Digital Services Act

Avaaz Position Paper on the Digital Services Act, Disinformation and Freedom of Speech The Digital Services Act (DSA) is Europe’s historic opportunity to address key issues endangering democracies at a global and unprecedented scale.

COMMENTS OF THE EUROPE TECHNOLOGY POLICY COMMITTEE OF THE ASSOCIATION FOR COMPUTING MACHINERY* ON “THE DIGITAL SERVICES ACT – DEEPENING THE INTERNAL MARKET AND CLARIFYING RESPONSIBILITIES FOR DIGITAL SERVICES” The Association for Computing Machinery (ACM) is the world’s largest and longest established professional society of individuals involved in all aspects of computing. It annually bestows the ACM A.M.

LOS response to the EU consultation on the proposal for a Regulation on a single market for digital services (DSA) Lo has chosen to respond to the Commission’s open consultation on the proposal for a Regulation on a single market for digital services (DSA) and wishes to make the following comments. Maintaining fair competition is essential for the functioning of the internal market, including the digital market.

Filed in Swedish · English published by the European Commission

Confusion caused with regard to the position of DNS service providers SIDN is the foundation that manages the .nl domain and in the terms of the DSA-proposal (recital 27) a top-level domain name registry in which capacity it provides domain name system (DNS) services (same recital).

VIER PFOTEN / FOUR PAWS is an animal welfare organisation very active in the fight against illegal online sales of animals. In this regards FOUR PAWS welcomes the possibility to provide feedback on the Digital Services Act. Please find attached a more detailed feedback in the attachment.

Microsoft welcomes the publication by the European Commission of the Digital Services Act (DSA). Like the Commission, we believe that providers of digital services have a responsibility to design and operate their services in ways that help protect user safety online. The DSA provides a unique and timely opportunity for policymakers to promote a safe online ecosystem fit for Europe and aligned with European values.

The Association of European Radios (AER) is the Europe-wide trade body for commercial radio, representing the interests of companies operating over 5,000 commercial radio stations to the EU Institutions. AER promotes the development of commercially-funded radio broadcasting in Europe, by ensuring a fair and sustainable economic framework for radio so it can continue to thrive.

31 March, 2021 Digital Services Act – deepening the internal market and clarifying responsibilities for digital services Lie Detectors response to public consultations Lie Detectors, an award-winning journalist-led media literacy campaign in Europe, welcomes the ability to respond to the Commission consultation on the Digital Services Act.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EGDF and ISFE welcome the opportunity to comment on the Commission’s draft Digital Services Act (DSA). ISFE represents the video games industry in Europe and its membership comprises national trade associations in 15 countries which in turn represent thousands of video games developers and publishers at national level, ranging from small-to-medium sized enterprises (SMEs) to large global companies.

Women in AI Austria welcomes the opportunity to comment on the proposed Digital Services Act. We commend the work of the European Commission in developing such a comprehensive framework for digital services and believe it will be indispensable for the development of these services and markets in a way that respects, upholds and elevates European users and businesses.

Call for feedback - Digital Services Act proposal Comments from Verizon Media EMEA March 2021 1. 2. 3. Introduction 1.1. Verizon Media appreciates the opportunity to respond to this call for feedback. 1.2. The Digital Services Act (DSA) proposal would introduce significant new regulation for certain firms operating in the EU single market. 1.3.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Attached please find ICANN org's feedback on the Proposal for a Regulation of the European Parliament and of the Council on a Single Market for Digital Services (Digital Services Act) and Amending Directive 2000/31/EC (COM/2020/825 final; 2020/0361 (COD)).

The Digital Services Act, public health and prevention of alcohol-related harm The digital era brings with itself both opportunities but also new challenges to the EU and its Member States. Therefore IOGT-NTO welcome the new Digital Services Act (DSA) and hope that it will set a new legislative standard for the digital landscape.

Digital Services Act – Comments to the EC Proposal 1. Introduction Mediaset welcomes the proposed Regulation on the Digital Services Act (DSA). Since the early 2000s, new categories of services have emerged online: adapting the regulatory framework has therefore become an imperative to ensure a safe and thriving European digital landscape.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Centre for Democracy & Technology Europe (CDTE) welcomes the draft proposal on the Digital Services Act (the Draft) and the opportunity to provide feedback. The proposal includes a number of key elements of rights-protecting online content regulation: the 'Good Samaritan' principle, which provides intermediaries with liability protections for voluntarily taking action against abusive user-generated content, and…

i2Coalition Response to DSA Consultation The Internet Infrastructure Coalition (i2Coalition) appreciates the opportunity to provide feedback to the Digital Services Act proposal. Founded in 2012 by a diverse group of Internet infrastructure companies, the i2Coalition is a global organization that supports and represents the companies that build and maintain the infrastructure of the Internet.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

I.- Overall assessment of the proposal for a regulation. The Coalition makes a very positive assessment of the Proposal for a Regulation which is subject to a hearing and which will generally contribute to greater certainty and transparency in the operation of digital services and, in particular, to strengthening the protection of intellectual property rights.

Filed in Spanish · English published by the European Commission

beIN SPORTS’ views on the European Commission Proposal for a Digital Services Act beIN SPORTS welcomes the Digital services act (DSA) proposal to provide all EU citizens with a safer online environment but considers that the Commission’s proposal needs further improvements to translate into concrete, robust and adequate solutions the declaration “what is illegal offline is illegal online”.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Leaseurope feedback to the Digital Services Act Leaseurope is the European Federation representing the leasing and automotive rental industries. Its members are at the forefront of developing on-demand mobility services as well as providing services via platforms, some meeting the new “very large platform” definition.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

How the Digital Services Act (DSA) Can Tackle Disinformation March 2021 Executive Summary The Digital Services Act (DSA) proposal is a step forward in the EU’s approach to creating a safer online space. The harmonisation of regulatory oversight and the introduction of due diligence obligations for online platforms will create a stronger incentive structure for companies to tackle illegal and harmful content.

This submission is made by the European Specialist Sports Nutrition Alliance (ESSNA), the trade association representing the voice of the sports and active nutrition sector in Europe. ESSNA welcomes the opportunity to provide comments to the Commission’s proposal for a Regulation on a Single Market for Digital Services (Digital Services Act) and amending Directive 2000/31/EC.

MEDEF welcomes the work carried out by the European Commission on the DSA which is a rather well-balanced text. On the one hand, it maintains the key principles of the e-commerce directive (liability exemption for technical intermediaries and prohibition of general monitoring obligations).

The DSA is a unique opportunity to review online intermediaries’ liability, whose principles are now completely outdated. The rules of the DSA will be valid for many years to come; therefore, it is key to ensure they reflect both recent and upcoming changes in online business models, criminal trends, and consumer behaviors.

March 2021 GLOBAL WITNESS: RECOMMENDATIONS FOR THE DIGITAL SERVICES ACT About us: Global Witness is an international advocacy organisation that investigates and challenges abuses of power to protect human rights and secure the future of the planet. We carry out hard-hitting investigations, expose the facts, and push for systemic change.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Technology has impacted all aspects of life for citizens and society, modifying the way they interact with each other, communicate, consume, and create wealth. This is why we at the EADT welcome the regulatory proposal on a Single Market for Digital Services (DSA, Digital Services Act) contained in the Proposal for a Regulation of the European Parliament and of the Council amending Directive 2000/31/EC, and the…

The Swedish Anti-Counterfeiting Group (SACG) sees the Commission’s legislative proposal as a positive step towards a more modern and sustainable governance of digital platforms. In particularly we welcome the introduction of a notice and action regime, KYBC requirements and the extended obligations for very large platforms.

IFPI Position on the European Commission’s Proposal for a Regulation on Digital Services Act (DSA) 31 March 2021 I. IFPI IFPI is the organisation representing the interests of the recording industry worldwide. IFPI and its National Group network has over 8,000 members across more than 70 countries.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Publishers Council (“EPC”) welcomes the Commission’s Proposal for a Digital Services Act which represents an important step in updating the framework of liability exemptions for providers of intermediary services and in setting out of due diligence obligations that will help address harm arising out of the dissemination of illegal content online.

