Statements of Reasons (SoRs) in the Digital Services Act (DSA)

Subject: Statements of Reasons (SoRs) in the Digital Services Act (DSA)

Digital platforms are required to submit SoRs, pursuant to Article 17 of the DSA and in conjunction with Article 24 (5) of the DSA, to the DSA Transparency Database. The corresponding application programming interface (API) documentation1 provides, inter alia, the option ‘DECISION_VISIBILITY_CONTENT_LABELLED’ for reporting visibility restrictions.

Does the Commission believe that the application of content labelling triggers the obligation to issue an SoR to the affected recipient of the service and therefore expect platforms to also report these SoRs to the DSA Transparency Database?2

Submitted: 6.5.2025

1 https://transparency.dsa.ec.europa.eu/page/api-documentation.

2 See Müller-Terpitz/Köhler/Barudi, 1st edition 2024, DSA Article 17, marginal no 17.