Towards More Granular Reasoning: Mapping the DSA Transparency Database Taxonomy to Platform Terms and Conditions Using Large Language Models
Organizations: University of Amsterdam, The Netherlands · Vrije Universiteit Amsterdam, The Netherlands
Abstract
Article 24(5) of the Digital Services Act (DSA) requires providers of online platforms to submit every content moderation decision they make, with a corresponding Statement of Reasons (SoR), to the DSA Transparency Database (DSA-TDB). Such decisions are classified against seventeen high-level attribute categories that categorize the primary reason for the moderation decision. Because over 99.8% of statements cite a violation of the provider's own terms and conditions rather than a legal provision, the database is overwhelmingly a record of contractual enforcement using catch-all reporting; however, whether its categories actually describe those contractual rules well has not been examined. In this paper, we map the terms and conditions (T&C) of 31 designated online services against the DSA-TDB's high-level category taxonomy using a few-shot GPT-4.1 classifier over 447 policy documents. The analysis concerns how T&C rules are represented in the taxonomy, not how they are enforced. Two findings emerge. First, high-level category applicability varies sharply by service type: unsafe products account for 17.5% of e-commerce assignments and 0.2% of adult-platform assignments, and negative effects on civic discourse reaches 9.9% within the Meta family but is absent from adult platforms, Booking.com, and Wikipedia. Second, the categories have notable overlap among sub-category specifications, which makes assigning a single high-level category to a decision difficult. We argue that catch-all reporting is plausibly in part a consequence of the DSA-TDB's schema and attribute design, and recommend a schema that is differentiated by service type with more mandatory attributes derived inductively from platform governance language.
Figures & tables
| Category | Assign. | Category | Assign. |
|---|---|---|---|
| Other violation of T&Cs † | 1,330 | Violence | 220 |
| Intellectual property | 753 | Illegal or harmful speech | 219 |
| Unsafe or prohibited products | 708 | Public security | 210 |
| Scams and/or fraud | 587 | Cyber violence | 185 |
| Data protection and privacy | 570 | Civic discourse or elections | 161 |
| Protection of minors | 557 | Self-harm | 101 |
| Category | Meta | Social | E-com. | Search | Adult | Other |
|---|---|---|---|---|---|---|
| Data protection | 13.5 | 9.8 | 10.8 | 15.0 | 13.9 | 22.5 |
| Unsafe products | 8.8 | 15.8 | 20.5 | 7.2 | 0.4 | 0.8 |
| Consumer information | 4.0 | 6.3 | 15.2 | 8.1 | 0.7 | 28.7 |
| Protection of minors | 13.3 | 13.4 | 7.8 | 9.8 | 25.6 | 10.9 |
| Civic discourse | 15.6 | 4.8 | 0.4 | 2.5 | 0.0 | 0.0 |
| Assignments ( ) | 377 | 1,625 | 1,806 | 641 | 281 | 129 |
Content Moderation
Content moderation studies how to detect, interpret, and respond to harmful or policy-violating material across digital platforms.
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