EU rules applying to digital platforms and online intermediaries. Its horizontal nature reinforces legal certainty and supports coherent implementation across policy areas.

In the context of the EU’s ongoing digital simplification process, the report also identifies selected provisions where overlaps exist and where stronger coordination would help ensure clearer and more consistent application of legal frameworks. These insights will inform upcoming legal revisions and further alignment efforts.

Prepared under Article 91(1) of the DSA, the report fulfils a legal obligation requiring the Commission to assess the adequacy of the DSA’s horizontal framework and its interplay with other legislation by 17 November 2025. It draws on feedback gathered from civil society organisations, Digital Services Coordinators, national authorities, and online platforms, including VLOPs and VLOSEs, through three Commission-run surveys. Stakeholder input reflects a broad consensus on the need for clearer rules, better guidance, and enhanced interinstitutional cooperation.

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NEXT STEPS:

The Commission will use the findings to inform future alignment and simplification efforts across the digital acquis, as well as the upcoming evaluations mandated by the DSA. FESI will continue to monitor related developments and provide updates to members.