Global comparison
The EU set the standard. The Digital Services Act is the only regime that forces platforms to open their ad libraries, hand data to vetted researchers, assess systemic risk, and submit to independent audit, all under a regulator that can fine them a share of global turnover. So we asked a simple question of the rest of the world: how much of that do other countries actually require?
We scored 30 non-EU jurisdictions across 6 regions against the DSA’s obligations, grouped into transparency, accountability, and child protection. The pattern is stark: DSA-style transparency machinery is almost entirely EU-unique, while the one area where the rest of the world is moving fast is protecting children.
The map
Only the EU's 27 member states have comprehensive DSA transparency protection. A handful of others (the UK, Singapore, Brazil and India among them) have built substantial partial regimes, and a wider group has early or partial efforts. Of the 30 non-EU jurisdictions we researched, the rest offer nothing comparable; every country we haven't tracked is left grey.
Grading follows each country's DSA-alignment index in the matrix below. Base map: @svg-maps/world (CC BY 4.0).
The scoreboard
Every jurisdiction scored against the same 11 obligations, with the EU DSA pinned on top as the benchmark. Green means the law requires it; amber means partial or emerging; red means no such obligation. Each row links to the full, source-cited breakdown.
| Jurisdiction | Transparency | Accountability | Child protection | DSA alignment | ||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Ad library | Transparency reports | Researcher access | Reach disclosure | Risk assessment | Independent audit | Algorithmic transparency | Regulator + fines | No ads to minors | Age assurance | Child-safety duty | ||
| European UnionBenchmark | 95% | |||||||||||
| Europe (non-EU) | ||||||||||||
| United Kingdom | 41% | |||||||||||
| North America | ||||||||||||
| United States | 5% | |||||||||||
| Canada | 0% | |||||||||||
| Oceania | ||||||||||||
| Australia | 27% | |||||||||||
| Latin America | ||||||||||||
| Brazil | 36% | |||||||||||
| Colombia | 9% | |||||||||||
| Argentina | 5% | |||||||||||
| Peru | 5% | |||||||||||
| Mexico | 0% | |||||||||||
| Chile | 0% | |||||||||||
| Middle East | ||||||||||||
| United Arab Emirates | 23% | |||||||||||
| Turkey | 9% | |||||||||||
| Israel | 0% | |||||||||||
| Saudi Arabia | 0% | |||||||||||
| Qatar | 0% | |||||||||||
| Kuwait | 0% | |||||||||||
| Bahrain | 0% | |||||||||||
| Oman | 0% | |||||||||||
| Jordan | 0% | |||||||||||
| Egypt | 0% | |||||||||||
| Asia | ||||||||||||
| Singapore | 41% | |||||||||||
| Malaysia | 41% | |||||||||||
| Indonesia | 36% | |||||||||||
| India | 32% | |||||||||||
| South Korea | 32% | |||||||||||
| Taiwan | 32% | |||||||||||
| Japan | 27% | |||||||||||
| Philippines | 18% | |||||||||||
| Vietnam | 18% | |||||||||||
| Thailand | 14% | |||||||||||
The DSA-alignment index weights every obligation a jurisdiction fully meets as 2 points and every partial one as 1, out of a maximum of 22. It measures how closely a country's lawtracks the DSA's obligations, not how well platforms comply. Each row links to the full, source-cited breakdown. The checkmarks cover DSA-style, user-protective transparency and accountability only. A censorship or content-takedown regime is not scored as transparency. Last reviewed 15 July 2026.
On the horizon
The matrix scores the law in force today. But the DSA is spreading. These are the countries with live bills, drafts and consultations for DSA-style transparency and accountability: the “Brussels effect” in motion. We exclude pure child-safety and content-control measures; this is about who is debating the transparency machinery itself.
Comprehensive proposals for transparency, accountability and a platform regulator.
Platform Accountability and Transparency Act (PATA), S.3292
NSF-facilitated vetted-researcher access to platform data, mandatory public ad libraries, disclosure of recommender/ranking systems and content-moderation statistics, plus legal protections for researchers and journalists.
Latest: Reintroduced in the Senate as S.3292 in the 119th Congress (2025) by Coons, Cassidy, Klobuchar, Cornyn, Blumenthal and Romney. source ↗
Online Safety Act 2023 + Data (Use and Access) Act 2025 (researcher access)
Systemic-risk duties, transparency reporting and an empowered regulator (Ofcom) under the OSA, now extended by a statutory framework for independent-researcher access to platform data.
Latest: Data (Use and Access) Act received Royal Assent June 2025; Ofcom published its researcher data-access report and roadmap in July 2025. source ↗
Online Harms Act (Bill C-63) to Safe Social Media Act (Bill C-34)
A Digital Safety Commission, a statutory duty to act on harmful content and platform digital-safety plans/transparency obligations, now paired with a proposed under-16 social-media ban.
Latest: C-63 died on prorogation Jan 2025; the government reintroduced the Digital Safety Commission via Bill C-34, the Safe Social Media Act, in June 2026. source ↗
Draft Digital Platform Economy Act (PEA)
A near-copy of the DSA's tiered intermediary classification (mere conduit / caching / hosting), VLOP designation, annual transparency reports, advertising labelling and a Digital Platform Economy Committee with revenue-based fines.
Latest: Released by ETDA for public consultation 15 Jan to 15 Feb 2025, expanding the in-force 2022 Digital Platform Services royal decree. source ↗
Digital Intermediary Services Act (DISA)
An explicit DSA clone with tiered obligations, transparency reports, risk assessments and a new regulator for very large online platforms.