Digital Services Act Glassdoor, Inc. (“Glassdoor”), a U.S.-based company with European headquarters in Dublin, Ireland, welcomes the opportunity to provide feedback on the initial Digital Services Act (“DSA”) proposal.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

UNIFAB – Union des Fabricants is the French association for the promotion and defence of intellectual property rights. It represents businesses from all economic sectors, and provides them with an association umbrella for promoting intellectual property and fighting against counterfeiting.

Advertisements for pets involved in illegal trade pose significant risks to the health and welfare of the animals involved, as well as to EU consumers. While the EU Pet Advertising Advisory Group (EUPAAG) works to support online platforms’ self-regulation, we see the Digital Services Act as an opportunity for the EU to improve standards of online advertising of pets via regulatory obligations.

RELX is a data and analytics company, created in Europe, rooted in Europe, with 33,000 employees operating globally. We provide information-based analytics and decision tools for professional and business customers. We help scientists make new discoveries, doctors and nurses improve the lives of patients and lawyers win cases.

31 March 2021 FEEDBACK ON THE EUROPEAN COMMISSION'S PROPOSAL FOR THE DIGITAL SERVICES ACT 1. BACKGROUND ON ECIS 1. The European Committee for Interoperable Systems ("ECIS") is an international, non-profit association of information technology companies founded in 1989 which endeavours to promote a favourable environment for interoperable ICT solutions.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Advertising Standards Alliance (EASA) would like to comment on the proposal for a Regulation on a Single Market for Digital Services (Digital Services Act - DSA) which main objectives are to contribute to the protection of consumers, ensure higher standards on transparency and accountability of online platforms and foster innovation.

IMPALA represents over 5,000 independent music companies across Europe, which account for more than 80% of all new releases and 80% of the sector's jobs and deal on a daily basis with online platforms. The DSA is the opportunity to secure a more inclusive and competitive online ecosystem, however there is still some way to go for the DSA to achieve its purpose.

Digital Services Act (DSA): Media stands for a secure and trustworthy online environment The final objectives of “deepening and further developing the Digital Single Market” and the establishment of uniform rules for a “safe, predictable and trustworthy online environment” are welcome by the European Commission in the DSA.

Filed in German · English published by the European Commission

31 MARS 2021 Ref. Ares(2021)2239152 - 31/03/2021 Position Paper « Digital Service Act » La FEBEA (Fédération des Entreprises de la Beauté) est une fédération professionnelle française qui rassemble et représente plus de 320 entreprises fabricantes vendant en France et à l’international des produits cosmétiques au sens du règlement CE n°1223/2009 (parfums, maquillage, produits pour la coiffure, produits de soins et…

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The following Executive Summary contains an overview of major points from IAB Europe’s position on the proposed Digital Services Act (DSA). IAB Europe (Transparency Register: 43167137250-27) is the European-level association for the digital advertising and marketing ecosystem.

Bertelsmann Views on the European Commission Proposal for a Digital Services Act Bertelsmann is a media services and education company that operates in about 50 countries around the world. It includes the broadcaster RTL Group, the trade book publisher Penguin Random House, the magazine publisher Gruner+Jahr, the music company BMG, the service provider Arvato, the Bertelsmann Printing Group, the Bertelsmann…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

On 15 December 2020, the European Commission has published its long-awaited rules for digital services and digital markets. The Digital Services Act Package aims at tackling some of the main issues which have been associated with large platforms: the spread of hate speech and illegal and unsafe products (Digital Services Act); and the dominance of gatekeeper platforms in certain markets (Digital Markets Act).

POLICY PAPER Ref. Ares(2021)2238312 - 31/03/2021 SMEunited position paper on Digital Services Act (DSA) - COM(2020) 825 final Introduction SMEunited welcomes the opportunity to comment on the European Commission’s proposal on the Digital Services Act (COM(2020) 825 final), published on 15 December 2020.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

E.ON welcomes the opportunity to actively participate in the consultation process on the Digital Services Act. E.ON generally supports the plans of the European Commission to deepen the internal market for digital services. The integrity and seamless functioning of the single market, especially the provision of cross-border (intermediary) digital services, is of high importance to E.ON.

The Council of Bars and Law Societies of Europe (CCBE) represents the bars and law societies of 45 countries, and through them more than 1 million European lawyers. The CCBE responds regularly on behalf of its members on policy issues which affect European citizens and lawyers. With this paper, the CCBE wished to further develop its position in relation to several aspects of the DSA and the DMA proposals.

Together with the Digital Services Act (DSA), the European Commission aims to strengthen the EU’s single market for digital services and shares the objective of strengthening security and trust as well as the conditions for innovation. SYNTEC Numérique and TECH IN France welcomed this approach, which included an important update of the regulation of services and digital markets to modernise it.

Filed in French · English published by the European Commission

Pearle* - Live Performance Europe welcomes the opportunity to give input to the draft Digital Services Act to be launched later this year. We share the Commission’s analysis that online services have deeply transformed the way we interact, communicate and do businesses. In this context, the live performance sector faces serious problems with a growing illicit online secondary ticketing.

Booking.com fully supports the political objective of fostering a more secure and safe online environment, as proposed by the Digital Services Act. We believe the vast majority of the proposed provisions form the right approach for a more responsible regulation of the digital economy. However, we believe that the proposal could have been more ambitious in tackling the problem of illegal short term holiday rentals.

The Global Network Initiative (GNI) welcomes the European Union’s efforts on the Digital Services Act (DSA). We were pleased to see several recommendations from GNI’s prior submission addressed in the Commission’s draft.

Together with the Digital Services Act (DSA), the European Commission aims to strengthen the EU’s single market for digital services and shares the objective of strengthening security and trust as well as the conditions for innovation. SYNTEC Numérique and TECH IN France welcomed this approach, which included an important update of the regulation of services and digital markets to modernise it.

Filed in French · English published by the European Commission

1. Risk Assessment (Article 26) Article 26 outlines the requirement of very large online platforms (VLOPs) to conduct risk assessments for their business operations within the EU. In addition to the areas outlined, these assessments should include platforms’ exposure to disinformation risks. Knowing and mitigating these risks can help to demonetise disinformation (i.e.

Recommandations sur le Digital Services Act (DSA) et le Digital Markets Act (DMA) Mars 2021 PROPOS LIMINAIRE Le Digital Services Act (DSA) et le Digital Market Act (DMA) représentent une occasion unique pour imposer des garanties démocratiques dans l’espace de l’information et de la communication. Ils présentent indubitablement des avancées mais l’état actuel de ces textes n’est pas à la hauteur des enjeux.

Filed in French · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

SAA feedback regarding the Digital Services Act proposal 30 March 2021 About the SAA The Society of Audiovisual Authors (SAA) is the umbrella association of European collective management organisations representing audiovisual authors. Its 33 members in 25 countries manage rights for over 160,000 film, television and multimedia European screenwriters and directors.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EGDF and ISFE welcome the opportunity to comment on the Commission’s draft Digital Services Act (DSA). ISFE represents the video games industry in Europe and its membership comprises national trade associations in 15 countries which in turn represent thousands of video games developers and publishers at national level, ranging from small-to-medium sized enterprises (SMEs) to large global companies.

CPME welcomes the European Commission’s initiative to introduce a modern and clear legal framework for businesses to grow safely in the Digital Single Market. At the same time, CPME welcomes the legislative form chosen, two European regulations, which will streamline the effectiveness, efficiency and harmonisation of future measures.

Filed in French · English published by the European Commission

SAA feedback regarding the Digital Services Act proposal 30 March 2021 About the SAA The Society of Audiovisual Authors (SAA) is the umbrella association of European collective management organisations representing audiovisual authors. Its 33 members in 25 countries manage rights for over 160,000 film, television and multimedia European screenwriters and directors.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Liberty Global welcomes the European Commission’s proposal for a Digital Services Act (DSA) to update the horizontal rules that define the responsibilities and obligations of providers of digital services. The eCommerce Directive was adopted two decades ago and, since then, major market and technological changes have taken place – including the growth of platforms driven by user-generated content and online…

The Wikimedia Foundation (WMF) and the Free Knowledge Advocacy Group EU (FKAGEU) appreciate the Commission’s thoughtful approach to addressing the rights and responsibilities of providers of digital services. The WMF is the charitable organization that hosts the Wikimedia movement’s free knowledge projects, including Wikipedia.

