unphish
unphish unphish

European Union – Digital Services Act 2022/2065

Understanding obligations under the EU Digital Services Act and how organisations can demonstrate consistent, auditable handling of illegal content and platform risk.

A New Standard for Platform Accountability in the EU

The Digital Services Act represents a significant shift in how online platforms are expected to manage illegal content, platform risk, and user protection across the European Union.

Unlike fragmented national approaches, the DSA establishes a single regulatory framework that applies consistently across intermediary services. It introduces clear operational expectations for how platforms detect, assess, and act on illegal activity—while ensuring transparency and accountability in decision making. For organisations operating in or serving the EU, this is not just a compliance update. It is a structural change in how risk, trust, and platform responsibility are managed at scale.
Enforcement Framework

Key Regulatory Shifts Under the Digital Services Act

The Digital Services Act introduces structured, enforceable obligations that redefine how platforms manage illegal content, platform risk, and accountability across the EU.

Notice & Action Obligations

Structured mechanisms requiring illegal content to be reported and processed in a timely, diligent, non-arbitrary manner, with safeguards for parties.

Trusted Flagger Prioritisation

Recognition of verified entities whose high-quality notices must be prioritised, improving signal accuracy and enforcement efficiency.

Marketplace Accountability

Enhanced trader traceability requirements to reduce fraud and ensure greater accountability for entities selling through digital platforms.

Transparency & Reporting

Clear expectations for documenting and reporting moderation decisions, enforcement actions, and platform risk handling.

Systemic Risk Management

Mandatory risk assessments and mitigation measures for large platforms to address coordinated abuse, illegal content, and platform manipulation.

Scalable Governance Framework

A unified EU-wide regulatory model enabling consistent, auditable, and enforceable platform governance across member states.

Framework Principles

What This Means for Organisations

The DSA introduces a shift from reactive moderation to structured, evidence-based enforcement at scale.

Organisations must now demonstrate:
  • Consistent handling of illegal content aligned to defined processes
  • Clear audit trails supporting moderation and enforcement decisions
  • The ability to prioritise high-risk signals and trusted sources
  • Ongoing visibility into systemic risks and coordinated threat activity
  • Transparent reporting aligned to regulatory expectations

This requires not only policy alignment, but operational capability across detection, investigation, enforcement, and reporting.

Operational Enforcement

Core Operational Obligations Under the DSA

The DSA moves beyond high-level principles by defining how organisations must operationalise enforcement.
Notice and Action Workflows

Operational pipelines for intake, triage, validation, and enforcement of illegal content reports, with defined SLAs and escalation paths.

Trusted Signal Handling

Systems to ingest, verify, and prioritise high-confidence reports (including trusted flaggers) while filtering noise at scale.

Trader Verification Operations

Ongoing processes to collect, validate, and maintain trader data, supporting fraud prevention and marketplace integrity.

Enforcement Decisioning & Audit Trails

Standardised decision frameworks with full auditability, ensuring consistency, defensibility, and readiness for review or appeal.

Risk Monitoring & Intelligence

Very Large Online Platforms and Search Engines are required to assess and mitigate systemic risks annually, including the spread of illegal content, manipulation, and coordinated abuse.

Reporting & Regulatory Readiness

Automated reporting workflows that generate structured outputs aligned with DSA transparency and oversight expectations.

Capability

How unphish Aligns with the DSA

unphish helps organisations operationalise DSA requirements by turning detection and enforcement into a repeatable, evidence based process that supports both speed and accountability.

Scalable Notice & Action Workflows

Identify, validate, and act on illegal scam and impersonation content in line with DSA notice-and-action expectations.

Evidence-Led Enforcement

Capture, structure, and retain evidence to support consistent, defensible decisions and appeals handling.

Trusted Signal Prioritisation

Differentiate high-confidence reports, including trusted flagger inputs, to enable faster and more accurate enforcement.

Systemic Risk Intelligence

Detect patterns across campaigns, map repeat offenders, and surface coordinated activity to support a systemic risk approach.

Transparency & Reporting

Generate clear, auditable reporting aligned with DSA transparency requirements, including enforcement outcomes and threat trends.

Be DSA Compliant

Operationalise Digital Services Act Compliance with Confidence

Align your organisation with DSA requirements through structured detection, enforcement, and reporting workflows. unphish enables consistent, auditable handling of illegal content and platform risk at scale.
Request a Consultation

Create your account