An empirical critique of the DSA Transparency Database: mapping shortcomings and levers for improvement

The EU Digital Services Act (DSA) leans heavily on transparency obligations in pursuit of a ‘safe, predictable and trusted online environment’ (Article 1(1)). The present paper critically assesses the product of one DSA transparency obligation in particular: the ‘DSA Transparency Database’ (TDB), to which online platforms must submit an explanation for most content moderation decisions they take. As Recital 66 elucidates, its multifaceted objective entails ensuring transparency and enabling scrutiny over platforms’ content moderation decisions and tracking the spread of illegal content online. Through empirical inquiry into eight leading platforms’ submissions to the TDB, this paper maps the flaws that impede the TDB’s effectiveness, stemming from both database architecture and the underlying normative framework. By extension, this paper explores whether Implementing Regulation 2024/2835, adopted to standardise transparency reporting under the DSA, improves the TDB’s informativeness. The analysis concludes by stressing the importance of granularity in deriving meaningful insights from data.