Who Speaks and Who is Heard: Civil Society’s Role in Shaping DSA Decisions

2026-02-17 · Source: Tech Policy Press · Field: Legal & Regulatory — Regulatory Affairs & Government Relations, Compliance & Risk Management, Litigation & Dispute Resolution · Depth: Intermediate, medium

Summary

A report by Mateus Correia de Carvalho and Rachel Griffin, published on February 17, 2026, investigates civil society's role in shaping decisions under Europe's Digital Services Act (DSA), two years after its full effect. The study, part of the DSA Observatory series, examines how diverse civil society actors participate in the DSA's systemic risk management framework, the opportunities and obstacles they encounter, and whether all affected actors are heard. Through a focus group workshop with 14 civil society actors and 21 semi-structured interviews, the research identifies various engagement mechanisms, strategic considerations influencing participation, and structural inequalities leading to unequal influence. It highlights that while formal mechanisms like strategic litigation and lobbying regulators are seen as promising, advocacy directed at platform companies is considered less useful due to perceived disinterest from Big Tech.

Key takeaway

For Policy Makers and Regulators navigating DSA enforcement, you must actively address the identified structural inequalities in civil society participation. Proactively reach out to diverse civil society groups, provide material support for underrepresented actors, and broaden the scope of accepted input beyond current enforcement priorities to ensure more equitable and effective regulatory outcomes. Your efforts should explicitly make inclusive engagement a criterion for evaluating VLOP compliance.

Key insights

Civil society participation in DSA implementation faces structural inequalities despite being deemed essential for accountability and expertise.

Principles

• Participation mechanisms extend beyond formal legal avenues.
• Coalition-building can mitigate individual resource limitations.
• Unequal access to resources and recognition hinders inclusive participation.

Method

A qualitative empirical investigation using a focus group workshop with 14 civil society actors and 21 semi-structured interviews to analyze participation in the DSA's systemic risk management framework.

In practice

• Regulators should proactively engage diverse civil society actors.
• Support underrepresented actors' participation materially.
• Welcome diverse input, including qualitative research.

Topics

• Digital Services Act
• Civil Society Participation
• Platform Regulation
• Systemic Risk Management
• Regulatory Governance

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Editorial summary, takeaway, and curation by AIssential. Original article published by Tech Policy Press.