25 January, 2024

ETNO comments to the European Commission’s Draft Implementing Regulation laying down templates concerning the transparency reporting obligations of providers of intermediary services and of providers of online platforms under Regulation (EU) 2022/206

ETNO welcomes this opportunity to provide comments to the European Commission’s draft Implementing Regulation laying down templates concerning the transparency reporting obligations of providers of intermediary services and of providers of online platforms under the ‘Digital Services Act’ (DSA).

In general, ETNO believes that the number of variables included in the annex I template should be strictly limited to the DSA obligations pursuant to articles 15(1), 24(1) and 42(2) in order to reduce to the administrative burden for providers. Obligations extend to ETNO members, who do not have neither ability nor the legal right to see the content of communications and therefore to moderate content for the vast majority of the services they provide. Many ETNO members also already publish transparency reports on relevant efforts (e.g. blocking of websites done on the basis of EU and national laws). Detailed regulation of how companies should report implies changes in systems and processes, without tangible benefits in terms of transparency.

We elaborate on our comments in the document For questions and clarifications regarding this feedback, please contact Xhoana SHEHU, Policy Manager at ETNO (shehu@etno.eu).