Prepare for the Digital Services Act with Holistic AI

The EU Commission released the DSA, which consists of composite rules and legal obligations for technology companies – particularly social media and user-oriented online platforms. It also includes clear responsibilities for the EU and member states to enforce these rules and obligations.  Under the new initiative, digital service providers, such as Facebook and Google, must obtain an independent audit from a third-party provider within four months of being designated as a VLOP/VLOSE or by 17 February 2024, whichever is earlier.

Under Article 37 of the DSA, online platform providers need to enhance transparency and public accountability through an annual independent audit. The final report of the audit needs to follow auditing methodologies for algorithmic systems, which include provisions ranging from assessments before deploying new features, disclosure requirements, and comprehensive risk assessments. Algorithmic systems include recommendation engines, content moderation technologies, and other features that may use novel technologies like generative AI models.
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Online platform providers must submit this report to the European Commission and Digital Services Coordinator of its Member State within a month of receipt from the auditor.  

As part of the effort to increase transparency and algorithmic accountabilities, the DSA requires all online platforms to publicly report how they use automated content moderation tools and the tools’ error rates. Furthermore, they must include information regarding the training and assistance provided to their content moderators.

All online platform providers will be required to disclose the number of removal orders issued by national authorities (enforcers) and all notices about the presence of illegal content trusted flaggers (content moderators) or obtain by automated means.