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: €1,000,000 or 6% of global annual turnover (for individual infringements); up to 1% for providing incorrect information
Complete each item below to achieve compliance. Use ComplianceIQ 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.
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.
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.
Implementation Steps
4. Identify if you operate as a Very Large Online Platform (VLOP) — >45M EU users
5. For recommender systems: publish an explanation of each algorithm used
6. Offer users at least one recommendation option NOT based on profiling
7. Conduct annual risk assessments for algorithmic amplification risks
8. Conduct independent audits (if VLOP) — submit to European Commission
9. Establish a complaints mechanism for algorithmic decisions
10. Publish a transparency report on content moderation and recommender systems