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Implement the DSA for platforms and hosting services
Clear processes instead of mere knowledge of the law.
For companies concerned, the DSA is no longer a future topic. We check whether your service falls under the Digital Services Act, which tier of duties and obligations applies and which implementation is specifically required.
Please enter a short description first.
Initial contact is free of charge. Before any costs arise, we will expressly point this out to you.
Response within 24 hours on working days
As of: 23 October 2026
DSA obligations matrix1 of 5
- Service categoryOnline platformAvailable
- Points of contact and termsCheck
- Missing
Notice and action No statement-of-reasons process - Complaint handlingMissing
- Transparency reportCheck
Checkpoint: Blocks without a reasoned decision
- 1Clarify DSA statusCategory and role
- 2Determine obligationsSpecific measures
- 3Secure implementationTexts and evidence
Schematic illustration of a DSA classification. Simplified example.
We check DSA obligations for
- Platforms
- Marketplaces
- Hosting services
- Communities
Key points at a glance
- The Digital Services Act applies to intermediary services, hosting services, online platforms and marketplaces with tiered obligations.
- Anyone who stores user content, makes moderation decisions or onboards merchants needs clear processes instead of mere knowledge of the law.
- ITMR classifies your service, determines the tier of obligations and builds terms, reporting channels, complaints, statements of reasons and transparency reports.
- A specialist lawyer for IT law supports you at every step of DSA implementation.
- Your contact is Jean Paul Bohne and his team. He is a specialist lawyer for IT law and for copyright and media law. Response within 24 hours on working days.
- DSA
- Digital Services Act. EU regulation with obligations for online platforms and intermediary services.
- SaaS
- Software as a Service. Software that is used over the internet and not installed.
- Data Act
- EU Data Regulation. It governs access to data from connected products and services.
- NIS2
- EU directive on cybersecurity. It obliges many companies to carry out risk management and reporting.
Practice
Where does DSA implementation fail in practice?
Nobody doubts that the Digital Services Act exists. The question is whether service category, user processes, terms, moderation, complaints, transparency and documentation fit together.
A notice form is of little help if review, reasoning and feedback are not regulated internally.
The Digital Services Act works in tiers. A mere conduit service, a hosting offer, an online platform, a marketplace with third-party sellers and a very large service do not have the same profile of obligations. Anyone who skips this first classification builds compliance in the wrong place.
The legal review must be built from the business model. The specific function is decisive. Who posts content, who can report, who decides, who complains, who sells, who advertises, who moderates?
DSA risk arises where product, legal, customer service, trust & safety, marketing and management are affected at the same time. A template clause is then not enough. The German Digital Services Coordinator and the European Commission make DSA compliance a management issue close to documentation and procedure.
For providers of digital services, the DSA shapes how notices come in, how content is reviewed, how users are informed, how complaints are handled, how marketplaces vet merchants and how decisions can be explained later. The DSA is therefore procedural architecture and compliance at the same time.
- For whom
- Platforms, hosting, marketplaces
- Basis
- Regulation (EU) 2022/2065
- Supervision
- Federal Network Agency as DSC
- Result
- Obligations matrix and implementation
Depending on the service, implementation covers points of contact, terms of use, notice and action, complaints, statements of reasons, transparency reports, advertising, recommender systems, marketplace obligations and dealing with the supervisory authority.
You can use the platform liability check in advance to see where your platform stands in terms of liability for notices and illegal content.
Send a short description of your service using the form. We will get back to you within 24 hours on working days.
How it works
How do we implement the DSA with you?
Three steps from classification to robust implementation.
01
Clarify DSA status We classify the service, user roles, EU link, platform function and company size – intermediary service, hosting, online platform, marketplace or very large service.
02
Determine obligations We translate the legal classification into specific measures for terms, reporting channels, complaints, moderation decisions, transparency, advertising, merchant vetting and documentation.
03
Secure implementation We review texts, processes, user journeys, responsibilities and evidence so that the implementation holds up towards users, contractual partners and the supervisory authority.
