# Automated Transparency: A Legal and Empirical Analysis of the Digital Services Act Transparency Database

arXiv: https://arxiv.org/abs/2404.02894 · HTML: https://mlsanity.com/paper/2404.02894/

## Key facts

- Cited by 7 papers in the map (data through 14 Oct 2026).
- First posted on arXiv 3 Apr 2024.

## Built on by (most cited first, 7 of 7)

- [Acceptable Use Policies for Foundation Models](https://mlsanity.com/paper/2409.09041/) (2024)
- ["Is This Not Enough?": Asymmetries in Institutional Accountability and Collective Sensemaking in the Case of Canada's Algorithmic Visa Triage System](https://mlsanity.com/paper/2606.13071/) (2026)
- [Can Foundation Models Moderate Online Content? Evaluating Instruction- vs. Example-Driven Policy Operationalization](https://mlsanity.com/paper/2609.10410/) (2026)
- [Bureaucratic Silences: What the Canadian AI Register Reveals, Omits, and Obscures](https://mlsanity.com/paper/2604.15514/) (2026)
- [Visible to the Court: How AI Is (and Isn't) Litigated in U.S. Federal Court Opinions](https://mlsanity.com/paper/2607.23888/) (2026)
- [ChildSafeAds Shared Task 2026: Commercial Content in Child-Facing YouTube Videos](https://mlsanity.com/paper/2608.19165/) (2026)
- [A Global Comparison of Schemas, Transparency, and Interoperability in Public-Sector AI Registers and Inventories](https://mlsanity.com/paper/2609.24883/) (2026)

## Abstract (arXiv)

The Digital Services Act (DSA) is a much awaited platforms liability reform in the European Union that was adopted on 1 November 2022 with the ambition to set a global example in terms of accountability and transparency. Among other obligations, the DSA emphasizes the need for online platforms to report on their content moderation decisions (`statements of reasons' - SoRs), which is a novel transparency mechanism we refer to as automated transparency in this study. SoRs are currently made available in the DSA Transparency Database, launched by the European Commission in September 2023. The DSA Transparency Database marks a historical achievement in platform governance, and allows investigations about the actual transparency gains, both at structure level as well as at the level of platform compliance. This study aims to understand whether the Transparency Database helps the DSA to live up to its transparency promises. We use legal and empirical arguments to show that while there are some transparency gains, compliance remains problematic, as the current database structure allows for a lot of discretion from platforms in terms of transparency practices. In our empirical study, we analyze a representative sample of the Transparency Database (131m SoRs) submitted in November 2023, to characterise and evaluate platform content moderation practices.