Performance of independent audits provided for in the Digital Services Act

On behalf of the team at BABL AI, we thank the Commission for the opportunity to provide our thoughts on the draft Delegated Act on Auditing in the Digital Services Act (DSA). As a firm that audits algorithms for ethical risk, bias, disparate impact, and effective governance, we believe that the audit requirements of the DSA are central to protecting EU citizens from harm and align with our mission to promote and…

The 5Rights Foundation welcomes the opportunity to comment on the Commission draft delegated regulation on rules on the performance of audits for very large online platforms (VLOPs) and very large online search engines (VLOSEs) for the purpose of ensuring compliance with the Digital Services Act (DSA).

Dear European Commission, Thank you for the opportunity to submit feedback to the Draft Delegated Regulation on Conducting Independent Audits under the Digital Services Act. My feedback (in the attached document) follows from my experience of conducting independent audits of platforms for privacy violations and algorithmic discrimination.

Dear Members of the European Commission, I am writing in response to your request for comments on the recently proposed legislation, on the Draft of Commission Delegated Regulation supplementing Regulation (EU) 2022/2065 of the European Parliament and of the Council, by laying down rules on the performance of audits for very large online platforms and very large online search engines.

The Global Network Initiative (GNI) is grateful for the opportunity to provide input on the draft delegated regulation on independent audits of very large online platforms and very large online search engines (draft delegated regulation). The role of audits is critical to the DSAs overall compliance and enforcement architecture.

As a global audit firm, Mazars welcome the DSA and the DMA as EU pioneering initiatives to create a safer digital Internal Market and stands ready to contribute to their successful implementation. Independent and consistent audits will play an important role in achieving DSA endgoals: the transparency and accountability of major digital players in the Union.

The Commission has requested feedback on the Delegated Regulation supplementing the Digital Services Act (Reg. 2022/2065) and annex. The Delegated Regulation lays down the framework for conducting an audit as mandated by art. 37 DSA. All VLOPs and VLOSEs must be subject to an external independent audit ensuring they comply with the various commitments of the Digital Services Act.

The Delegated Regulation (DR) builds upon established sector-specific risk management frameworks to provide procedural guidance for AI audits. However, the regulation lacks provisions to disclose normative methodological choices that underlie AI systems, such as recommender systems, which is crucial for evaluating associated risks in a meaningful way (as mandated by DSA Article 34).

The Global Disinformation Index (GDI) is a not-for-profit organisation focused on defunding and disrupting disinformation. We welcome the opportunity to submit the following response as a proposal for strengthening Article 37 of the DSA through a delegated act.

The European Contact Group, which represents the six large accounting networks in Europe, is pleased to provide feedback on the draft Delegated Regulation laying down rules on the performance of audits for very large online platforms and very large online search engines.

The Wikimedia Foundation is the non-profit organization that hosts Wikipedia. We support the global Wikimedia movement whose mission is to bring free educational content to the world. As a service provider, we work to empower communities to collaborate in creating and collecting content and making moderation decisions together.

AlgorithmWatch and AI Forensics welcome the opportunity to provide feedback to the European Commissions work on a Delegated Regulation, which further specifies principles and procedures for independent, second-party audits within the Digital Services Act (DSA) framework.

Dear Commission Team, We are Eticas Tech and since 2012 we have built a track record as a global leader in practical and applied AI ethics. We have a proven methodology for conducting end-to-end, socio-technical algorithmic audits (E2EST/AA) on high-risk systems and social media platforms where AI is increasingly used to make decisions impacting individuals and society, but also its applicability to low or…

The Digital Services Act is poised to shape the platform auditing ecosystem for years to come, in the EU and beyond. This is therefore a critical window within which to foster a trusted and healthy auditing ecosystem, and to ensure the functioning of this key compliance measure. In our attached recommendations we encourage the European Commission to: 1.

Chris Riley and Susan Ness, distinguished fellows at the University of Pennsylvanias Annenberg Public Policy Center, thank the Commission for this public consultation. We recognize that the scope of independent audit under the Digital Services Act covers all the providers obligations under the DSA. Our feedback focuses specifically on one key component: the risk assessment required by Article 34.

ForHumanity and ForHumanity Europe are providing specific responses to the Delegated Acts on a Recital and Article by Article basis. They can be found in the attached document - at the bottom of the attachment we have appended our DSA certification scheme for the Commission's consideration as to how and when it might be useful.

Dear Commission Colleagues, Please find attached a short feedback document from myself, Sally Broughton Micova and my colleague Andrea Calef that elaborates on the following: Summary The effective, transparent and inclusive auditing of very large online platforms and very large online search engines will be crucial to ensuring that the Digital Services Act (DSA) meets its policy objectives in relation to preventing…

On behalf of Deloitte , we are pleased to provide feedback on this draft Delegated Act (DA) concerning the performance of independent audits. At the outset, we note that Article 37 Independent Audit is a key provision for the Digital Services Act (DSA).

SNV is grateful for the opportunity to provide feedback to the Commissions draft delegated act on independent audits in the Digital Services Act (DSA), which we provide in the attached document. We applaud the Commission for its early work on this draft which shows a willingness to focus strongly on audits for very large online platforms (VLOPs) and very large search engines (VLOSEs), a novel and key aspect of the…

The European Tech Alliance (EUTA) emphasises the importance of establishing a balanced and clear framework that ensures consistency, particularly considering the diverse business models within scope. The forthcoming Delegated Act under the Digital Services Act (DSA) provides an opportunity to provide better guidance, standards, and safeguards for audits.

Dear European Commission, Many thanks for opening this valuable public consultation on independent audits under the EU Digital Services Act. I am providing this response to the public consultation in a personal capacity as an academic working in this field and do not wish to be perceived as speaking for the whole of TU Delft or the TPM Faculty.

We welcome the Commission's aim to provide guidance to the wide range of professionals who may seek to perform independent audits under the DSA, an area where assurance practice is at an early stage. However, the draft Regulation raises significant issues for i) potential DSA auditors and ii) audit report users (EU and Member State oversight bodies, civil society, etc). We outline four main areas of concern below.

Hello there, I'm writing with some feedback from the group I co-lead at the Global Partnership on AI, that works on social media governance, and specifically on recommender systems. We have researched methods for studying the effects of social media recommender systems on platform users, in particular in domains of harmful content.