Open-Xchange would like to thank for the opportunity to provide comments on the Commission’s proposal for the new Digital Services Act. We generally support the Commission’s objectives and stand in favour of enacting a new regulation building on the draft.

SGI Europe welcomes the Digital Services Act (DSA) by the European Commission and the opportunity to reflect on the proposal for a regulation again in the public feedback consultation. Service providers of general interest serve to the public good and protect European fundamental rights. We are taking Europe forward in serving and acting in the general interest and in being key players in the digital environment.

As an organisation that has contributed to the technical operation and development of the Internet in Europe for nearly 30 years, the RIPE NCC appreciates the opportunity to give its feedback on the adoption of the European Commission’s proposed Digital Services Act (DSA).

Vivendi – Feedback on the Digital Services Act – deepening the internal market and clarifying responsibilities for digital services Introduction Vivendi is a European company based in France. Vivendi is one of the few companies to be at the crossroads of several cultural and creative industries: music, cinema, television, communications, books, video games and live performances.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EU Transparency Register ID Number: 39850528734-23 BAR COUNCIL FEEDBACK ON THE DIGITAL SERVICES ACT 1. This is a response by the General Council of the Bar of England and Wales (‘the Bar Council’) to the European Commission’s Proposal for a Regulation of the European Parliament and Council on a Single Market for Digital Services (the Digital Services Act) and amending Directive 2000/31/EC (‘the Proposed…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Legge sui servizi digitali Approfondire il mercato e chiarire le responsabilità per i servizi digitali Position Paper CRTV 31 marzo 2021 Confindustria Radio Televisioni The fears expressed concern, in particular, the issue of responsibility of online platforms on the contents conveyed and the enforcement tools, which should inspire the new “horizontal and coordinated” approach of the EU Commission.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EUROPEAN SOFTWARE DEVELOPERS AND USERS RELY ON OPEN SOURCE SOFTWARE DEVELOPMENT PLATFORMS AND CODE REPOSITORIES TO INNOVATE AND COMPETE GLOBALLY Brussels, 31 March 2021 Further to our one-pager on Digital Services Act (8/9/20), OpenForum Europe (OFE) wishes to submit more detailed comments as an active advocate of technological openness and our long-standing collaboration with the Open Source software (OSS)…

The Electronic Frontier Foundation is among the leading non-profit organizations defending civil liberties in the digital world. Founded in 1990, EFF champions user privacy, free expression, and innovation through impact litigation, policy analysis, grassroots activism, and technology development.

The Polish Filmmakers Association – Union of Audiovisual Authors and Producers (SFP-ZAPA) would like to thank the European Commission for organising consultations on the extremely important matter of the future of digital services.

Transparency of advertising Online advertising drives excessive data collection, personal data abuse and intrusive targeting. In addition to the large-scale privacy breaches that continue to escape GDPR enforcement, this situation has led to the manipulation of democratic elections and the distortion of online public debate around the world.

STM welcomes the Commission’s proposal for a Regulation on a Single Market for Digital Services (Digital Services Act, DSA) and amending Directive 2000/31/EC (E-Commerce Directive, ECD). STM believes that the DSA provides a positive horizontal approach which seeks to provide clarity regarding the responsibilities of providers of intermediary services.

POSITION STATEMENT Proposal for a Regulation on a Single Market for Digital Services In summary ➢ FSB welcomes the intention to complete the digital single market and establish a fair, stable regulatory environment that facilitates cross-border trade. Further action is needed to redress the balance between online platforms and small business users.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

DSA Proposal: Etsy’s Feedback 31 March 2021 ABOUT ETSY Etsy is a global marketplace for unique and creative goods. Our mission is to keep commerce human, and we’re committed to using the power of business to strengthen communities and empower people.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Contributo sulla proposta di regolamento Digital Service Act La proposta di regolamento COM (2020) 825 final, cosiddetto Digital Services Act (DSA) rappresenta un significativo passo in avanti nella direzione di contrastare in maniera omogenea alcune delle evidenti problematiche connesse al funzionamento e all’uso di servizi digitali consentendo a imprese, professionisti, acquirenti e utenti di trarre beneficio da…

Filed in Italian · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

IBM welcomes the opportunity to give feedback on the Commission’s proposal for a Digital Services Act (DSA). As a global Business-to-Business (B2B) technology company with a significant European footprint, IBM plays a key role in the digital transformation of Europe’s industry, enabling our clients to benefit from the power of data.

DFL Deutsche Football Liga e.V. is the merger of the 36 professional football clubs of the Bundesliga and 2. German Football League. On its behalf, DFL Deutsche Football Liga GmbH organises the league competitions and markets the Bundesliga and 2. German Football League. This includes, in particular, the marketing of audiovisual media rights in the matches of the two top classes of German football.

Filed in German · English published by the European Commission

Digital space is plagued by a range of deficiencies from the proliferation of hate speech to dissemination of disinformation and harmful information to vulnerable audiences by plethora of domestic as well as foreign actors.

The European Federation of Pharmaceutical Industries and Associations (EFPIA) represents the biopharmaceutical industry operating in Europe. Through its direct membership of 36 national associations, 39 leading pharmaceutical companies and a growing number of small and medium-sized enterprises (SMEs), EFPIA’s mission is to create a collaborative environment that enables our members to innovate, discover, develop and…

The G5 Santé members would like to remind the impact of illicit, substandard and falsified products have on patient safety and, overall, society. They seriously harm or kill patients, challenge healthcare systems and undermine people’s trust in quality medicines.

As the registry operator of the .COM, .NET, .NAME, .CC and .TV top-level domains (TLDs), and as an organization with a long history of helping to maintain the security, stability and resiliency of the Domain Name System (DNS) and the internet, VeriSign, Inc. (“Verisign”), welcomes the opportunity to provide feedback on the proposal for a Digital Services Act (DSA).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

March 30 2021 Developers Alliance Position On The Digital Services Act (DSA) Founded in January 2012, the Developers Alliance is a global industry association that supports software developers as entrepreneurs, innovators, and creators. DevelopersAlliance.org In summary, the Developers Alliance supports a Digital Services Act that… …is a horizontal and harmonized framework. …provides legal clarity and certainty.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Civil Liberties Union for Europe submits its position to give feedback to the European Commission about the Proposal for a Regulation of the European Parliament and of the Council on a Single Market For Digital Services (Digital Services Act). See the attachment in pdf.

The La Poste Group intends to seize all the opportunities offered by digital technology to continuously improve the quality of services provided to its customers and users, innovate and develop new activities. That is why he advocates a healthy and fair competitive environment (a “level playing field”) in all sectors of activity, leading to innovation and collective well-being.

Filed in French · English published by the European Commission

AFNUM welcomes this text and wishes to highlight the fact that ongoing regulatory discussions in Europe are going in the right direction to promote a safe online environment. This proposal for a framework provides the basis for more responsibility for online platforms, in particular as regards the content, products and services they host, make available and distribute to the general public.

Filed in French · English published by the European Commission

Please find attached the feedback of ACT | The App Association (Transparency Reg. # 72029513877-54) to the European Commission’s adopted "Digital Services Act" proposal. Anna Bosch Policy Associate ACT | The App Association (Transparency Reg. # 72029513877-54) Rue de Trèves 45 B-1040 Brussels

Pex welcomes the opportunity to provide comments on the DSA proposal. Pex’s mission is to provide copyright transparency that enables digital marketplaces to reach their full potential, while maintaining a fair balance between interests of rightsholders, content creators, platforms and users.

IFRRO, the International Federation of Reproduction Rights Organisations, is the international network of collective management organisations operating in the field of text and image (known as Reproduction Rights Organisations, or RROs).

Snap is overall supportive of the DSA proposal. We are however concerned that it may not, in its current state, fully achieve the objectives envisaged by the Commission of clarifying liability for digital intermediaries for the benefit of consumers and innovation. Snap would therefore like to present its main concerns.

FEP welcomes the Commission’s proposal for the Digital Services Act. This update of the E-Commerce Directive is needed to address the emergence and dominance of new hosting services, whether in the form of marketplaces or content sharing services. These new services use legal safe harbours that were never envisioned for them to reduce their obligations regarding illegal content.

