Paris, October 3, 2025
Open Terms Archive now tracks all DSA systemic risk assessment Reports across all very large online platforms and search engines (VLOPSEs), creating a dedicated dataset ensuring the long-term availability and traceability of these documents.
Leveraging its open-source software, originally designed to monitor changes to online services’ contractual documents, Open Terms Archive collaborated with CheckFirst to create a new collection that automatically archives and tracks Systemic Risk Assessment Reports published in compliance with the EU Digital Services Act (DSA).
Under articles 34 and 35 of the DSA, VLOPSEs must publish systemic risk assessment reports at least once per year. These reports identify and analyze risks stemming from their services and describe the measures taken to mitigate them.
This reporting obligation represents the first time VLOPSEs have publicly assessed systemic risks in their systems. While the first round of reports set a precedent for a more informed public conversation about online risks and for platforms adopting proactive risk-management practices, report content and publishing practices have been criticized by civil society organisations and academic researchers.
Early versions of the reports have raised concerns about transparency and accessibility, including unclear publication timelines, inconsistent formats, and a lack of version history. Because the reports are hosted directly by the platforms, accessing them can be difficult. For instance, reports hosted by pornographic large online platforms are often blocked by workplace security filters, preventing access by researchers or regulators. While the DSA requires platforms to preserve these reports for at least three years after the assessments, there is currently no mechanism to verify modifications made to published reports, and previous versions are not publicly available. The European Commission DSA transparency page lists reports only as links to the platforms’ web pages.
While the DSA does not currently require Systemic Risk Assessment Reports to be machine-readable or mandate notification of modifications to previously published versions, it already imposes these standards on other types of reports, such as transparency reports and could, in the future, extend them to additional categories.
In line with Open Terms Archive’s first design principle, “never trust the platforms”, and its ongoing mission to strengthen transparency and research in online platform governance, this dataset was created to:
- Archive all published systemic risk assessment reports, giving researchers and regulators access to all of their versions over the long term.
- Track modifications over time to enable verification of report updates.
- Ensure version traceability and document authenticity.
- Identify which platforms have published these required reports, and therefore which ones are not in compliance.
This project was developed collaboratively by the Open Terms Archive and CheckFirst teams during the Hack the DSA hackathon hosted by the CNAM’s Chaire sur la modération des contenus on October 3, 2025 and was awarded second prize by a jury of experts.
This dataset currently covers systemic risk assessment reports but could be expanded to include other reports mandated by the DSA, such as transparency (article 42) or audit reports (article 37). We are looking for partners to expand coverage, reach out to contact@opentermsarchive.org if interested to collaborate on this expansion!