site.btaFrom Framework to Enforcement: How EU Countries Are Applying the Digital Services Act

The EU Digital Services Act (DSA) has moved from institutional preparation to practical enforcement. Since the regulation fully came into force on February 17, 2024, Member States have shifted focus from designating competent authorities and national rules to supervision, inspections, sanctions and coordination with the European Commission.

Implementation follows a two-tier model: the Commission oversees very large online platforms and search engines with systemic impact on the EU market, while national Digital Services Coordinators (DSCs) supervise other intermediaries, handle user complaints, and conduct initial national checks. Coordination occurs through the European Board for Digital Services and the AGORA information-sharing platform.

Ireland: Hub of Platform Oversight

Ireland plays a central role, hosting the European headquarters of major tech companies such as Meta, Google, TikTok, and X. Its regulator, the Media Commission (Coimisiún na Meán), is among the busiest in the EU due to the high volume of cross-border cases. Ireland places strong emphasis on "trusted flaggers" - NGOs and public bodies whose reports of illegal content platforms are required to prioritize. This mechanism is actively used in cases involving child protection, online violence and serious violations.

France: Transparency, Disinformation and E-Commerce

France approaches the DSA from a public-interest perspective. Its regulator, ARCOM, focuses on algorithmic transparency, combating disinformation, and monitoring online trading practices. French authorities are particularly active against manipulative dark pattern interfaces and participate in EU-wide investigations into dangerous or illegal goods sold online.

Germany: Data Access and Research Oversight

Germany emphasizes independent researchers' access to platform data. The Federal Network Agency (Bundesnetzagentur) has developed mechanisms for meeting the requirements for providing data for scientific purposes. Between May 2024 and the end of 2025, the agency received around 850 complaints, mostly about unclear reporting procedures, poorly justified removal decisions, or restrictions on accounts, content and access to services. The government sees digital product passports as a key tool for more effective enforcement of safety rules. This tool would significantly ease regulatory checks on products sold via online platforms.

Bulgaria: Catching Up on Enforcement

In Bulgaria, the Communications Regulation Commission acts as the DSC. For Bulgarian users, the DSA introduces new complaint and appeal mechanisms against insufficiently justified content removal or account blocking. In 2025, the European Commission took action against Bulgaria for incomplete and delayed implementation, including gaps in the DSC's powers and the national sanctions framework. The country has since enacted the necessary legal changes, enabling full participation in the system.

From "Soft" Regulation to Sanctions

The clearest sign that the Digital Services Act (DSA) is now functioning as an enforcement tool is the initiation of concrete investigations and sanctions at the European level. The European Commission has launched multiple probes against major platforms for breaches of transparency obligations, failure to assess and mitigate systemic risks, and inadequate protection of minors.

In 2025, the Commission imposed the first significant fine under the DSA, against X, demonstrating that the regulation carries real enforcement power.

Official proceedings were also opened against TikTok in February and April 2024, AliExpress in March 2024, and Meta in April and May 2024.

By mid-2025, the Commission announced that the Chinese online retail giant Temu was violating EU law by failing to adequately prevent the sale of illegal products on its platform. Data indicated a high risk that EU consumers could encounter prohibited goods. A mystery shopping analysis conducted by Commission experts revealed that shoppers on Temu were likely to find non-compliant items among the offerings, including children's toys and small electronics.