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Event (10 May): implementing audit frameworks under the DSA

In anticipation of the release of a delegated act on audit under the DSA, we are delighted to announce an upcoming online panel discussion featuring a compelling list of speakers:

  • Emma Llansó (Director, Free Expression Project, Centre for Democracy and Technology)

  • Dunstan Allison-Hope (Vice President, BSR)

  • Dr Rumman Chowdhury (Parity Consulting, Berkman Klein Centre)

  • Jason Pielemeier (Executive Director, Global Network Initiative)

  • David Sullivan (Executive Director, Digital Trust and Safety Partnership)

  • Zak Rogoff (Research Manager, Ranking Digital Rights)

  • Nicolo Zingales (Professor of Information Law and Regulation, Centro de Tecnologia e Sociedade, FGV)

This event will draw from work published by the ACT in a briefing note on implementing audit frameworks under the DSA (available here).

Event description

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.

As an enormously important part of the DSA’s transparency and accountability frameworks, these audits will have global impacts. Redacted audit reports will be published publicly under article 37(4). But uncertainties remain around how audits will be administered and evaluated. These audits differ substantially from those performed in other industries, and will require different skills, approaches, and systems.

In addition to the development and implementation of frameworks for audits, there are parallel mechanisms being implemented for human rights risk assessment, as well as other forms of independent assessment. What are the boundaries between these frameworks, and how best can their integrated or independent features be managed?

Processes for developing audit standards may not be well understood and may not be accustomed to accommodating civil society groups. This session will delve into these questions and provide an opportunity to hear from those closest to the issue about how they’d prefer those questions be answered.

Key discussion questions:

Participants with a question or comment they would like to submit anonymously using the form below.

The discussion will be shaped around the following questions.

  • How do DSA audits align with, or differ from, existing assessment processes under a range of frameworks?

  • What issues need to be addressed before audits can effectively take place under the DSA’s framework?

  • What standard setting processes will be used and how can civil society, researchers etc. best contribute?

  • What do civil society organisations expect to see in audit reports?

  • How can civil society organisations most effectively interface with independent audit firms?

  • What is the role of civil society groups in contributing to the way audits are conducted?

There will be an opportunity for Q&A from attendees and we will allow spillover time for around 10-15 minutes.

Important details

  • Chatham House rule (no attribution of comments)

  • Open invitation

  • Anonymised summary to be prepared for public distribution


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