Our legal approach
- 1
Read the business model We review the product description, user groups, EU link, content functions, merchant integration, moderation, advertising, ranking and existing terms.
- 2
Determine the depth of obligations We separate general intermediary obligations from hosting, platform, marketplace and very large service obligations.
- 3
Build the implementation We develop or review the required texts, processes, interfaces, decision rules and documentation points.
How long does it take? Most work steps are completed within a few working days. How quickly it goes depends on the scope and on your feedback. Do you have a fixed date, such as a launch? Tell us when you send your enquiry and we will plan for it.
Implementation package
Which work results do you receive?
Service package DSA implementation
Scope and role memo Classification of the service, user roles, EU targeting, platform function and the applicable tier of obligations.
Map of obligations Specific obligations by type of service – general obligations, hosting obligations, platform obligations, marketplace obligations and VLOP/VLOSE questions.
Terms and policy set Terms of use, moderation rules, complaint texts, merchant terms, advertising and recommender information.
Process design Notice and action, complaints, escalation, protection against misuse, statements of reasons, responsibilities and decision logs.
Documentation Evidence for transparency reports, user numbers, moderation decisions, statements of reasons and internal control points.
Readiness for disputes and supervision Preparation for complaints, regulatory enquiries, platform conflicts, merchant disputes or court proceedings.
- For whom
- Platforms, hosting services, marketplaces, communities
- First response
- within 24 hours on working days
- Costs
- We tell you the costs transparently before you instruct us.
- Not included
- Ongoing moderation of individual content. On request.
Who delivers what and who decides
- Product description
- User roles and target markets
- Existing terms
- Current notice processes
- Classification and obligations matrix
- Texts and policies
- Process design
- Representation before the supervisory authority on request
- You, on product and implementation
- The supervisory authority, on infringements
- The court, in a dispute
How does instructing us work?
- 1
Initial assessment You send a description of your service using the form. We assess where you stand. Initial contact is free of charge.
- 2
Quote Before work begins, we tell you the scope and costs transparently.
- 3
Court proceedings separately Proceedings before the supervisory authority or a court are agreed separately if you wish.
Typical breaking points
Where does DSA implementation tip over?
Six breaking points we see in DSA projects. These are exactly the points ITMR can classify for you before implementation.
Intermediary service, hosting, online platform, marketplace or search engine are not clearly separated. This leads to too many, too few or wrongly prioritised obligations.
A notice form is of little help if responsibility, review, reasoning, deadlines, logging and feedback are not robustly regulated.
Terms, community guidelines, UI texts, blocking rules, advertising notices and internal playbooks must follow the same legal line.
Anyone who cannot justify removal, blocking, demonetisation, account closure or a refusal to act loses their own basis for decisions in a dispute.
Reporting obligations, user numbers, statements of reasons, advertising, recommender systems and marketplace information must be prepared in good time.
The Digital Services Coordinator and the European Commission expect documented procedures and traceable decisions.
Service categories
Which obligations apply to which service?
DSA implementation starts with the right service category.
| Tier | Service category | Core obligations |
|---|---|---|
| Basic | Intermediary service | Points of contact, clear terms of use, transparency reports and responsibilities form the base. |
| Content | Hosting service | Notice and action, acknowledgement of receipt, review process, decision and statement of reasons become central. |
| Platform | Online platform | Complaint handling, dispute settlement, trusted flaggers, dark pattern review, advertising, recommender systems and protection of minors under Art. 28 DSA are added. |
| Marketplace | Online marketplace | Merchant vetting, trader information, product and service presentation and customer communication must be managed in a traceable way. |
Scope of review
What does ITMR review in DSA implementation?
We review from the business model, not from an abstract catalogue.
- Classification of the service Distinction from mere own-sales, SaaS, media or e-commerce functions.
- Obligations matrix By DSA category, company size, EU link and user role.
- Terms and rules Review and adaptation of terms, community guidelines, merchant terms and moderation rules.
Notice and action Form, receipt, review, decision and statement of reasons.Complaints and blocks Structure for internal complaints, blocks, removals, account restrictions and reinstatement cases.Documentation For transparency reports, user numbers, moderation decisions, statements of reasons and internal control points.
