Article 91

Review

1. By 17 November 2025, and every five years thereafter, the Commission shall evaluate the application of Article 33 and report on its findings to the European Parliament, the Council and the European Economic and Social Committee. The Commission shall consult the Board and Member States for this purpose.

2. By 18 February 2027, the Commission shall evaluate and report on the potential effect of this Regulation on the development and economic growth of small and medium-sized enterprises and on the economic functioning of the Board and report to the European Parliament, the Council and the European Economic and Social Committee.

3. By 17 November 2027, and every 5 years thereafter, the Commission shall evaluate this Regulation and report on the main findings to the European Parliament, the Council and the European Economic and Social Committee. The reports shall, in particular, include an evaluation of: (a) the functioning of the internal market for intermediary services and the evolution of illegal content, disinformation and other societal risks online, including for minors; (b) the effective enforcement of this Regulation; (c) the application of Articles 13, 16, 20, 21, 45 and 46. The Commission shall request the Board to provide an assessment of the application of Articles 45 and 46.

4. The Commission shall pay specific attention in the reports referred to in paragraphs 2 and 3 to the position of small and medium-sized enterprises and the position of new competitors in the market with a view to ensuring, in particular, a diverse and competitive ecosystem of providers of intermediary services.

5. For the purposes of paragraphs 1, 2 and 3, Member States, the Board and the Digital Services Coordinators shall provide the Commission with information upon its request and without undue delay, and the Digital Services Coordinators shall have the power to require intermediary service providers that are under their jurisdiction to provide the information necessary. The Commission shall take into account the annual reports submitted by the Digital Services Coordinators pursuant to Article 55(1).

6. The Commission may request the Board to provide the Commission with a specific opinion on its findings, where appropriate.

7. On the basis of the findings pursuant to paragraphs 1, 2 and 3, the Commission may submit proposals to amend this Regulation, as appropriate.

Understanding This Article

Article 91 establishes comprehensive multi-tiered review framework ensuring DSA remains effective, proportionate, and adapted to technological evolution, market developments, and enforcement experiences through periodic evidence-based evaluations. Three distinct review timelines address different assessment needs: (1) Article 33 Designation Review (November 2025, every 5 years) - Evaluates VLOP/VLOSE designation criteria application examining whether 45 million monthly active user threshold appropriately identifies systemically important platforms, designation procedures function effectively, designated platforms actually exhibit systemic importance warranting enhanced obligations, any platforms systematically important but below threshold require designation criteria adjustment. Reviews designation methodology, market concentration dynamics, new platform emergence. (2) SME and Board Assessment (February 2027) - Evaluates DSA impact on small and medium-sized enterprises examining whether compliance obligations disproportionately burden smaller platforms, SMEs can compete effectively with large platforms given regulatory requirements, regulatory costs create market entry barriers disadvantaging startups, any modifications needed to graduated compliance requirements under Article 19. Assesses Board economic functioning examining resource adequacy, operational efficiency, cross-border cooperation effectiveness. (3) Comprehensive DSA Review (November 2027, every 5 years) - Holistic evaluation of entire Regulation covering internal market functioning (whether DSA facilitates EU-wide intermediary services market, fragmentation issues, cross-border service provision), illegal content and disinformation evolution (whether online harms addressed effectively, new risks emerged requiring regulatory response, Articles 13-46 adequate), enforcement effectiveness (Commission, DSC, Board enforcement actions sufficiency, procedural adequacy, penalties deterrent effect), specific provisions assessment (Articles 13, 16, 20, 21, 45, 46 application). Special SME attention ensures reviews examine regulatory proportionality preventing innovation barriers. Amendment authority enables Commission to propose legislative changes addressing identified deficiencies, adapting to technological change, responding to enforcement experience.

Key Points

  • November 17, 2025: Commission evaluates Article 33 designation criteria application, repeats every 5 years
  • February 18, 2027: Commission evaluates SME impact and Board economic functioning
  • November 17, 2027: First comprehensive DSA review, repeats every 5 years (2032, 2037, etc.)
  • Comprehensive review examines: (a) internal market functioning and illegal content/disinformation evolution, (b) enforcement effectiveness, (c) specific Articles 13, 16, 20, 21, 45, 46 application
  • Commission must consult European Board for Digital Services and Member States for all reviews
  • Special attention to SME position and new market competitors ensuring diverse competitive ecosystem
  • Board provides assessment of Articles 45-46 (codes of conduct, crisis protocols) application
  • Commission uses DSC annual reports per Article 55(1) as information source
  • Member States, Board, and DSCs must provide information upon Commission request without undue delay
  • DSCs empowered to require intermediaries provide information necessary for review evaluations
  • Commission may request Board provide specific opinions on findings
  • Commission may submit amendment proposals to Parliament and Council based on review findings
  • Reviews ensure DSA adaptation to technological evolution, market developments, enforcement experiences
  • Regular evaluation creates accountability and evidence-based regulatory refinement
  • First formal Commission report published November 19, 2025 (interim assessment)

Practical Application

2027 Comprehensive Review Process and Findings: Commission initiates comprehensive review November 2026 preparing for November 2027 deadline. Information gathering phase: Requests Digital Services Coordinators provide enforcement statistics (investigations conducted, decisions issued, penalties imposed, cross-border cooperation cases), platform compliance data (transparency report analysis, Article 35 risk assessments quality, Article 40 researcher access uptake), user complaints trends, SME compliance cost surveys. Board submits assessment of Articles 45-46 application documenting: 12 codes of conduct adopted under Article 45 covering advertising transparency, content moderation, recommender systems, minor protection; effectiveness varies - advertising codes highly effective improving transparency, moderation codes implementation inconsistent, recommender codes limited adoption by smaller platforms; Article 46 crisis response protocols activated twice (disinformation campaigns during elections, public health emergencies), demonstrated value enabling rapid coordinated responses but improvement needed in cross-border activation procedures. Commission analysis identifies findings: (1) Article 35 Risk Mitigation - Effective for largest platforms with sophisticated compliance systems but smaller VLOPs struggling with technical implementation complexity; risk assessment methodologies vary widely affecting comparability; Commission guidance documents helped but more standardized frameworks needed. (2) Article 40 Researcher Access - Broadly successful enabling 200+ research projects across EU, but data standardization issues limiting research quality; platforms interpret access scope inconsistently; confidentiality review processes causing delays; improvements needed in data format specifications, clearer access scope definitions, streamlined confidentiality protocols. (3) Article 16 Notice-and-Action - Functions well with 15 million notices processed annually, but response time variations across platforms (ranges 2 hours to 14 days); user understanding of notice requirements uneven; improvements needed through maximum response time requirements, standardized notice templates, enhanced user guidance. (4) Cross-Border Cooperation - Effective with 89 joint investigations completed, but DSC resource constraints limiting capacity in some Member States; AGORA system functioning well; improvements needed through dedicated DSC funding mechanisms, enhanced Commission coordination support. (5) SME Impact - Compliance costs disproportionately affect smaller platforms; graduated requirements under Article 19 help but threshold calibration issues; some SMEs report market exit considerations due to regulatory burden; improvements needed through refined graduated requirements, longer implementation timelines for SMEs, technical assistance programs.