EU Digital Services Act (DSA) — AI Transparency Obligations Compliance Checklist 2026
The EU Digital Services Act (Regulation 2022/2065) has been in force for all online platforms since February 17, 2024. For businesses operating online platforms that serve EU users, Article 27 require…
Maximum penalty: 6% of global annual turnover (individual infringements); 1% for providing incorrect information to European Commission; periodic penalty payments up to 5% of average daily turnover
Complete each item below to achieve compliance. Use Aegis Firma to generate all required documentation automatically.
Regulatory Requirements
1. Recommender System Transparency (Article 27)
If your online platform uses recommender systems (algorithms that rank, prioritize, or personalize content for EU users), you must provide at least one option that is not based on profiling, and clearly disclose the main parameters used in recommendations. Post this information in an easily accessible, plain-language notice on your platform.
Due: February 17, 2024
2. No Profiling-Based Advertising for Minors (Article 38)
Do not present targeted advertising based on profiling to users you know are under 18 years old. If your platform is accessed by minors, implement age verification or profiling-free advertising for all users who might be minors.
Due: February 17, 2024
3. AI Advertising Transparency (Article 26)
For each AI-targeted advertisement shown to EU users: identify it clearly as an advertisement, identify who paid for it, and (for targeted ads) explain the main reasons the specific user was targeted. This applies to all online advertising including AI-optimized ad delivery.
Due: February 17, 2024
4. Systemic Risk Assessment (VLOPs Only — 45M+ EU Users)
Very Large Online Platforms must conduct annual systemic risk assessments of their AI recommendation, moderation, and advertising systems. Assessments must cover: dissemination of illegal content, fundamental rights risks, electoral integrity risks, and public health/safety risks from algorithmic amplification. Results submitted to European Commission.
Due: February 17, 2025
Implementation Steps
5. Identify if you operate as a Very Large Online Platform (VLOP) — >45M EU users
6. For recommender systems: publish an explanation of each algorithm used
7. Offer users at least one recommendation option NOT based on profiling
8. Conduct annual risk assessments for algorithmic amplification risks
9. Conduct independent audits (if VLOP) — submit to European Commission
10. Establish a complaints mechanism for algorithmic decisions
11. Publish a transparency report on content moderation and recommender systems