BDZV Bundesverband Digitalpublisher und Zeitungsverleger e.V. VDZ Verband Deutscher Zeitschriftenverleger e.V. Erste Stellungnahme zum Entwurf der EU-Kommission für einen Digital Services Act v. 15.12.2020 (COM(2020) 825) – im Folgenden DSA-E (Stand: 30. März 2021 – v2) Der Verband Deutscher Zeitschriftenverleger e.V. (VDZ) ist der Dachverband der deutschen Zeitschriftenverlage.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Amnesty International welcomes that the Digital Services Act (DSA) increases accountability of providers of online services, improves transparency of platforms’ practices and establishes clearer rules for content moderation. The fact that the DSA upholds the conditional liability exemptions and the prohibition of a general monitoring obligation to find illegal activity is equally welcome.

Access Now welcomes the opportunity to submit comments on the proposed Digital Services Act (DSA) legislative framework. Access Now has been advocating for a human rights-based and user-centric regulation that will establish clear responsibilities for large online platforms with strong enforcement mechanisms that can hold them to account.

The Imaging Consumables Coalition of Europe, Middle East and Africa (ICCE) welcomes the opportunity to provide feedback on the European Commission’s DSA proposal. The DSA is of particular importance to ICCE members and the many consumers that they serve.

EUROCINEMA represents audiovisual producers at the European level. EUROCINEMA welcomes the European Commission's proposal for a Digital Services Act as an important step toward a more regulated and safer online environment.

On 15 November to Sofia, Bulgaria, with the Conference of Presidents, in view of preparations for the Bulgarian Presidency of the Council: In December 2020, the European Commission presented its Digital Services Package with a Digital Services Act and a Digital Markets Act.

Filed in German · English published by the European Commission

Summary Directive 2000/31/EC of the European Parliament and of the Council on certain legal as-pects of information society services, in particular electronic commerce, in the internal market (Directive on electronic commerce) (‘eCommerce Directive’ – ‘eCD’) was adopted on 8 June 2000.

Media organisations generally welcome the European Commission’s legislative proposals for a Digital Services Act and a Digital Markets Act. They represent an important step towards strengthening the European single market and refocus on the much needed prerogatives of the legislator in the context of regulating global online services.

Filed in German · English published by the European Commission

The Digital Services Act (DSA) proposal marks an important update to internet regulation in Europe. DIGITALEUROPE's membership supports the European Commission's ambition to strengthen the Single Market for digital services in the EU. Clarity is needed on the role and responsibilities of online intermediaries to address the problem of illegal content online and help boost trust in the internet.

The Global Legal Entity Identifier Foundation (GLEIF) is pleased to provide comments to the European Commission’s Proposal for a Regulation of the European Parliament and of the Council on a Single Market for Digital Services (Digital Services Act) and amending Directive 2000/31/EC.

For 20 years, the Association for Internet Progress (SPIR) has represented the most important players in the Czech Internet economy from among publishers, media agencies, and technology companies with a turnover of more than 37 billion crowns per year. The services offered by SPIR members are used by over 90% of the population of the Czech Republic.

For the European Digital Single Market to function properly and cohesively, its rules must be aligned with the evolution of technology and the rise of new digital services. Fragmentation of the single market regulation hampers growth and is particularly detrimental to the prospects of small and medium-sized enterprises that provide and use digital services.

CENTR is the association of European country code top-level domain registries (ccTLDs). All EU Member State and EEA country ccTLDs (such as .de, .ch, and .pt) are members of CENTR. CENTR members are at the core of the public internet, safeguarding the stability and security of the internet as we know it today.

For members of the European Broadcasting Union (EBU) – public service media organizations in Europe – establishing a strong and consistent rulebook for global online platforms is crucial. We support the objective of the DSA to create a safer and more accountable online environment. However, we ask EU decision-makers to make the proposed DSA stronger.

Deutsche Football-Bund e.V. (DFB) is one of the largest sports professional associations in the world, with more than seven million registered members in almost 25.000 clubs and around 155.000 teams. He markets, among other things, the audiovisual media rights of the national women’s matches and the DFB pokal.

Filed in German · English published by the European Commission

The Deutsche Steuerberaterverband e.V. (DStV) — the Federation of Tax Consultants and Economic Auditing Professions — represents around 36.000 nationwide and thus more than 55 % of professionals working independently in their own law, a large number of whom are also accountants or certified accountants.

Filed in German · English published by the European Commission

CSC recognises the need to update the regulation of the digital services market in order to adapt it to the evolving operating environment and to make the market safer and fairer for consumers as well as service providers of different types and sizes. The Commission’s proposal for a Digital Services Act contributes to this endeavour and is therefore highly appreciated.

Allied for Startups welcomes the opportunity to give feedback on: “Digital Services Act (DSA) – deepening the internal market and clarifying responsibilities for digital services”. Startups are key innovators and competitors in the Digital Single Market. Today, there are about 10,000 high-growth platforms in Europe. Today’s startups are tomorrow’s scale-ups and job creators.

Recommendations on the Digital Services Act 26th March 2021 About us European Visual Artists (EVA) is representing 28 European collective management organisations (CMOs) in 23 countries for authors of fine arts, painters, sculptors, photographers, illustrators, designers, graphic designers, street artists and architects. They manage the rights of over 130.000 artists. Scope and Definitions (Art.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

You will please find in attachment the full contribution of the European Cultural and Creative Industries Alliance (ECCIA) on the DSA proposal. ECCIA is composed of six European high-end cultural and creative industries organisations - Altagamma (Italy), Circulo Fortuny (Spain), Comité Colbert (France), Gustav III Committee (Sweden), Meisterkreis (Germany) and Walpole (UK) - who between them represent over 600…

DOT Europe – the voice of leading digital, online and tech companies in Europe – believes that the DSA has enormous potential. While there are significant details to iron out during the legislative process, we believe that the purpose of the DSA and the opportunity it represents must be kept in mind throughout.

Position paper 29 March 2021 Regulation on a Single Market for Digital Services (Digital Services Act) I. Executive Summary The European Data and Marketing industry plays a crucial role in helping marketers to effectively communicate reliable information and services to individuals.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ARD and ZDF welcome the European Commission’s proposal for a Digital Services Act (DSA) as a good basis for the upcoming legislative process. Together with the proposed Digital Markets Act, the DSA has the potential to set modern and future-proof EU rules which duly react to the influence of global intermediary services providers on today’s way of life and help build public trust in information online, provided that…

The European Alcohol Policy Alliance (Eurocare) welcomes the opportunity to comment on the Digital Services Act – deepening the internal market and clarifying responsibilities for digital services. Eurocare is an alliance of non-governmental health organisations with 52 member organisations across 22 European countries advocating the prevention and reduction of alcohol related harm in Europe.

ANDEMA welcomes the opportunity to comment on the Proposal for a Regulation on the Digital Services Act (DSA), focusing on the issue of the presence of illegal goods (including counterfeit goods) on online platforms, which did not exist when the e-Commerce Directive was adopted.

Filed in Spanish · English published by the European Commission

Prior to the release of the Commission's legislative proposal, the European Regulators Group for Audiovisual Media Services (ERGA) had published a first Position Paper on the DSA and responded to the Commission’s public consultation (https://erga-online.eu/wp-content/uploads/2020/06/ERGA_SG1_DSA_Position-Paper_adopted.pdf).

The Commission announced on the Communication on ‘Shaping Europe’s Digital Future’ a Digital Services Act package, including a proposal of new and revised rules to deepen the Single Market for digital services, by increasing and harmonising the responsibilities of online platforms and information society service providers.

The Face-value European Alliance for Ticketing welcomes the European Commission’s thorough and considered draft Digital Services Act (DSA), in particular, its focus on ensuring that consumers are better protected online and robust systems are in place to effectively supervise online platforms.

Tackling the proliferation of illegal products online has become even more important to foster consumers’ trust in the digital environment now that the COVID-19 crisis has forced them to rely increasingly on the Internet for their everyday needs.

