How can the Digital Services Act (DSA) effectively contribute to making major online services more transparent and accountable? This is the question at the heart of the article “Research Opportunities and Challenges of the EU’s Digital Services Act,” whose first author is Francesco Pierri, assistant professor at the Department of Electronics, Information and Bioengineering - Politecnico di Milano, together with an international group of scholars.
Published in the Communications of the ACM, the article draws on the authors’ direct experience in discussions surrounding the implementation of Article 40 of the DSA. Among other initiatives, this network of researchers took part in an 18-month European Research Council (ERC)-supported pilot programme bringing together researchers, the European Commission’s Directorate-General for Communications Networks, Content and Technology (DG CONNECT), and national Digital Services Coordinators, as well as a roundtable discussion with major platforms and the European Commission.
Article 40 provides a new framework enabling vetted researchers to access both public and non-public data from Very Large Online Platforms and Very Large Online Search Engines (VLOPs and VLOSEs). This is an important step towards enabling independent research into systemic risks associated with digital services, from electoral interference and disinformation to algorithmic bias, privacy and public-health implications.
Drawing on their experience in this process, the authors identify several challenges that could hinder the effective implementation of the DSA, including misaligned incentives between research and industry, asymmetries in access to data and resources, and legal and organisational complexities in data-access procedures.
The article therefore puts forward several practical measures: streamlining and standardising data-access procedures, providing stronger support for independent research, and strengthening coordination within the research community by sharing experience, best practices and successful approaches.
The authors also draw attention to Large Language Models (LLMs) and their increasing integration into search engines and social media platforms, arguing that emerging regulatory blind spots need to be addressed rapidly. This issue has become even more timely following the European Commission’s decision of 31 August 2026 to designate ChatGPT as a Very Large Online Search Engine (VLOSE) under the DSA. The designation, following the service’s declaration that it exceeds the threshold of 45 million average monthly users in the EU, brings ChatGPT within the additional obligations that the DSA places on very large services.
The article concludes by urging the European Commission to ensure rigorous oversight of the DSA’s implementation and calling on the research community to coordinate around the new data-access procedures, reinforcing the role of independent research in promoting transparency and accountability across Europe’s digital ecosystem.