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Audit frameworks under the Digital Services Act - an ACT briefing note

Today we are releasing a briefing note on audit frameworks under the European Union's Digital Services Act.

Article 37 audits are one of the most probing and powerful transparency mechanisms under the DSA. Audits entail access to relevant data, access to premises (presumably for inspection of systems and sensitive datasets), and responses to written and oral questions. Each audit report provided to the Commission under article 37 will be accompanied by a redacted version for public release.

In 2023, we expect that DG CONNECT will be publishing and consulting on a delegated act on article 37 audit frameworks under the Digital Services Act. This document is intended to support civil society input into any consultation processes, consistent with the ACT's objectives of coordinating, connecting, and amplifying existing work in this area.

The briefing document was drafted by the Brainbox Institute, in its role as the Project Lead for the Action Coalition on Meaningful Transparency (ACT). It reflects information shared by the ACT’s members but should not be understood to speak for them.

The ACT welcomes further opportunities to engage with regulators and others who will be involved in implementing audit frameworks on this and other issues within our mandate. The ACT will be supporting further discussions about the implementation of audit frameworks and aiming to coordinate and connect others working on this topic. We will also be producing similar briefings on key topics related to implementation of regulatory frameworks for tech transparency.

For further information, please contact us via the website contact form, email, or sign up for the Action Coalition on Meaningful Transparency at

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