The APM strongly welcomes the objective of putting digital regulation on a new, modern basis. Trading platforms in particular have a key role to play at a time when trade is increasingly moving online (not least due to the current pandemic) and consumers get their goods there. They interact between consumers and traders and thus have an overview and ultimately control over all transactions.

Filed in German · English published by the European Commission

Seznam.cz is an online platform and media company based in Czech Republic, with dozen of services like news, entertainment, general search engine, freemail, maps, price comparison tools and others. With more than 1500 employees, 90 % reach in Czech population and annual revenue above EUR 150 million, Seznam.cz represents a significant and Valuable European online company.

Filed in Czech · English published by the European Commission

ABSICHERUNG VON NUTZERRECHTEN AUF ONLINE-PLATTFORMEN Stellungnahme des Verbraucherzentrale Bundesverban ds zum Entwurf eines Gesetzes über digitale Dienste 23. Februar 2021 Impressum Verbraucherzentrale Bundesverband e.V.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EuroISPA is the voice of the European Internet industry, representing over 2,000 Internet Service Providers across Europe, all along the Internet value chain. As we have been engaging in discussions on intermediary liability and content moderation for over 20 years, we highly appreciate the opportunity to share our feedback with the European Commission on the Digital Services Act (DSA).

eco welcomes the opportunity to share its initial view on the proposed regulation, and we look forward to further specifying the initial, subsequent remarks in the near future. eco acknowledges the ambitious proposal and welcomes the Commission’s approach with regard to the continuation of the existing liability exemptions, which have been carried over from the E-Commerce Directive (ECD) into the Digital Services…

EMMA and ENPA’s Position paper on the proposal for a Regulation on a Single Market for Digital Services (COM(2020) 825) – hereafter the Digital Services Act (DSA): 1. Editorial platforms must be explicitly excluded from the scope of the new obligations of Chapter III DSA as they jeopardize the freedom of the press and editorial freedom Newspapers and magazines depend on the possibility to offer third parties, their…

INDICAM welcomes the European Commission’s Digital Services Act (DSA) proposal as an important first step to ensure a more transparent and secure digital environment for consumers and more attentive to the protection of intellectual property rights and the know-how of companies, without restricting fundamental rights and freedoms.

Filed in Italian · English published by the European Commission

19.03.21 The Danish Rights Alliance1 submission: The consultation on the Proposal for a Regulation of the European Parliament and of the Council on a Single Market for Digital Services COM(2020) 825 final The Danish Rights Alliance herewith submits a short response to the Commission’s consultation on the Proposal for a Regulation: Digital Services Act (the 'proposal’ in the following).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The French Building Federation welcomes the proposal for a Regulation on an internal market for digital services as it intends to define the responsibilities of online platforms as intermediary service providers.

Filed in French · English published by the European Commission

Brussels, March 2021 BSA Position Paper on the Digital Services Act BSA | The Software Alliance (BSA) 1 welcomes the opportunity to provide input to the Commission’s draft Digital Services Act (DSA). BSA is the leading advocate for the global software industry.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

10 March 2021 ITI Views on the European Commission Proposal for a Digital Services Act (DSA) Introduction Digital services play a foundational role in driving innovation and growth in the economy, supporting the smooth operation of digital supply chains and creating market opportunities and access for businesses of all sizes.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

POSITION OF MARKENVERBAND MARKENVERBAND CLARIFIES: DIGITAL SERVICES ACT IS ONLY A SHARP SWORD IF PROPOSED MEASURES ARE AMENDED Markenverband (German Brands Association) represents the interests of brand-oriented businesses in Germany.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

AIM, the European Brands Association, is grateful to the European Commission for its considered draft Digital Services Act (“DSA”), which should help to ensure that the European Union remains at the vanguard of protecting online consumer and business trust, safeguarding both rights and citizens.

Founded in 1973, the Fédération represents over a hundred internationally known brands and is the voice of the French creative and luxury fashion industry. Its members are significantly impacted by the sale of illegal and counterfeit products online and make great investments to try to limit such sales on intermediaries’ websites.

Wien, am 29. Januar 2021 Stellungnahme zum Vorschlag der Europäischen Kommission für eine Verordnung über einen Binnenmarkt für digitale Dienste („Digital Services Act“) und zur Änderung der Richtlinie 2000/31/EG (COM (2020) 825 final) Der ÖRAK begrüßt die Bestrebungen zur Weiterentwicklung und umfangreichen Harmonisierung des europäischen Rechtsrahmens für die Erbringung von Diensten der Informationsgesellschaft.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Thank you for this opportunity to provide feedback. Please find attached the Computer & Communications Industry Association (CCIA Europe)'s position paper on the Digital Services Act. We believe the DSA to be an opportunity to create a better functioning EU Digital Single Market, provide clarity on everyone’s responsibilities, and safeguard online rights.

Eu travel tech welcomes the proposal for a Digital Services Act, which paves the way for a more responsible online environment, in particular the European Commission’s approach to keep the core principles of the eCommerce Directive with a proven track-record - such as the Country of Origin principle and the absence of a general obligation to monitor.

EACA, the European Association of Communications Agencies, welcome the European Commission’s intention to maintain the core principles of the e-commerce Directive, including its conditional intermediary liability regime, the absence of a general monitoring obligations, and the country-of-origin principle. These principles enabled the growth of the digital economy in Europe and expanded access to information.

• • 1 https://ec.europa.eu/digital-single-market/en/news/communication-enabling-digital-transformation-healthand-care-digital-single-market-empowering 2 https://www2.deloitte.com/content/dam/Deloitte/nl/Documents/public-sector/deloitte-nl-shaping-thefuture-of-european-healthcare.pdf • • • • 3 https://ec.europa.eu/health/human-use/eu-logo_nl…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Association for a Professional Hosting and Tourism (AhTop) welcomes the EC’s proposal aiming at clarifying the platforms’ responsibilities. Specifically, we consider the measures below are heading in the right direction: • The establishment of a contact point and, where necessary, a legal representative ; • The implementation of a notice and action mechanisms ; • The cooperation with national authorities…

We welcome the opportunity to share our views on the Inception Impact Assessment on the Digital Services Act Package: Deepening the Internal Market & Clarifying Responsibilities for Digital Services. In the light of the tremendous development of digital services in the last decades, we fully agree that it is timely to take stock and update legacy provisions, where required.

At Apple, our mission is to make hardware, software and services that help people make the world a better place. We design our products and services to create a seamless user experience that sets the industry standard for privacy protection and digital security.

MARKENVERBAND POSITION PAPER MARKENVERBAND’s Response to the EU Commission Inception Impact Assessment for the Digital Services Act (eCommerce Directive) Markenverband (German Brands Association) represents the interests of brand-oriented businesses in Germany.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

FEEDBACK FOR THE PUBLIC CONSULTATION ON A NEW COMPETITION TOOL. SUGGESTION FOR A PARADIGM CHANGE. 30 June de 2020 CONTACT Autoritat Catalana de la Competència Via Laietana, 60, 5a planta 08003 Barcelona Tel: [phone removed] [email removed] http://acco.gencat.cat/ @competenciacat [name removed] [email removed] @xavipuigs 2 Table of contents 1.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

European Commission consultation on a proposed Digital Services Act Response by Sky Introduction The e-Commerce Directive has made a key contribution to the growth of the internet in the EU. Innovative businesses have flourished in the online world to the benefit of millions. Yet the role of the internet in a democratic society clearly has evolved.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

In its September 2017 Communication on Tackling Illegal Content Online , the European Commission (EC) acknowledged that “what is illegal offline is also illegal online”, which we welcome. The EC underlining that the rule of law also applies and should be respected online was a very positive step forward.

Deliveroo welcomes the opportunity to engage with the Roadmap on clarifying the responsibilities for digital services. - Proposals should distinguish between digital platforms posing a genuine risk to freedoms and those that are merely marketplaces. - We welcome the codification of law applicable to our business. The proposals must simplify, rather than further fragment, the legal framework.

Toy Industries of Europe (TIE), the voice of reputable toy makers in the EU, welcomes the opportunity to comment on the combined evaluation roadmap/Inception Impact Assessment on the ‘Digital Services Act package: deepening the Internal Market and clarifying responsibilities for digital services’. Our comments relate to the need to prevent illegal content on online marketplaces.

