Towards Meaningful Fundamental Rights Impact Assessments under the DSA
By Marlena Wisniak, Karolina Iwańska, Eliška Pírková, Vanja Skorič and Boglárka Szalma
The paper argues DSA Article 34(1)(b) fundamental rights impact assessments (FRIAs) risk becoming ‘tick-box’ exercises without harmonized minimum standards. It sets six benchmarks papers must meet — governance grounded in the EU Charter, full scope, sufficient methodological detail, public transparency, a harmonized-but-flexible structure, and regular external stakeholder consultation — plus separate benchmarks for algorithmic content-moderation risks.
Executive summary
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ECNL and Access Now jointly analyzed the gap between the DSA’s Article 34 risk-assessment mandate and the absence of any Commission-set methodology for conducting it. The paper is a prescriptive framework rather than an ex-post audit of filed reports, built from prior human-rights-impact-assessment practice (Danish Institute for Human Rights, Dutch government FRAIA) and UN Guiding Principles on Business and Human Rights. Its core conclusion is that without EU-enforced minimum requirements on governance, scope, detail, transparency, harmonization and stakeholder consultation, VLOP/VLOSE self-assessments will not deliver meaningful accountability.
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