Understanding the Digital Services Act: Obligations for Marketplaces and Aggregators in the EU
Digital Services Act (DSA) sounds like just another thick European regulation designed to be read by robots and lawyers. In reality, it’s a sweeping legal framework that’s poised to change how digital platforms operate across the European Union.
If your platform helps people find secondhand jeans, antique swords, freelance designers, or dog yoga instructors—congrats, you may be regulated under the EU's new Digital Services Act (DSA). Here’s what that means, in human language.
/wp:paragraph wp:headingWelcome to the DSA Era
/wp:heading wp:paragraphOn paper, the Digital Services Act (DSA) sounds like just another thick European regulation designed to be read by robots and lawyers. In reality, it’s a sweeping legal framework that’s poised to change how digital platforms—especially marketplaces and aggregators—operate across the European Union.
/wp:paragraph wp:paragraphComing into full force in 2024, the DSA is the EU’s attempt to tame the Wild West of the internet. And while it covers everything from illegal memes to algorithmic transparency, for marketplaces and aggregators, it’s a legal earthquake.
/wp:paragraph wp:headingWhat Exactly Is the DSA?
/wp:heading wp:paragraphThe DSA is part of a regulatory duo with the Digital Markets Act (DMA). Its goal is to create a safer, more transparent internet. The EU is essentially telling platforms: “If you’re going to run a digital town square, keep it clean and follow the rules.”
/wp:paragraph wp:paragraphMain goals:
/wp:paragraph wp:list- Tackle illegal content and dangerous products
- Ensure transparency in advertising and recommendations
- Assign accountability
- Harmonize rules across the EU
Who’s Affected?
/wp:heading wp:paragraphThe DSA applies to all intermediary services operating in the EU—from hosting to online platforms. Two categories under special scrutiny:
1. Online marketplaces (Amazon, Etsy, Vinted, etc.)
2. Aggregators (price comparison sites, service platforms, booking engines)
Obligations: From Light Touch to Heavy Lifting
/wp:heading wp:paragraphBasic obligations (for everyone):
- Appoint an EU representative
- Provide contact information
- Ban illegal content in terms of service
- Cooperate with authorities
Hosting services:
- Implement notice-and-action systems
- Notify users about content takedowns
- Publish moderation reports every six months
Online platforms:
- Explain recommendation systems
- Allow users to turn off personalization
- Clearly label ads
- Disclose the actual seller behind listings
Extra Requirements for Marketplaces
/wp:heading wp:list- Know Your Business Customer (KYBC)
- Collect trader name, address, ID, bank details
- Quickly remove unsafe products
- Notify affected customers
Example: If someone sold explosive chargers, you’re expected to track down buyers and alert them.
/wp:paragraph wp:headingVery Large Online Platforms (VLOPs)
/wp:heading wp:paragraphPlatforms with 45M+ EU users are considered VLOPs and must:
/wp:paragraph wp:list- Assess systemic risks
- Undergo annual audits
- Increase algorithm transparency
- Appoint DSA compliance officers
What If I Ignore It?
/wp:heading wp:paragraphFines can reach up to 6% of global turnover. That’s not a slap on the wrist—it’s a strategic risk.
Other measures include temporary bans, forced changes, and public naming-and-shaming.
What Should Marketplaces and Aggregators Do Now?
/wp:heading wp:list- Map your role: hosting, platform, VLOP?
- Implement KYBC for onboarding
- Update terms of service
- Set up moderation and appeals systems
- Document recommendation algorithms
Common Misconceptions
/wp:heading wp:paragraphMisconception: "We’re outside the EU—it doesn’t apply."
Reality:Â If you serve EU users, it applies.
Misconception: "We don’t sell—just aggregate."
Reality:Â You still influence purchasing decisions.
Misconception:Â "Only giants are affected."
Reality:Â Most rules apply broadly.
Conclusion: The Price of Digital Admission
/wp:heading wp:paragraphThe DSA isn’t here to stifle innovation—it’s here to ensure accountability. For marketplaces and aggregators, it’s a challenge and an opportunity.
/wp:paragraph wp:paragraphThe internet has grown up. The EU wants it to dress like an adult. Maybe not wear a tie, but at least tuck in its shirt.
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