Match Group welcomes the plans of the European Commission to clarify responsibilities for digital services and improve user safety online. The online dating services of Match Group, which include Tinder, Meetic and OkCupid, are peer-to-peer match-making services, which aim at connecting people rather than enabling one-to-many content sharing or generating transactions.

Contribution 30 June 2020 FINAL Comments to the Commission’s roadmap/inception impact assessment on the Digital Services Act package: deepening the Internal Market and clarifying responsibilities for digital services Introduction EuroCommerce welcomes the opportunity to provide input to the roadmap consultation on ‘deepening the Internal Market and clarifying responsibilities for digital services.’ Digital services…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

MINISTER FOR INDUSTRY, BUSINESS AND FINANCIAL AFFAIRS Denmark’s response to the Roadmap for the Digital Services Act package – Deepening the Internal Market and clarifying responsibilities for digital services The Danish Government welcomes the Commission’s decision to launch a Digital Services Act and appreciates the opportunity to comment on the Commission’s roadmap.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

IOGT-NTO is the largest temperance organisation in Sweden. It is also one of the country's oldest NGOs with a long tradition of cultural, social and educational efforts in local communities. IOGT-NTO has long-standing expertise on questions of alcohol marketing. IOGT-NTO's detailed feedback to the Roadmap/IIA attached.

The Wikimedia Foundation and the Free Knowledge Advocacy Group EU welcome the debate on the responsibilities of digital services. We believe that a regulatory framework must preserve and promote the freedom of imparting and receiving information without interference by public authority; promote freedom of expression; and protect users from harmful and illegal activities.

We, the European Producers Club, representing more than 130 independent producers across 28 countries in Europe and Canada, have witnessed a wide change in our industry with the digitalization, and the arrival of OTT streaming platforms.

EFPIA (the European Federation of Pharmaceutical Industries and Associations), representing research-based pharmaceutical manufacturers in Europe, welcomes the recently launched proposal for a new Digital Services Act package, which aims to modernise the current legal framework for digital services.

The Alliance for Safe Online Pharmacy in the EU (ASOP EU) Submission to European Commission Combined Evaluation Road Map and Inception Impact Assessment Reference Ares (2020)2877686 – 04/06/2020 Executive Summary ASOP EU is an informal multi-stakeholder patient safety coalition, with the objective of making buying medicines online safer.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

30 June 2020 Feedback on the Inception Impact Assessment for a Digital Services Act: Deepening the internal market and clarifying responsibilities for digital services eBay welcomes the Commission's intention to adopt a Digital Services Act that would deepen the internal market and clarify responsibilities for digital services The e-Commerce Directive (ECD) was adopted in 2000 to set-up the basic legal framework for…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Shopify was founded in 2006 by German-born Tobias Lütke with the goal of helping to democratize commerce. Fourteen years later, our ecommerce platform is used by over 1 million entrepreneurs and small businesses globally. Today, over 100,000 European businesses, many of them small and medium-sized enterprises, have used Shopify to generate USD 319 Billion of economic activity, creating over 2 million full-time jobs.

Digital Services Act - deepening the internal market and clarifying responsibilities for digital services Inception Impact Assessment Comments by Mediaset S.p.A. The current horizontal framework governing the internet has been adopted 20 years ago. It has allowed the entrance of new players in the European Union which offered innovative services to European consumers.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

How the Digital Services Act (DSA) Can Help Foster a More Responsible Online Environment June 2020 ABOUT IFPI IFPI represents the interests of the recording industry worldwide. We have some 1,300 members around the world and in all major European markets, ranging from small-tomedium enterprise (SME) to global labels.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Free Knowledge Advocacy Group EU welcome the debate on the responsibilities of digital services. We believe that a regulatory framework must preserve and promote the freedom of imparting and receiving information without interference by public authority; promote freedom of expression; and protect users from harmful and illegal activities.

The Juridical Observatory on Digital Innovation (“JODI”) (https://web.uniroma1.it/deap/ogid) welcomes the initiative taken by the European Commission to consult with the various stakeholders prior to putting forward a proposal for a future regulation dealing with, inter alia, the “responsibilities for digital services” in the context of the ‘Digital Services Act package’ announced by the President of the European…

The Motion Picture Association (MPA) welcomes this opportunity to comment on the combined evaluation roadmap/inception impact assessment. MPA members are leading producers and distributors of diverse film, series, television and online content enjoyed by European audiences via lawful digital services.

PIKE (Polska Izba Komunikacji Elektronicznej – the Polish Chamber of Electronic Communications) is an organisation that brings together polish undertakings providing electronic communications services, especially cable operators. We welcome this opportunity to provide feedback on Digital Services Act. Please find some particular remarks below. I.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Enclosed you can find Facebook's submission to the European Commission’s Inception Impact Assessment and Roadmap assessing different policy options for reforming the regulatory framework for digital services operating in Europe under the part on deepening the Internal Market and clarifying responsibilities for digital services.

Warsaw, 30 June 2020 Allegro’s comments on the European Commission’s Roadmap/Inception Impact Assessment to the Digital Services Act package: deepening the Internal Market and clarifying responsibilities for digital services I.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Google welcomes the opportunity to submit feedback to the Commission’s Inception Impact Assessment and we invite all to read the full submission in the attachment. Digital services connect individuals and communities around the world. They inspire the best of society by democratizing access to knowledge, powering business, and providing new opportunities for art and creativity.

FIAPF (International Federation of Film Producers Associations - FIAPF Headquarters - ID 332167817125-52)’s members are 34 film and TV producer organizations from 27 countries, including 15 in the EU/EEA. Their activities include the development and production of films and audiovisual content which are distributed offline and online via all forms of authorised and legal online distribution channels.

Given Eurocare’s profile, comments are given to areas in which it possesses expertise and interest. As a general comment Eurocare would like to support the European Commission’s remarks regarding an increasingly fragmented legal landscape and the need for better alignment and simplification of the legal provisions governing the digital landscape.

FEP welcomes the objective of the Commission to review and clarify the responsibilities of digital services as part of the Digital Services Act package. The core principles of the E-Commerce Directive should be maintained as they remain valid, particularly the limited liability applicable to purely passive and merely technical intermediaries and the related ban on general monitoring.

Limiting intermediary liability has been an essential enabler for the success of the digital economy and has resulted in substantial tangible benefits for consumers. For example, customer generated reviews of hotels and other accommodations have intensified competition, increased trust and opportunity for properties outside of popular destinations, lowered prices, and improved quality.

Bol.com welcomes the opportunity to respond to the Digital Services Act (DSA) Inception Impact Assessment (IIA) on 'deepening the Internal Market and clarifying responsibilities for digital services'. As a local online retail platform operating in the Netherlands and Belgium, bol.com is pleased to share their views on the problem analysis and the introduced possible policy options: • Since 'digital services' and…

Digital Services Act Effektive Rechtsdurchsetzung für eine wettbewerbsfähige europäische Filmwirtschaft Die Spitzenorganisation der Filmwirtschaft e.V. (SPIO) vertritt die Interessen der deutschen Filmwirtschaft entlang der Wertschöpfungskette Filmproduktion, Postproduktion, Filmverleih, Filmtheater und Videoprogramm. Als Dachverband von 18 Berufsverbänden repräsentiert sie mehr als 1.100 Mitgliedsfirmen.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

BSA | The Software Alliance (BSA) welcomes the opportunity to provide input to the Commission’s evaluation roadmap/inception Impact Assessment on the Digital Services Act. BSA is the leading advocate for the global software industry. Our members are at the forefront of software-enabled innovation that is fueling global economic growth by helping enterprises in every sector of the economy operate more efficiently.

ANDEMA is grateful for the opportunity to make comments to the EU Commission Inception Impact Assessments and Public Consultation on a Digital Services Act, focused on the issue of the presence of illegal (including counterfeit) goods on online platforms, platforms that did not exist when the E-Commerce Directive was adopted.

Filed in Spanish · English published by the European Commission

Europe and the United States both want a trustworthy and values-based internet, yet both struggle with the surge of online content that is either illegal or deemed harmful to society. Regulating such content is difficult, however, given our deep belief in the fundamental right to freedom of expression, a cornerstone of our democracies. And as the U.S.

