Platform governance alert — DSA 2025 systemic risk assessment cycle

Executive briefing: Very large online platforms (VLOPs) and search engines (VLOSEs) designated under the EU Digital Services Act must complete their yearly systemic risk assessments by 25 August 2025. Article 34 of Regulation (EU) 2022/2065 mandates that platforms analyse the dissemination of illegal content, negative effects on fundamental rights, civic discourse, public health, and gender-based violence. The 2025 cycle is the first full-year iteration after the Commission’s initial mitigation orders, so marketplaces, social platforms, and app stores need evidence-driven methodologies, sign-offs from compliance officers, and audit-ready records before the August cutoff.

Key compliance signals

Scope confirmation. The Commission’s April 2023 designation decisions remain in force, covering services with over 45 million EU users; no off-ramps exist without a revised designation.
Cross-team inputs. Article 34(2) requires platforms to assess the effectiveness of mitigation measures from Article 35—content moderation tooling, recommender transparency, and advertising controls—demanding inputs from engineering, security, policy, and product.
Board accountability. Senior management must approve the assessment and ensure resources for risk mitigation, creating governance artefacts similar to SOX 404 or SEC cyber attestations.

Mitigation work programme

Refresh threat modelling for generative-AI misuse, election interference, and underage user protection, documenting indicators and playbooks aligned to Article 35 obligations.
Validate recommender system guardrails (Article 38) and ad repository completeness (Article 39) to demonstrate proportionality of mitigation controls.
Integrate risk findings into quarterly supervisory dialogue with the Commission, anticipating requests under Article 67 for detailed documentation.

Enablement moves

Establish cross-functional DSA programme management offices coordinating product, legal, and policy teams to deliver the 2025 assessment package.
Leverage structured data catalogues to map systemic risk indicators to platform telemetry, enabling reproducible analytics and external audit support.
Simulate emergency protocol drills for rapid response to Commission interim measures, ensuring service restoration and legal compliance.

Sources

Zeph Tech guides VLOPs through DSA systemic risk analysis—building defensible methodologies, aligning mitigation budgets, and supporting Commission supervisory dialogues.