Turning the DSA into a Verification Tool: A Feasible Solution to the Reliability Problem

Abstract

Content-moderation transparency suffers from a fundamental reliability problem: platforms disclose information about their practices, but the accuracy of those disclosures is difficult to verify. The Digital Services Act (DSA) introduced a Database of Statements of Reasons that has collected billions of decision-level records since February 2024, and, since July 2025, the Implementing Regulation has harmonised transparency-reporting templates and aligned categorisation across instruments. This article assesses whether those reforms convert the Database from an observation tool into a verification tool. The article argues that while the reforms deliver semantic alignment and comparability, they leave the legal relationship between aggregate reports (Articles 15, 24) and decision-level data (Article 17) undefined. A narrowly tailored duty of traceability – linking reported aggregates to the corresponding statements of reasons – would enable systematic consistency checks without expanding the scope of reporting. Absent this clarification, transparency will remain descriptive rather than verifiable, particularly for intermediaries outside the audit regime.