Without the use of independent trust indicators, it can be hard for large online companies to ensure the quality of their content, e.g. using human fact-checkers: item by item evaluation by fact-checkers is relevant but too slow. One should assess sources, not negatively by censoring any, but positively: highlighting the most credible ones.

The French Association of Large Companies (AFEP) welcomes the European Commission’s consultation on a combined roadmap/inception impact assessment on the Digital Services Act package and strongly support the Commission’s intention to revise the E-Commerce Directive.

Access Now supports the European Commission’s effort to establish a new legislative framework that would regulate online platforms’ procedural obligations in content governance, while modernising the current legal regime in the e-Commerce Directive.

SPANISH DIGITAL ECONOMY ASSOCIATION (ADIGITAL) Digital Services Act, European Commission public consultation Inception Impact Assessment Internal Market aspects The European Commission has released an Inception Impact Assessment on the e-Commerce aspects of the Digital Services Act (“deepening the Internal Market and clarifying responsibilities for digital services”).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Allied for Startups welcomes the opportunity to provide feedback to the Inception Impact Assessment of the Digital Services Act package. Please find attached our feedback and do not hesitate to reach out if you have questions. Allied for Startups is a worldwide network of over 40 advocacy organisations focused on improving the policy environment for startups.

RECOGNISE THE WORKER DIMENSION Throughout the Digital Services Act (DSA) documents there is mention of consumers, sellers, and intermediaries, but no mention of platform workers. Platform workers are just as much a part of this equation. As the DSA address the obligations and responsibilities of platforms, it is therefore necessary to add the employer responsibilities and employment relationship.

The European Public Health Alliance (EPHA) appreciates the opportunity to provide feedback on the combined roadmap and inception impact assessment (IIA) for the Digital Services Act package: deepening the Internal Market and clarifying responsibilities for digital services.

STM welcomes the ambition of the European Commission (EC) to upgrade the rules for digital services and further deepen the Digital Single Market through a new Digital Services Act (DSA) package. The E-Commerce directive (ECD, Directive 2000/31/EC) has been a cornerstone piece of legislation since 2001, underpinning the functioning of the internal market and playing a pivotal role both for and throughout the whole…

On behalf of the Center for Data Innovation, we are pleased to submit feedback (please see attached) to the European Commission’s roadmap titled “Digital Services Act package: Deepening the internal market and clarifying responsibilities for digital services." The European Commission plans to propose a new Digital Services Act, legislation that could revise or repeal the e-Commerce Directive and create a new set of…

Our information space is plagued by numerous deficiencies such as proliferation of hate speech and dissemination of disinformation and harmful narratives to vulnerable audiences by plethora of domestic as well as foreign actors.

UNIFAB warmly welcomes this combined evaluation roadmap / inception impact assessment. We fully agree with the EU commission when it states that “the rapid and widespread development of digital services has been at the heart of the digital transformation”. Unfortunately, this development has also had negative effects such as the increase of online sales of counterfeits and other illegal goods.

Microsoft supports the European Commission’s ambitions for the Digital Services Act (DSA). Digital services have a responsibility to design and operate their services in ways that help protect user safety online. The intermediary liability safe harbor offered by the e-Commerce Directive (ECD) is the foundation upon which rests the promotion, protection, and enjoyment of human rights on the internet.

European Tech Alliance (EUTA) position on Digital Services Act Impact Assessment: deepening the Internal Market and clarifying responsibilities for digital services We are grateful for the opportunity to comment on the European Commission’s Inception Impact Assessments on DSA initiatives.

The Electronic Frontier Foundation (EFF) is among the leading non-profit organizations defending civil liberties in the digital world. We welcome the opportunity to provide feedback to the European Commission on this IIA and to highlight what matters most: the E-Commerce Directive should be apt to deal with the challenges brought by a digital space that is monopolized by a few platforms and where alternative…

AIM, the European Brands Association welcomes the EU Commission initiative to consult on the future Digital Services Act. In our view the EU Commission has identified correctly the main challenges and has suggested, both in the Roadmap/Inception Impact Assessment and the Public Consultation, measures (Options 2+3) that would be appropriate and proportionate to address: the Single Market context, the challenge of…

The content of the Digital Service Act Package is a matter of shaping the legal framework for the next decades in an essential and very dynamic business sector. It is a very important project and there is also a need for a swift process. Therefore, it is very important to involve the responsible government representatives in advance so that the legislative project can then be implemented quickly.

BEUC, the European Consumer Organisation, welcomes the possibility to give feedback on the European Commission’s roadmap and inception impact assessment on the e-commerce part of the forthcoming Digital Services Act package. BEUC recommends proposing a comprehensive overhaul of the EU e-Commerce Directive as many problems have arisen for the last twenty years.

The members of the International Video Federation (IVF - ID 7013477846-25) are associations representing businesses active in all segments of the film and audiovisual sector in Europe. Their activities include the development, production, and distribution of films and audiovisual content as well as their publication on digital physical carriers and via all forms of authorised and legal online distribution channels…

OpenForum Europe (OFE) welcomes the opportunity to give input to the public consultation on the Roadmap on ‘DSA package: Deepening the Internal Market and clarifying responsibilities for digital services’. The Digital Services Act’s broad set of objectives means that many different kinds of services fall within its scope.

Warszawa, 30 czerwca 2020 r. Stanowisko Konfederacji Lewiatan wobec Roadmap: "Digital Services Act package: deepening the Internal Market and clarifying responsibilities for digital services" W ramach zapowiedzianego przez przewodniczącą Komisji Europejskiej (KE) pakietu związanego z aktem prawnym o usługach cyfrowych Komisja chce ustanowić nowoczesne ramy prawne dla usług cyfrowych, wzmocnić jednolity rynek cyfrowy…

Filed in Polish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

VAP represents the audiovisual sector in Austria in matters of content protection. Our focus is the enforcement of the rights of SMEs against commercial-scale copyright infringement online and the development of a level digital playing-field for legitimate businesses.

1. IFLA defends and promotes freedom of speech and freedom of access to information, as set out in Article 19 of the Universal Declaration of Human Rights, as the basis of intellectual freedom. The last three decades have seen the rise of digital tools (including major platforms) which have made it possible to amplify the dissemination of knowledge and information, facilitate the discoverability of contents.

The Danish Chamber of Commerce is the second largest business organisation in Denmark and represents more than 15.000 members in different sectors including retail, wholesale and tele companies. We have the following input and suggestions: We share the European Commission’s concern about the online sale of counterfeit, dangerous or illegal products putting citizens at risk and harming law-abiding legitimate…

Please find attached the position paper of the European Commission on the "Inception Impact Assessment on e-commerce aspects (IIA)" prepared by the "Digital Services Act Package: Opening the Internal Market and Cloning responsibilities for digital services.

Filed in Polish · English published by the European Commission

The German Trade Association (HDE) thanked you for the opportunity to comment on the EU initiative for a Digital Services Act. German and European platforms are in international competition. Laws on taxation, customs and product safety, environment, packaging and waste cannot be enforced on non-EU operators to the same extent as on European suppliers and therefore enjoy significant competitive advantages.

Filed in German · English published by the European Commission

The Computer & Communications Industry Association (CCIA) welcomes the opportunity to provide comments on the Digital Services Act’s instrument aiming at deepening the internal market and clarifying responsibilities for digital services. Please find our contribution attached.

EUROCITIES welcomes the Digital Services Act (DSA) proposal. Information society services are the engine of the collaborative economy. However, despite potential for positive economic impact these services exert a strong, and sometimes challenging, influence on cities. The DSA is an opportunity to address the issues that have arisen since the adoption of the e-Commerce Directive.

30 June 2020 The EU Digital Services Act ITI Views on the Inception Impact Assessments: Responsibilities, Gatekeepers Regulation and Competition tools The Information Technology Industry Council (ITI) appreciates the opportunity to comment on the European Commission inception impact assessments and roadmaps on clarifying responsibilities for digital services, regulatory instruments for gatekeepers, and the new…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The ESSTE, a hub for the gathering of hundreds of different actors of different origins that share online content and services, is the best way to raise public awareness of the challenges of economic development of publishers and digital regulation.

