In December 2025 the European Commission fined X €120 million under the Digital Services Act. In July 2026 it fined AliExpress €550 million for failing to deal properly with illegal and unsafe products. If you read only the headlines, the DSA looks like a law about a handful of giants.
It isn't. The giants carry the heaviest obligations, but the DSA is built in layers — and some of those layers reach ordinary businesses in two very different ways: as providers of a digital service, and as users of the platforms they depend on.
You don't need 45 million users to be touched by the DSA. You only need to host someone else's content — or to depend on a platform that does.
The layers, in plain language
The DSA applies to "intermediary services" — services that transmit, store or publish information provided by others. Its obligations stack up:
- All intermediary services — basic duties such as a point of contact and clear terms and conditions.
- Hosting services — anyone storing information on behalf of users must offer a way to report illegal content (notice and action, Article 16) and explain decisions to restrict content (statement of reasons, Article 17).
- Online platforms — hosting services that also make user content public, such as forums, social networks and marketplaces: complaint systems, transparency on advertising, a ban on deceptive interface design ("dark patterns", Article 25), protection of minors.
- Very large platforms and search engines — over 45 million monthly users in the EU: systemic risk assessments, independent audits, data access for researchers.
An ordinary company website that presents your own content is usually not an intermediary service at all. But the moment you let others publish — customer reviews, a community forum, listings from other sellers, user uploads — you may have stepped onto the first rungs of this ladder.
When your website becomes a host
This is where legal knowledge changes the design. Adding a review section or a small marketplace is not only a feature; it is a choice of legal role. If the DSA applies, the build needs a few things that are easy to include at the start and awkward to bolt on later:
- a visible way for anyone to report content they believe is illegal;
- a process for handling those reports — who looks at them, how fast, and how decisions are recorded;
- a short explanation to the user whose content is removed or restricted;
- terms and conditions that say, in plain words, what is allowed and how moderation works.
There is good news for smaller players: micro and small enterprises are exempt from most of the additional obligations for online platforms (Article 19). The basic hosting duties, however, apply regardless of size. Knowing exactly where that line runs saves you from both over-building and under-building.
The part most businesses overlook: your rights as a platform user
For many businesses, the DSA matters most not as an obligation but as a tool. If you sell through a marketplace, advertise on social media or rely on a profile for bookings, the DSA gives you rights you did not have before:
- A reason. If a platform removes your content, demotes it, suspends your account or stops payments, it must give you a clear statement of reasons (Article 17).
- A complaint. Online platforms must offer a free internal complaint system, and decisions may not be taken purely automatically (Article 20).
- An independent review. You can turn to a certified out-of-court dispute settlement body (Article 21).
- Transparency on ads. Ads must show who is behind them and the main parameters used to target them (Article 26).
In practice, a suspended shop or ad account is often treated as a customer-service problem. It is also a legal one — and a business that can cite the right article in its complaint is far more likely to get a real answer.
Selling on marketplaces: traceability
Online marketplaces must collect and verify basic information about the traders who sell through them — name, contact details, registration and payment information (Article 30). If you sell on a marketplace, expect these requests and keep your company details consistent everywhere: on your website, your legal notice and your seller profiles. Inconsistency is one of the most common reasons for delays and suspensions.
A lesson that reaches every website
The DSA's ban on dark patterns formally applies to online platforms. But the principle behind it — don't design interfaces that trick people into choices they didn't intend — also runs through consumer law and data protection law. Pre-selected options, hidden "reject" buttons and confusing cancellation flows are increasingly treated as legal problems, not just bad taste. Honest design is becoming a compliance requirement.
The point
The DSA is a reminder that a digital presence is never only yours. It lives on servers, platforms and marketplaces with their own rules — and now with legal duties towards you. Understanding those rules lets you design features responsibly, and defend your business when a platform gets it wrong.
Planning a review section, a community or a marketplace? We can design it with the right reporting and moderation flow from day one — talk to us about your project.
Lawyer by training, web builder by trade. Goran writes about EU digital law — GDPR, the DSA and the AI Act — and what it means for the people who build and run websites.
Sources
This article is general information, not legal advice. It reflects the law as of its publication date.