The EU Digital Services Act is known for its rules on giant platforms. Most of the DSA’s platform duties are aimed at larger platforms. The text lists a handful of duties without a size exemption. Here is the short list, and how to work through it in an afternoon.
The DSA covers intermediary services: services that pass on or store content provided by others. Under its definitions (Art. 3), a service that stores content its users upload, such as images, videos or comments, is a hosting service, and a hosting service that also shows those uploads to the public, as tube, cam and fan platforms do, is an online platform.
The definition of an intermediary service (Art. 3) is about content provided by others; a site that only publishes its own content is not described there. For platforms, Article 19 says micro and small enterprises are exempt from Section 3, which includes Article 28. Check the definition in Article 19 for your company. National laws on minors, such as the JMStV in Germany or Arcom’s rules in France, are separate from the DSA.
Article 19(1) says Section 3, the extra duties for online platforms in Articles 19 to 28, does not apply to micro and small enterprises as defined in Recommendation 2003/361/EC (fewer than 50 staff and up to €10 million turnover or balance sheet), with the exception of Article 24(3). That section includes, for example, the internal complaint system of Article 20 and the minors duty in Article 28. Article 19(2) says the exemption doesn’t cover platforms designated as very large. Article 15(2) also leaves micro and small enterprises that are not very large platforms out of the yearly transparency reports.
One thing to watch: Article 24(3) still applies, so on request a platform gives its Digital Services Coordinator or the Commission its average monthly user numbers in the EU. Article 19(1) also keeps the exemption for 12 months after a company loses its micro or small status. National age-check laws are separate from the DSA and its exemptions.
The Commission’s guidelines on protecting minors under Article 28, published on 14 July 2025 according to the Commission (checked 19 October 2026), recommend age verification for porn and say self-declaration isn’t enough. Article 19 places Article 28 inside the Section 3 exemption for micro and small enterprises, and the Commission says the guidelines don’t apply to them. National laws in the UK, Germany, France and Italy have their own age-check rules; our country pages summarise them.
Each EU country has a Digital Services Coordinator that supervises providers established there and handles complaints: the Bundesnetzagentur in Germany, Arcom in France and AGCOM in Italy, for example. The European Commission supervises very large platforms; its list of designated platforms shows which adult sites are on it. According to the Commission (checked 19 October 2026), on 26 March 2026 it preliminarily found Pornhub, Stripchat, XNXX and XVideos in breach of the DSA on the protection of minors.
Do I count as small if my group is large? The size test in Recommendation 2003/361/EC counts linked and partner enterprises, so a small site in a large group may be measured as part of the group.
Can the user contact point be an email address? Article 12 asks for a way to communicate directly and rapidly that doesn’t rely only on automated tools. An email address that a person answers is one common way; a chatbot alone is not.
Must the report form be in every EU language? Article 16 doesn’t list languages for the form, but a form in the languages of your main audiences gets more usable reports. State which languages you accept.
Where do I publish all this? One page linked from every footer is the simplest. It is easy for users, authorities and our scanner to find.
Even where Article 15(2) leaves you out of transparency reports, keep a short log: which notices arrived, what you decided, when, and the statement of reasons you sent. If a coordinator asks, a plain spreadsheet with those columns is a much better answer than searching old emails.
We read your footer, terms, imprint and contact pages by keyword and look for the contact points, a legal representative where needed, the content-rules topics and a report form with the Article 16 elements. A found page means “a page that looks like this”, not that you meet the DSA. Statements of reasons are something you tell us.
Not legal advice. This page summarises and links to primary sources; it does not tell you what the law requires of your specific site. Related: DSA reporting duties · Guide: DSA contact points and terms · A report page that works
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