Filed in French · English published by the European Commission

The German Association of Tax Consultants (Deutsche Steuerberaterverband e.V.) aims to contribute to strengthening legal certainty and data protection for consumers and service providers on the internet with the following feedback. The opinion also aims to contribute to a higher level of consumer protection in digital services and, as a consequence, to ensure an increase in high-quality digital services.

Filed in German · English published by the European Commission

OLX Group Comments on the European Commission’s Inception Impact Assessment on a “Digital Services Act” June 2020 The OLX Group (OLX Global BV, hereafter “OLX”) is pleased to have the opportunity to comment on the European Commission’s Inception Impact Assessment (IIA) on a “Digital Services Act package: deepening the Internal Market and clarifying responsibilities for digital services”.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Verizon Media welcomes the opportunity to provide initial feedback to the European Commission on the Inception Impact Assessment (IAA) and Roadmap on ‘deepening the Internal Market and clarifying responsibilities for digital services’.

30th June 2020 Feedback of e-commerce aspects of the Digital Services Act Background. The Commission’s general claim is that a few very large online platforms account for a very large share of the digital economy in the EU.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Etsy, the global two-sided marketplace for unique and creative goods, welcomes the European Commission’s announced plans to propose new and revised rules to deepen the Internal Market for Digital Services. We find it reasonable and appropriate for the Commission to define and enforce the responsibilities and obligations of digital services and online platforms, as long as they are properly informed by the lived…

The Imaging Consumables Coalition of Europe, Middle East and Africa (ICCE) welcomes the European Commission’s combined evaluation roadmap/Inception Impact Assessment on the “Digital Services Act package: deepening the Internal Market and clarifying responsibilities for digital services” and the opportunity to provide its initial perspective on this initiative.

Over the last few years, many platforms have developed and delivered services in order to support both the companies in their business and the individuals in their day-to-day activities. Today, we use platforms in almost every sector of our life: health, computing, transport, tourism, etc. In most cases, platforms do not play just like passive intermediaries.

Τhe economic impact of digital markets is multidimensional, and the size of some dimensions is rather significant. The design and the implementation of the proposed initiative should be meticulously examined from both the firm perspective and the consumer viewpoint, aiming for the maximisation of social welfare.

Developers Alliance welcomes the opportunity to provide its input on the IIA on Digital Services Act package. The future regulation governing the provision of online services in the EU should be fit-for-purpose and provide a clear and stable legal framework which will allow businesses to provide a diversity of products and services to consumers, in a safe way and with respect to fundamental rights.

DASA (Danish Automotive Service Association) is in line with FNA in this feedback. We shall stress that there is a significant information- asymmetries through advanced technologies in the automotive industry. Advanced technologies win the automotive industry: on the one hand, the electric car revolutionizes maintenance methods; on the other hand, the increasing connectivity of new "smart" vehicles tends to channel…

Finnish Commerce Federation welcomes the Commissions’ intend to harmonize responsibilities and obligations for digital services including online platforms. We also share the view that this should happen on the European level instead of national level to be effective. Online marketplaces such have become very popular among consumers.

Platforms used as a significant tool for information asymmetries 1. FNA supports the European Commission analysis, i.e. “there is currently a lack of oversight over digital services in the current legal framework, with significant information asymmetries between the services and their users (citizens and businesses).” 2.

Open-Xchange, as the leading European open source software company in the email and DNS space, commends and supports the Commission's effort to address the issues related to illegal and harmful online content. We generally agree with the inception impact assessment as published, and we stress the importance of bringing services without legal establishment in the EU into the scope of the upcoming rules, to ensure…

ROADMAP DIGITAL SERVICES ACT – DEEPENING INTERNAL MARKET & CLARIFYING RESPONSIBILITIES FOR DIGITAL SERVICES COMMENTS In line with BEUC, we suggest that an updating and modernising of the e-Commerce Directive are needed but « if not carefully drafted, the DSA could be a barrier for Member States to protect consumers or correctly address public interest objectives » (BEUC).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ACT agrees that the fundamental principles of the E-commerce directive remain valid. The DSA should provide targeted solutions to tackle specific illegal/ harmful activities whilst being coherent with sector specific regulations and existing CJEU and national case law.

INDICAM, the Italian Association for the protection of intellectual property, praises the EC's purpose to create a strong Single Market environment and tackle the issue of illicit goods promoted and sold on online platforms, by reconsidering the context designed by the E-Commerce Directive, that does not take into account the evolution the digital world has gone through over the past 20 years, therefore risking to…

Response to the EU Commission Impact Assessment for the Digital Services Act: We would like to thank the EU Commission for its Evaluation Roadmap / Inception Impact Assessment for the Digital Services Act. Our contribution focusses on the issue of illegal goods on platforms. Digital transformation has brought major benefits but has also enabled the massive sale of counterfeit products online.

Orange response to the EC Inception Impact Assessment - DSA Package clarifying responsibilities for digital services We welcome the EC’s policy objectives to provide a modernized framework for digital services. We believe that the future DSA package clarifying responsibilities for digital services should strive to provide a high level of legal certainty.

The development of the Digital Single Market is a priority of the EU Commission and has the potential to create sustained, inclusive growth. The evolution of digital services raises new issues that the existing regulations do not always address.

EDiMA welcomes the opportunity to provide feedback to the Commission on this IIA. Given our role at the heart of the digital economy, EDiMA and its wide variety of members can offer first-hand insight into the evolving nature of technology and EU citizens’ relation to it. We are eager to use our shared experience to be a constructive driver of the DSA discussions.

DIGITALEUROPE’s membership fully supports the European Commission’s ambition to strengthen the digital services market in the EU. We agree that clarity is needed on the role and responsibilities of online platforms to make the internet safe. Illegal and harmful content is too prevalent on the internet.

ARD: 6774178922-55 ZDF: 3209361971-85 June 2020 Digital Services Act Package: deepening the Internal Market and clarifying responsibilities for digital services Comments on the combined evaluation roadmap/inception impact assessment ARD and ZDF welcome the opportunity to comment on the combined evaluation roadmap/inception impact assessment regarding the deepening of the Internal Market and clarifying…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

FESI highly welcomes the European Commission’s ambition to adopt “new and revised rules increasing and harmonising the responsibilities of online platforms, and to reinforce the oversight over platforms’ content policies in the EU”. We agree that digital transformation has brought major benefits but also challenges, on top of which the online sale of counterfeit and dangerous products.

- Introduction Cloudflare provides web security, performance and reliability services to a significant portion of the Internet, with a mission to help build a better Internet. While Cloudflare protects websites from malicious cyberattacks and helps the Internet operate more efficiently, it does not provide websites with access to the Internet or generally host their content.

The Counter Extremism Project (CEP) welcomes the opportunity to provide feedback on the European Commission’s inception impact assessment on The Digital Services Act package: deepening the Internal Market and clarifying responsibilities for the digital services.

Considerations on digital platforms in the context of the new Digital Services Act 1. Definition. “Digital platforms” is a rather ill-defined term that describes all online spaces where users engage in commercial and non-commercial interaction with each other (Gillespie, The politics of ‘platforms’, New Media & Society, 2010).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CEEP, the European Centre of Employers and Enterprises providing Public Services and Services of General Interest (SGIs), welcomes the emphasis on the importance of digital services and the Commission’s plan to prepare an ambitious Digital Services Act (DSA) package later this year.

22 June 2020 Ref. Ares(2020)3345933 - 26/06/2020 LARA, CESM og MQF DI-2020-10340 The Commission Response to the Commission on roadmaps for the Commission’s Digital Services Act 1. General remarks The Confederation of Danish Industry (DI) has been asked for our opinion regarding the roadmaps for the Commission’s Digital Services Act. DI acknowledges this and submits the following remarks.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Although improving the functioning of Europe’s Digital Single Market is vital, it is worth reminding that regulation will bring the EU and its companies only so far when it comes to achieving increased competitiveness and productivity in the global digital economy. In short, the EU cannot regulate its way to the top.

• There is an urgent need to create fair competitive conditions in the platform economy. • On the one hand, it is important to have fair contractual terms and conditions between online platforms and the companies offering their services and products on the platforms.

Filed in German · English published by the European Commission