Boosting the EU's Digital Services Act: Conflict Sensitivity Requirement for VLOPs

The report by Search for Common Ground is divided into five sections. The first section explains what conflict-sensitivity is and why it is important for the European Commission. The second section examines how three major social media platforms - Facebook, Snapchat and TikTok - have dealt with conflict sensitivity, based on their first risk assessments. The third section shares valuable insights to address systemic risks on Very Large Online Platforms (VLOPs) in Kenya, Sri Lanka, and the Democratic Republic of Congo, which can improve the DSA’s implementation. The fourth section highlights the importance of involving non-EU actors in implementing the DSA, and the fifth section summarizes the report’s key recommendations.

The Digital Services Act (DSA) is a binding European Union (EU) legislation that regulates all hosting services and online platforms that offer services within the Union. The legislation is enforced by relevant authorities in EU member states and the European Commission, with the latter holding a supervisory role over its implementation by all Very Large Online Platforms and Search Engines. It sets the rules for tackling illegal content as well as aims to address various challenges posed by the digital environment, such as harmful online content, misinformation, and the power of dominant online platforms. All online intermediaries in scope should be preparing for full compliance in February 2024. The report examines how a “conflict sensitivity” approach can improve future risk assessments of Very Large Online Platforms (VLOPs) as stipulated in Article 34 of the DSA, which requires platforms to “identify, analyze and assess any systemic risks in the Union stemming from the design or functioning of their service and its related systems, including algorithmic systems, or from the use made of their services.” We highlight lessons learned from the first round of risk assessments of VLOPs and examine digital peacebuilding case studies from Sri Lanka, Kenya, and the Democratic Republic of Congo. This policy report does not propose a new parallel compliance mechanism. Our recommendations are intended to help the European Commission, the Directorate General -Communications Networks, Content and Technology (DG-CNECT), and the newly established DSA enforcement team to play a preventive role in addressing online manifestations of conflicts in the Union before they escalate into offline violence, thereby also setting a standard for the rest of the world. 

This report is realized with the support of the Belgian development cooperation. The opinions expressed by our organization do not necessarily reflect those of the Belgian State and do not bind the latter in any way.