Triggers
When does legal DSA support become particularly relevant?
Six situations in which companies contact us.
A platform or community feature is about to go live.
Users can upload content, reviews, profiles, listings, comments or media.
Merchants, creators, customers or members are to interact via the platform.
There are blocks, removals, complaints, takedowns or moderation decisions.
Advertising, recommender systems or ranking rules influence visibility.
An investor, enterprise customer, association, user or authority asks about DSA compliance.
Typical mistakes
Which mistakes do we see in DSA projects?
The biggest risks arise from missing texts and unclear workflows. Anyone who promises something in the interface but has no matching internal review and reasoning process creates an attack surface.
Hastily "not affected" The service is classified as "not affected" without a review.Functions mixed up Own web shop, marketplace, review function and platform model are not separated.Areas of law mixed up DSA, data protection, media law, e-commerce and competition law are blurred together.Only one paragraph in the terms Implementation stops at a single paragraph in the terms.
Notice channel only in an emergency Notice and action is only built once problematic content has already been reported.Complaint channels are missing Accounts, listings or content are restricted without users being able to complain.Reports not prepared Transparency reports are not prepared on an ongoing basis.Product change without review Changes are published without a follow-up legal DSA review.
Distinctions
When is another ITMR route a better fit?
DSA implementation fits when platform obligations, hosting, user content, moderation, complaints, transparency or marketplace functions are the focus. If the case is broader or different, deliberately switch routes.
For content, account, reputation, publication and platform proceedings with a media law focus.
For digital business models, software, platform architecture, governance, cloud, data and several digital legal regimes.
When the DSA, Data Act, AI Act, DMA, NIS2 or other digital laws must be classified together.
For accounts, creators, platform communication, channels, campaigns, blocks and reach issues.
For online retail, checkout, terms, platform sales, reviews, advertising and merchant obligations.
For SaaS, software, cloud, platform operation, provider contracts, SLAs, outsourcing and digital service relationships.
Legal framework
Which rules and sources apply to the DSA review?
Regulation (EU) 2022/2065 governs the scope, service categories, liability privileges, due diligence obligations and enforcement. Art. 6 DSA governs the liability of hosting services, Art. 16 DSA the notice and action mechanism.
If an online platform is accessible to minors, Art. 28 DSA requires appropriate and proportionate measures for the privacy, safety and protection of minors. Profiling-based advertising aimed at users who are recognisably minors is prohibited. Micro and small enterprises are exempt.
In Germany, the Federal Network Agency is the Digital Services Coordinator. It provides information on supervision, the provider portal, obligations, transparency reports and legal representatives. For very large platforms and search engines, the European Commission enforces the obligations.
- DSA-Verordnung Regulation (EU) 2022/2065 on EUR-Lex.
- Digital Services Coordinator Information from the Federal Network Agency.
- DSA-Durchsetzung Enforcement framework of the European Commission.
Limits
What does the DSA review not cover?
We review classification, texts and processes. Some points remain with you.
- 1
No ongoing moderation The review of individual reported content is agreed separately.
- 2
Supervisory practice is evolving We check guidelines and procedures of the Commission and the DSC as of the date of the review.
- 3
Technology remains with you Your product team handles the technical implementation of forms and logs.
Helpful for the first review
- Product or platform description.
- Existing terms, community guidelines, merchant terms or rules of use.
- Description of user content, uploads, reviews, listings, profiles or comments.
- Current workflow for notices, removal, blocking, complaints and reactivation.
- Information on advertising, recommender systems, ranking, target groups and EU users.
Your contact
Lawyer and mediator · Partner · Specialist lawyer for IT law · Specialist lawyer for copyright and media law
View profile Düsseldorf, Schirmerstraße 80 · Hamburg, Palmaille 124
TOP lawyer 2027 · Business lawyers · Intellectual property
F.A.Z.-Institut and QuantiQuest. Based on recommendations from peers and assessments by in-house counsel. Source (opens in a new tab)
ReviewsWe do not check reviews of us on other platforms that we do not quote verbatim for authenticity. They may therefore also come from people who are not our clients. The rules of the respective platform apply. Reviews that we quote verbatim on our website, by contrast, have been checked for authenticity within the meaning of Section 5b(3) UWG (German Act against Unfair Competition): we compared the reviewers’ names with our client register. We also asked the respective platform to check the reviews for authenticity.
