Helping (non-)users of the digital services in the Digital Services Act

Digital services are becoming increasingly central to EU member states’ economies and administrative functions. The Digital Services Act (DSA) came into effect in early 2024 and aims to hold extensive online platforms accountable for the content they post and share with millions of residents and citizens within the EU. The key recommendations do not yet officially cover smaller providers. This means that providers operating primarily in more minor language communities are exempt from the provisions of the DSA, though they are recommended to follow the guidelines.

This has consequences not only for people as consumers of services but also for people as citizens. Many terms are used in the DSA to describe people, including recipient, consumer, person, child, citizen and user. What is striking about this list is the emphasis on people as individuals and their relationships to private business. Except for citizens and persons, people using digital services as patients, passengers, and audiences are absent. These collective interests and public values must also be considered.

The interests of non-users of digital services should also be taken into account. People might not use online platforms for various reasons, including physical, cognitive and socioeconomic limits. Non-use might happen because of the fear of harm, especially for women who are subject to misogynistic abuse. Policy-makers need to take seriously their needs and protections.

The DSA is a long, complex document. The EU should provide summaries of its policy documents that are readable by large population segments. This is also important for ensuring democratic accountability and engagement.