Latest: NCC halted drafting in September 2022 after public backlash; no formal revival as of 2026, though it remains the reference template for future action. source ↗
PL 2630 'Fake News Bill' + STF platform-liability ruling
Algorithmic transparency, annual transparency reports, moderation due-process and independent oversight in PL 2630, echoed by the Supreme Court's DSA-inspired procedural duties on platforms.
Latest: PL 2630 stalled in Congress since 2023; on 26 June 2025 the STF struck down part of Marco Civil Art. 19 and imposed DSA-style transparency/self-regulation duties. source ↗
Bills that pick up some DSA-style duties without the full framework.
PL 074/2025 (social-media platform regulation)
Platform transparency, content-moderation and advertising duties, mandatory disclosure of algorithms used to moderate/rank/recommend content and a local-office requirement, alongside minor-protection rules.
Latest: First-debate committee report (ponencia) filed in the Chamber of Representatives in October 2025. source ↗
Digital Duty of Care
A statutory duty requiring platforms to run ongoing systemic-risk assessments, apply mitigations and publish transparent reporting, enforced by the eSafety Commissioner with penalties up to A$100M.
Latest: Government published its 'Digital Duty of Care for Australia' framework paper in May 2026 with draft legislation expected later in 2026; the separate misinformation-transparency bill was withdrawn Nov 2024. source ↗
Information Distribution Platform Act (IDPA)
Designated large platforms must publish and apply content-removal standards, disclose moderation practices and meet response deadlines, overseen by the MIC, which has signed a DSA-enforcement cooperation arrangement with the EU.
Latest: Took effect 1 April 2025; MIC designated Google, LINE Yahoo, Meta, TikTok and X as large platforms on 30 April 2025. source ↗
Digital India Act (to replace the IT Act 2000)
Risk-based classification of platforms, algorithmic/recommender transparency and enhanced intermediary accountability, alongside deepfake-labelling and traceability provisions.
Latest: The long-promised DIA remains in draft with public consultation expected in 2026; MeitY issued interim IT Rules amendments on synthetic/AI-generated content in Oct 2025. source ↗
Boletín 14.785-24 (digital platforms & social networks)
Transparency and due-process in content moderation, user appeal rights, disclosure of ranking algorithms, a local legal representative and fines, though criticised for conditioning removals on prior court rulings.
Latest: Under review in the Chamber of Deputies as one of two competing platform bills; limited movement through 2025 to 2026. source ↗
A single DSA-adjacent element inside an otherwise different bill.
Online Safety (Relief and Accountability) Act + Online Safety Commission
Designated social-media services must file annual online-safety/transparency reports to IMDA and provide reporting tools, with a new Online Safety Commission empowered to order takedowns and victim redress.
Latest: The Online Safety Commission began operations on 29 June 2026 under the OSRAA regime, building on the 2023 Code of Practice for Online Safety. source ↗
Online Safety Act 2024/2025 + social-media class licensing
A risk-based duty of care requiring platforms to publish an Online Safety Plan and safety guidelines and enable reporting, plus an MCMC class-licence regime for platforms with 8M+ users.
Latest: The Online Safety Act came into force 1 January 2026; MCMC deemed major platforms licensed from 2026, with penalties up to RM10M. source ↗
Bill on addictive algorithms / protection of minors (Brügge)
Bans addictive design aimed at minors and requires data-protection impact assessments, a local legal representative for foreign firms and audits/sanctions by the data-protection authority, but is centred on child protection.
Latest: Presented in June 2026, part of a wave of Argentine bills targeting addictive platform design and minors. source ↗
The method
The checkmarks measure DSA-style, user-protective transparency and accountability. A censorship, licensing, or content-takedown regime is not scored as transparency, even where a country regulates platforms heavily. Child-protection obligations are drawn from any source law, not only the DSA, because that is where most of the world is legislating.
Does the law force platforms to open up — ads, moderation, reach, data?
Public ad library
DSA Art. 39 — A public, searchable library of every ad the platform shows, with an API.
Transparency reports
DSA Art. 15 / 24 / 42 — Regular public reports on content-moderation activity.
Researcher data access
DSA Art. 40 — Vetted independent researchers can access platform data to study systemic risk.
Reach disclosure
DSA Art. 24(2) — Platforms publish user-reach / active-user numbers on a fixed cadence.
Is there a duty to assess risk, submit to audit, and answer to a regulator with teeth?
Systemic risk assessment
DSA Art. 34–35 — A duty to identify and mitigate systemic risks the service creates.
Independent audit
DSA Art. 37 — External auditors verify compliance on a recurring basis.
Algorithmic transparency
DSA Art. 27 / 38 — Recommender parameters disclosed, with a non-profiling feed option.
Regulator + penalties
DSA Art. 49–52, 74 — A dedicated regulator empowered to levy meaningful fines.
Are minors protected by age assurance, an ad-targeting ban, and a duty of care?
No profiling ads to minors
DSA Art. 26(3) / 28 — A ban on advertising targeted using minors' personal data.
Age assurance
Beyond the DSA — A legal duty to verify or estimate users' age to protect minors.
Child-safety duty of care
DSA Art. 28 — A duty of care and/or child-specific risk assessment protecting minors.
The DSA is only the benchmark because it has teeth. See the proceedings, the fines, and the compliance gaps behind every checkmark in the EU column.