Marybeth Collins
The EU’s latest evaluation of the Digital Services Act (DSA) shows regulators increasingly expect large digital platforms to manage both societal and environmental risks, from traceability to transparency in algorithmic systems. The assessment, published by the European Commission signals that digital governance is evolving into a broader framework that touches sustainability, product supply chains, and the accuracy of environmental information online.
A Shift Toward Systemic Risk Management
The Digital Services Act was initially positioned as a horizontal online safety law focused on illegal content, consumer protection, and platform accountability. But the new report makes clear that the Commission sees Very Large Online Platforms (VLOPs) and Very Large Online Search Engines (VLOSEs) as systemic actors whose influence extends far beyond digital markets. The EU has already designated 25 services as VLOPs or VLOSEs, including fast-growing marketplaces such as Temu and Shein, whose scale and speed of adoption raise new questions about product traceability, supply-chain visibility, and environmental claims.
The Commission confirms that the 45 million monthly-user threshold remains appropriate, emphasizing that platform size correlates with the potential for large-scale societal impact. This includes the spread of misleading environmental information, illegal product listings, and sustainability-related data that influences consumer choices across borders.
Traceability Rules Expand Into Sustainability Oversight
One of the most notable developments is the way DSA provisions are being “plugged into” environmental and product-safety legislation. Requirements such as Article 30 (trader traceability) and Article 31 (compliance by design) are now referenced in the Batteries Regulation, the General Product Safety Regulation, and emerging sector-specific rules.
This connection matters for sustainability teams. Marketplace operators must verify seller identities, track product origin, and maintain transparent records of goods circulating through their platforms. These obligations increasingly intersect with environmental due diligence, as companies face greater scrutiny over chemical safety, waste, recyclability, and lifecycle impacts.
Fast-fashion platforms illustrate why this matters. Shein and Temu were designated VLOPs just months after entering the EU market, reflecting not only user growth but concerns about supply-chain opacity and the sale of products containing restricted substances. Stronger traceability mechanisms could require marketplaces to validate environmental and safety information before products reach consumers.
Algorithmic Systems Face Environmental Responsibility
The Commission highlights a growing overlap between the DSA and the EU Artificial Intelligence Act. As generative AI systems begin to function like platforms—shaping how users consume content, conduct research, and interpret sustainability information—the EU indicates that certain AI systems may eventually face VLOP-level obligations.
For sustainability professionals, this has two implications. First, environmental misinformation amplified through recommender systems becomes a regulatory issue, not just a content-quality problem. Second, transparency requirements for algorithmic ranking could influence how environmental data, green claims, or supplier certifications appear in search results or digital marketplaces.
Meanwhile, research from the International Energy Agency (IEA) and multiple university studies continues to show rising energy and water consumption linked to AI development. As AI becomes more integrated into platform infrastructure, the DSA’s risk-assessment rules may indirectly push companies to consider the environmental footprint of algorithmic systems.
Regulatory Convergence Raises Compliance Pressure
The Commission identifies 54 EU laws that now interact with the DSA, including consumer protection rules, data privacy, copyright, audiovisual media standards, and environmental safety laws. While many of these frameworks complement one another, overlapping obligations create practical challenges for businesses. Stakeholders reported that compliance consumes 15–30% of internal legal and IT resources and often results in duplicative reporting.
For companies operating in digital marketplaces, supply chains, or sustainability-linked sectors, this regulatory convergence means digital governance can no longer be separated from environmental responsibility. Obligations related to transparency, traceability, product safety, and risk assessments now reinforce one another. This is especially impactful as the EU prepares additional updates in 2026, including the Digital Fairness Act and reviews of the AVMS Directive and Copyright Directive.
What Comes Next
The Commission plans a broader “Fitness Check” of the EU digital rulebook, aiming to reduce fragmentation and simplify obligations, particularly for small and medium-sized enterprises. However, it also emphasizes that large platforms will continue to face heightened expectations around risk management, including the societal and environmental impacts of the digital systems they operate.
As digital, environmental, and consumer regulations become more intertwined, sustainability leaders will increasingly find themselves engaging with rules that historically fell under technology and compliance teams. The message from the EU is clear: platforms with systemic reach must now account for systemic risks—environmental risks included.