What clients say
5,0 von 5 · 71 Bewertungen auf anwalt.dePeriod: October 2018 to date · As of: 28 October 2026
“Mr Bohne supported me at short notice, very competently and kindly, and thus achieved the result I wanted promptly. Many thanks!” (translated from German)
“Mr Bohne quickly filtered out the essential parts of the material provided and gave me helpful suggestions for an appropriate response. Many thanks for that. …” (translated from German)
“The advice was very competent and professional. I am very happy to recommend Mr Bohne and would come back to him at any time.” (translated from German)
FAQ
What do companies ask about DSA implementation?
Does every digital company fall under the DSA?
No. It depends on whether an intermediary service within the meaning of the DSA is offered and which service category is concerned. A classic own-sales web shop must be assessed differently from hosting, a platform, marketplace, app store, community, review function or search function.
Is it enough to add a DSA paragraph to the terms and conditions?
In most DSA-relevant cases, no. Terms and conditions are important, but they must fit together with reporting channels, moderation rules, complaint procedures, statements of reasons, user information, transparency reports and internal responsibility.
When does a hosting service need a notice and action procedure?
If user information is stored on their behalf, the notice and action procedure becomes the central DSA interface. It must be easily accessible, user-friendly and usable electronically. Internally, it must be set up so that notices can be reviewed and decisions can be justified.
Which companies need to pay particular attention to complaint handling?
Above all, online platforms that decide on content, accounts, listings, visibility, monetary payments or restrictions of use. It is not enough to receive complaints technically. The decision must be prepared in a traceable, careful and not purely automated way.
Is the DSA only relevant for very large platforms?
No. Very large online platforms and search engines have particularly strict additional obligations. Besides these, there are obligations for other intermediary services, hosting services and online platforms, tiered according to the type and size of the service.
When is an EU Digital Acts audit the better choice?
If it is still open whether, besides the DSA, the AI Act, Data Act, DMA, NIS2, data protection, e-commerce or cybersecurity obligations shape the case. Once the DSA focus is clear, direct DSA implementation is in our experience the faster route.
Which documents should you have ready?
Helpful are a product description, target markets, user roles, terms and conditions, moderation rules, notice and complaint processes, merchant terms, advertising and recommender information, and examples of previous blocking, removal or complaint cases.
Do online platforms have to give minors special protection?
Yes, if the platform is accessible to minors. Art. 28 DSA then requires appropriate and proportionate protective measures. What the Commission's guidelines expect and what the proposed EU KIDS Act (COM(2026) 681) would change is explained in our article on the protection of minors.
Next step
Do you want to implement DSA obligations robustly?
If platform functions, user content, merchants, complaints, moderation, advertising or transparency obligations are relevant for your company, the review should not end with abstract applicability. You need an actionable catalogue of obligations with texts, processes, responsibilities and evidence.
Useful for your enquiry
- Short description of the service
- User groups concerned
- Platform or hosting functions
- Existing terms
- Specific reason for the review
You can also submit documents after our first response.
Have your DSA obligations classified now
Have your platform or hosting model reviewed. We name the tier of obligations and the next steps.
Helpful for the enquiry: product description, user roles, terms, moderation process, complaint channels, merchant or content functions.
Related services
IT-Compliance Overview of compliance services.Media law Platform and content proceedings.Social media law Accounts, blocks and reach.E-Commerce Online retail and merchant obligations.IT-Recht SaaS, cloud and provider contracts.EU Digital Acts audit Several digital laws together.Platform liability check Classify liability for notices in advance.Unblock an account Recover a blocked account.
From our blog: Merchant account suspended · Liability of hosting providers under the DSA · Protection of minors under Art. 28 DSA and the KIDS Act