The Digital Services Act: what EU rules ask of adult sites
The EU Digital Services Act has applied to all intermediary services since 17 February 2024. If your site stores content that users upload, the DSA (Art. 16, Art. 17) expects a way for anyone to report illegal content and an explanation of your decisions, whatever your size. Here's what the DSA says about small adult sites and how to check the pages it describes.
Summary of the official sources · checked 14 October 2026 · Not legal advice. · Sources at the end
Applies from17 February 2024
WhoSites that host user uploads for people in the EU
RuleRegulation (EU) 2022/2065
Effort to fixHalf a day for pages and form
Does your site show the DSA contact points and report form? Find out in about a minute.
Free · private · we never download your images or videos
In short
- If you host user content, the DSA expects a notice-and-action route for illegal content (Art. 16) and a statement of reasons when you act on it (Art. 17), regardless of size.
- Every intermediary needs a contact point for authorities (Art. 11) and one for users (Art. 12), plus terms that explain content rules (Art. 14).
- Providers outside the EU must name a legal representative in the EU (Art. 13).
- Micro and small enterprises (under 50 staff and up to €10 million turnover) are exempt from most platform duties in Art. 19–28, unless they are very large platforms.
Does this apply to your site?
The DSA is about services that pass on or store other people’s content. Start with the first question.
- ✓
Users can upload images, videos or comments to your siteThat makes you a hosting service; Art. 16 and 17 apply whatever your size.
- ✓
You show user uploads to the public: tube, cam or fan platformThat makes you an online platform. Section 3 (Art. 19–28) is added, with the small-business exemption.
- ?
You only publish your own contentArticle 3 DSA defines intermediary services; a site that only publishes its own content may fall outside that definition. National laws on minors still do.
- ✓
Your company is outside the EU but EU users can sign upArticle 13 DSA asks for a legal representative in the EU; name it on your site.
What regulators expect
- Add one “DSA contact” page linked in the footer, with an email for authorities and the languages you accept (Art. 11), and a user contact that a person answers (Art. 12).
- Publish a report form for illegal content that asks for the URL, the reason, name and email and a good-faith statement, and sends a confirmation (Art. 16). It can be the same form as your TAKE IT DOWN route.
- Explain each decision to the uploader: what you removed or restricted, why, and how to complain (Art. 17).
- Add a content-rules section to your terms covering what isn’t allowed, how you moderate (human or automated) and how complaints work (Art. 14).
- If you’re outside the EU, appoint a legal representative and name them on the DSA page (Art. 13). Service providers offer this.
Very large platforms have many more duties. On adult sites, the Commission designated Pornhub, XVideos, Stripchat and XNXX; Stripchat was de-designated in May 2025.
What good DSA pages look like
Authorities: dsa@yoursite.comLanguages: English, German
One “DSA contact” page
Linked in the footer: a contact for authorities with languages, and a contact for users answered by a person.
URL of the contentWhy is it illegal?
Report form for illegal content
URL, reason, name and email (optional for child-abuse reports) and a good-faith checkbox.
Removed · terms §4 · Complain
Statement of reasons
The uploader learns what you did, why, and how to complain.
How No451 checks your site
We read your footer, terms and contact pages as an anonymous visitor and look for the DSA contact points, a legal representative where one is needed, the content-rules topics in your terms and a report form with the Art. 16 elements. Whether you send statements of reasons is something you tell us; we can’t see it from outside.
Should fixImages visible before the age check (from a related check) Example resultWe don’t have a stored real DSA result yet, so this is a real finding from our age-check checks: behind an age-check overlay, 6 images were already on the page, 5 blurred and 1 not blurred at all.
The fix: send a page with only the check until the visitor passes. DSA findings look the same: what we saw, the evidence and the fix.
Contact for authoritiesArt. 11: email and languages
Contact for usersArt. 12: reachable by a person
EU representativeArt. 13: if you’re outside the EU
Terms on content rulesArt. 14: moderation and complaints
Notice and actionArt. 16: report form elements
ComplaintsArt. 20: how to object to a decision
Common mistakes
- Only a chatbot as user contact. Art. 12 asks for a contact that isn’t only automated.
- No languages next to the authority email. Art. 11 asks you to say which languages you accept.
- Report form behind a login. Anyone should be able to report illegal content, members or not.
- Assuming small means exempt from everything. The exemption covers Section 3. Notice and action, statements of reasons and the contact points still apply.
- Removing content silently. The uploader should get a statement of reasons that says what you did and why.
Enforcement
Each EU country has a Digital Services Coordinator that supervises providers established there and handles complaints; the Commission supervises very large platforms. On 27 May 2025 the European Commission opened formal proceedings against Pornhub, Stripchat, XNXX and XVideos under the Digital Services Act, including over “the absence of effective age verification measures”; it issued preliminary findings on 26 March 2026 (European Commission press releases). National coordinators run a coordinated action on smaller adult platforms.
Questions operators ask
Does the DSA apply to a small adult site?
If users can upload content, yes: notice and action (Art. 16), statements of reasons (Art. 17), contact points (Art. 11 and 12) and terms (Art. 14) apply whatever your size. The small-business exemption covers most of Art. 19–28.
Do I need an age check under the DSA?
The Commission’s guidelines on protecting minors (Art. 28), adopted in July 2025, recommend age verification for porn and say self-declaration isn’t enough. Art. 28 applies to online platforms, and micro and small ones are exempt unless very large; national laws on minors still apply.
Can one form handle DSA reports and TAKE IT DOWN requests?
Yes, with a “type of report” selector. Make sure each type asks for the fields its law needs.
Do I have to publish transparency reports?
Art. 15 asks intermediaries for transparency reports, but micro and small enterprises are exempt unless they are very large platforms.
What does No451 check for the DSA?
Whether your public pages show the contact points, a legal representative if you need one, content rules in your terms, a complaint route and a report form. Statements of reasons are self-reported.
Sources
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 in Germany · DSA in France · DSA in Italy · TAKE IT DOWN Act
See which DSA pages your site already has. Then add the rest in an afternoon.
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