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Initial analysis on the first round of Risk Assessment Reports under the DSA

In this brief, 5Rights – as part of the DSA Civil Society Coordination Group and in cooperation with the Recommender Systems Taskforce and People vs Big Tech – provides an initial, high-level analysis of the first round of Risk Assessment Reports (RA Reports), published under Art. 42 of the Digital Services Act (DSA).

The purpose of this initial feedback is to identify key trends, useful practices and gaps in this first iteration, so that future iterations of these reports advance the public interest, particularly at a time of diminishing trust amongst users related to the risks that VLOPs and VLOSEs create at the personal and societal level. Companies seeking to demonstrate effective compliance with the DSA and to foster trust with their users should take this feedback into consideration.

This brief will focus on four key aspects: useful practices from the RA Reports; the importance of focusing on platform design when assessing risk; why trust can only be fostered through transparency; and the need for meaningful stakeholder engagement. Due to the prevalence of their services in the EU, as some of the largest of the 25 very large online platforms and search engines, the focus is on the RA Reports of the following companies: Google (Search and YouTube); Meta (Facebook and Instagram); TikTok and X.